The basis of Zippo Manufacturing's claims was Dot Com's use of the word "Zippo" I in domain names in numerous locations on its websites and in the message title of the Internet newsgroup that were published by Zippo dot com subscribers. Dot Com sought dismissal for lack of personal jurisdiction. Zippo Manufacturing filed a complaint against Dot com for trademark dilution, false designation, and under the Federal Trademark Act and state trademark law. The Court established a three-pronged test to determine whether a court has jurisdiction over a website. Under the test, the likelihood that personal jurisdiction can be constitutionally exercised is directly balanced against the nature and quality of the merchantable or commercial activity that an entity conducts on the Internet. Under Zippo there is a “continuum” of escalators for measuring websites, which fall into three general categories