Zyskind v. Elena Koss

A nonresident corporate officer is subject to personal jurisdiction in Florida courts if the officer directed fraud or other intentional misconduct at parties in the State of Florida. The court's sole inquiry and determination is whether the tort as alleged occurred in Florida, not whether the alleged tort actually occurred. Directing a conspiracy and tortious conduct toward Florida satisfies both specific long-arm jurisdiction and the due process concerns implicated in a minimum contacts analysis. If a plaintiff has successfully alleged a cause of action for conspiracy among the defendants to commit tortious acts toward the plaintiff, and if the plaintiff has successfully alleged that any member of that conspiracy committed tortious acts in Florida in furtherance of that conspiracy, then all of the alleged conspirators are subject to the jurisdiction of Florida through its long-arm statute.