From the High Court of Australia, to the Fourth Circuit, and now the Fifth Circuit, jurisdiction issues as they apply to Internet libel cases are in the spotlight. The Fifth Circuit, in Oliver “Buck” Revell v. Lidov and Columbia University, affirmed the United States District Court For the Northern District of Texas decision that Revell, former Associate Deputy Director of the FBI under Reagan, and a resident of Texas, could not sue the author of an article critical of his role in the Pan Am Flight 103 tragedy over Lockerbie, Scotland in 1988, that was posted on a Columbia University owned website.