Where Internet Jurisdiction Can Get Your Business Sued!

The concept of Internet jurisdiction can be complicated and unclear. What happens when a dispute arises over an item or service purchased from your business through the internet? If that dispute turns into a lawsuit, it could be with an individual residing across the country from your business. What happens then? If you live in California, could your business actually be dragged into a state court in Maine?

Any business with an Internet presence should understand how courts gain authority to hear claims made against out-of-state businesses. The bottom line is that establishing Internet jurisdiction over your business can potentially end up being very costly!

Establishing Internet Jurisdiction Over Your Business

No matter what the subject of the dispute is about, a court must have what is known as “personal jurisdiction” over all the parties involved. This applies to all courts, including state and federal district courts. Establishing personal jurisdiction means that the court has the legal power to make a binding decision over the plaintiff and the defendant in a given dispute. State and federal courts always have personal jurisdiction over state residents. But, when the defendant’s principal residence or place of business is not in the state where the lawsuit is filed (often called the “forum state”), matters are much more complex. This is often the case with suits involving e-commerce.

(Note: A corporation is treated as a citizen of the state in which it is incorporated and the state in which its principal place of business is located. A partnership or limited liability company is considered to assume the citizenship of each jurisdiction of its partners/members. If you understand the nature of how a court can gain jurisdiction to hear a claim filed against your business, you can avoid certain practices that may expose you to out-of-state claims.)

The Concept of Minimum Contacts

One way a foreign court can claim personal jurisdiction over your business is by establishing that some sort of meaningful connection exists with the state in question and your business. States can exercise jurisdiction over your business through their “long-arm statutes” (which I discuss separately). However, the Due Process Clause of the U.S. Constitution mandates that certain “minimum contacts” must exist between the forum state and the defendant in order for a state to assert jurisdiction over the defendant. This basically means that activities which are deemed to establish substantially sufficient contacts with the residents or businesses of a particular state can be used by its courts to establish jurisdiction over your business. For example, you are not subject to the personal jurisdiction of an out-of-state court simply because you are involved in an automobile accident with a resident of that state where you live. All the events necessary to give rise to the claim occur outside the state of the other resident.

Activities establishing minimum contacts with another state are not always clear, but usually any substantial presence in the state will justify personal jurisdiction. Regularly soliciting business in that state, deriving substantial revenue from goods or services sold in that state, or engaging in some other persistent and continuous course of business conduct in the state are all examples of activities that would establish minimum contacts with that state.

Minimum Contacts Define Internet Jurisdiction

As stated, the concept of minimum contacts becomes more complicated when it involves the Internet. The courts have recognized that exposing the owners of a website to personal jurisdiction simply because the website can be viewed nationally is not enough to establish minimum contacts in a given state. Personal jurisdiction is “directly proportionate to the nature and quality of commercial activity that a business conducts over the Internet.” Businesses that enter into contracts or subscriptions with residents of another state that involve the “knowing and repeated transmission of computer files over the Internet will be subject to the jurisdiction of out-of-state courts. But, websites that only post information without making active sales are unlikely to establish personal jurisdiction in a foreign state (except in the state where the owner(s) resides or conducts other business).

The ‘Zippo’ Sliding Scale Guide

Generally speaking, minimum contacts for Internet retailers and marketers are directly related to the nature and quality of electronic contacts they establish with residents of another state. In other words, mere advertising alone is not enough to establish jurisdiction. Most courts across the nation have adopted the “sliding scale” approach used in Zippo Manufacturing Co. v. Zippo Dot Com, Inc. (1997). The court in Zippo determined that the act of processing the applications from Pennsylvania residents and assigning passwords was sufficient to demonstrate sufficient minimum contacts with the state. But, the Court held that jurisdiction is not proper when a website passively posts information on the Internet which may or may not be viewed by residents of that particular jurisdiction.

In the Zippo case, the district court described a spectrum consisting of three categories websites fall under. This spectrum ranges from: 1) businesses clearly conducting commercial activities over the Internet by entering into contracts with residents of the forum state; 2) interactive web sites with which a user in the forum state can exchange information and jurisdiction is proper if the level of interactivity is sufficient and there is a commercial component to the web site and 3) web sites which are “passive” by merely allowing users to post information accessible nationwide or globally that do not target a particular plaintiff in a particular forum (i.e. by intentional trademark or copyright infringement or in cases of defamation). Basically, under the Zippo sliding scale jurisdiction is more likely to be established when your Internet business engages in commercial activities directed at residents of a given state.

Of course, many cases fall in the middle of the Zippo sliding scale. In these instances, the courts generally have determined that “the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information that occurs on the website.” Making multiple sales to state residents is likely to expose an Internet-based business to personal jurisdiction in that state. A single sale may also be enough, provided it is accompanied by numerous intentional communications with a resident customers so that the transaction can be said to be purposefully aimed at the residents (or businesses) of that state.

Typically, the courts require “something more” than passive Internet advertising or more than just a single sale for jurisdiction to exist over a non-resident Internet business. Jurisdiction is often triggered by repeated or commercially significant sales to out-of-state residents, deliberate target marketing to out-of-state residents or significant non-Internet based contacts with the state.

State Long Arm Statutes

All states have enacted “long-arm statutes” setting forth what will be considered sufficient contacts with that state. In a nutshell, the long-arm statute allows that state’s courts to gain personal jurisdiction over Internet businesses. These statutes form the legal basis allowing the courts to exercise personal jurisdiction over your business. Under these statutes, service of process outside the state on nonresident individuals and businesses is allowed for claims generally arising out of: (1) the transaction of any business in the state; (2) the commission of a tortious act within the state; (3) the ownership, use, or possession of real estate in the state; or (4) contracting to supply goods or services to any person or business in the state; or 5) causing injury or damage in this state to any person by breach of warranty expressly or impliedly made in the sale of goods; 6) contracting to insure any person, property, or risk located within this state at the time of contracting; 7) an act or omission outside the state causing injury in the state.

State courts typically exercise personal jurisdiction over Internet businesses under the “transacting business” provision of the long-arm statute. Like the Zippo court, state courts will look at jurisdiction in an Internet setting by looking at the “nature and quality” of the contacts with the state. Some Long-arm statutes set forth factual situations likely to satisfy the minimum-contacts test. Others contain much broader provisions not inconsistent with constitutional restrictions.

Helpful Case Summaries

Here is a summary of some decisions that have helped shape the law regarding internet jurisdiction. Hopefully, these summaries can provide some guidance.

  • Thompson v. Handa-Lopez, Inc. (1998): A Texas court gained personal jurisdiction over an out-of-state online gambling enterprise because the gambling operation entered into contracts with Texas residents to play online gambling games, sent emails to the Texas residents, and sent winnings to Texas residents;
  • ChloĆ© NA v Queen Bee of Beverly Hills LLC (2010): The US Second Circuit Court of Appeals held that specific personal jurisdiction over an out-of-state website operator located in California may exist based on a single act of shipping a handbag into New York, along with other substantial business activity in the state. The single act of shipping an infringing handbag to New York combined with other substantial contacts, such as the shipment of several other items in-state and operating a commercial interactive website available to New York residents was sufficient to obtain specific personal jurisdiction;
  • Verizon Online Services, Inc. v. Ralksky (2002): The court held that nonresident defendants’ transmission of spam emails through plaintiff’s servers, located in Virginia, to nonresident Internet subscribers created a substantial connection to forum sufficient for exercise of personal jurisdiction on a claim of trespass to chattel;
  • Gates v. Royal Palace Hotel (1998): The court decided that the combination of a concentrated advertising effort within the state of Connecticut, active booking of reservations for Connecticut citizens through state travel agents, and an invitation to Connecticut citizens to make reservations through the Internet, constituted the transaction of business within the state such that exercise of personal jurisdiction was proper.

Causing an Injury within a State

Your Internet business can also be subject to jurisdiction in another state for purposefully causing a physical or economic injury (i.e. a “tort”) to a business or resident of that state. This is a separate avenue of liability outside of a breach of contract claim where your business is dragged into court by one of your unhappy customers. If you use the Internet to cause an injury in one state, you or your business may be brought into court in the state where the injury occurred. For example, under state long arm statutes, committing a tortious act within the state is a basis of jurisdiction.

Of course, in cases where the connection between the activity and the injury is not clear, courts have looked for evidence that the activity was “purposefully directed” at the resident(s) of the forum state, or that the person causing the injury had substantial contacts with the state. Most courts are less inclined to exercise personal jurisdiction over non-residents in cases involving tort claims arising from Internet use. Generally speaking, an Internet business must direct its activities at an in-state resident, or have a continuing obligation with that resident, in order reasonably to anticipate being hauled into court in the state.

But, not all torts or injuries will expose your business to the personal jurisdiction of another state. Even if a plaintiff claims to feel the effects of the harm caused by an act causing injury in his or her forum state, there must still be “something more” than mere Internet use to satisfy due process under the Constitution. Purposeful conduct may still be insufficient in jurisdictions where the activity must be directed at the plaintiff in his or her capacity as a resident of that particular state.

More case examples:

  • EDIAS Software International v. BASIS International Ltd. (1996): A New Mexico company was sued for sending defamatory email and making defamatory postings about an Arizona business. The court claimed personal jurisdiction because the defamatory statements intentionally targeted the Arizona business and actually caused an injury (defamation) within the state.
  • Pavlovich v. Superior Court (Cal. 2002): Under the “effects test”, the trial court did not have jurisdiction over a foreign resident in a corporation’s suit alleging the resident misappropriated its trade secrets by posting the corporation’s program’s source code on his website. The website was accessible to any person with Internet access and the resident merely posted information and had no interactive features. The court determined that the resident could not have known that his tortious conduct would hurt the corporation in California when the misappropriated code was first posted and this did not establish express targeting of California residents.
  • Blumenthal v. Drudge (1998): In another early decision, Matt Drudge of The Drudge Report made alleged defamatory statements about a Washington, D.C. resident on his website and the resident filed suit in the District of Columbia. Although Matt Drudge lived and worked in California at the time of the suit, a court ruled that he was subject to personal jurisdiction in the District because the injury occurred in the District. The court also determined that the Drudge Report had substantial contacts in D. C. since Drudge personally emailed his column to a list of emails belonging to D.C. residents, solicited contributions and collected money from D. C. residents and he traveled to D. C. on two occasions to promote his column. All of this was enough for the court in that case to determine that Matt Drudge had substantial contacts with the District;
  • Cybersell, Inc. v. Cybersell, Inc. (1997): An Arizona plaintiff suing for trademark infringement argued that a Florida defendant’s mere use of the same trademark in its home page was sufficient for personal jurisdiction. The Florida defendant had “no contacts with Arizona other than maintaining a home page that was accessible to anyone over the Internet.” The court declined to exercise jurisdiction, noting the Florida defendant “did nothing to encourage residents of Arizona to access its site, and there [was] no evidence that any part of its business (let alone a continuous part of its business) was sought or achieved in Arizona.” The circumstances lacked the “something more” necessary “to indicate that the defendant purposefully… directed his activity in a substantial way to the forum state.”

Consenting to Jurisdiction over Your Business

A court can obtain personal jurisdiction if both parties consent to such jurisdiction. The most common type of consent is where a company is required to consent, in advance, to personal jurisdiction in a state for incorporating or organizing a business under the laws of that state. State business organization statutes require that a business provide the secretary of state with an agent to accept service of process. An Internet business can also consent to the court’s jurisdiction by filing a response to a lawsuit filed with that court.

Similarly, you may grant consent by signing a contract that has a provision requiring you agree in advance to be subject to the personal jurisdiction of a state. For example, a California website developer may sign an agreement with an Illinois service provider containing a clause stating: “The parties consent to the exclusive jurisdiction of the federal and state courts located in Cook County, Illinois, in any action arising out of or relating to this agreement. The parties waive any other venue to which either party might be entitled by domicile or otherwise.” (However, the States of Montana and Idaho do refuse to recognize such clauses).

You have now been introduced to the catch 22 of e-commerce! The Internet provides a great way for small businesses to operate and achieve massive growth. Unfortunately, such growth will inevitably expose your business to foreign jurisdiction and the ability to be hauled into court in some distant State. If you want to guarantee that you will avoid this risk and you plan on operating a commercial website, you will surely sacrifice sales and growth.

SportGamble.us Picks this Year’s College Football Bowl Games

Here are the consensus bowl picks from the SportGamble.us staff.

Tue., Dec. 14

New Orleans Bowl

North Texas vs Southern Mississippi

SG’s Pick: North Texas

If the So. Miss defense can stop Jamario Thomas from adding to his gaudy stats they should be able to keep this one close.

7:30 pm

Tue., Dec. 21

Champs Sports Bowl

Georgia Tech vs Syracuse

SG’s Pick: Georgia Tech

7:45 pm

Wed., Dec. 22

GMAC Bowl

Memphis vs Bowling Green

SG’s Pick: Bowling Green

I want to pick Memphis to win this battle, but the Falcon’s scoring offense, 4th in the nation, will simply outscore Memphis regardless of how well they play.

8:00 pm

Thur., Dec. 23

PlainsCapital Fort Worth Bowl

Cincinnati vs Marshall

SG’s Pick: Marshall

Marshall has shown up to play in big games this year. I consider a bowl game a “big” game, wouldn’t you?

6:30 pm

Las Vegas Bowl

Wyoming vs UCLA

SG’s Pick: UCLA

UCLA should burn Wyoming with it’s passing and running game. Although, Wyoming is playing in it’s first bowl game in 11 years…that’s certainly motivating.

9:45 pm

Fri., Dec. 24

Hawaii Bowl

UAB vs Hawaii

SG’s Pick: Hawaii

NCAA’s all time passing leader should have a hay-day against this no show UAB defense

7:00 pm

Mon., Dec. 27

MPC Computers Bowl

Fresno State vs 18 Virginia

SG’s Pick: Virginia

Fresno State failed to play with the big dogs this season and Virginia is on the horizon to become one.

2:00 pm

Motor City Bowl

Toledo vs Connecticut

SG’s Pick: Toledo

Connecticut has a football team? Well, that’s what we would have said last season but they have a QB that can rip the secondary. You probably haven’t heard of him but the NFL scouts know him very well. Connecticut has a chance if they grasp the mindset they had when meeting Pittsburgh earlier in the year.

5:30 pm

Tue., Dec. 28

Independence Bowl

Iowa State vs Miami (Ohio)

SG’s Pick: Iowa State

Iowa State’s explosive offense will give Miami all they want…plus some.

6:30 pm

Insight Bowl

Oregon State vs Notre Dame

SG’s Pick: Notre Dame

Notre Dame is going to fight its heart out in defense of Tyrone Willingham. Oh, did we mention they’re a pretty good football team anyway?

9:45 pm

Wed., Dec. 29

Houston Bowl

Texas-El Paso vs Colorado

SG’s Pick: Texas-El Paso

Jordan Carson (name sound familiar?) will finally have his chance to showcase his talent on national television. Colorado is still wondering what happened in the Big 12 championship…

4:30 pm

Alamo Bowl

24 Ohio State vs Oklahoma State

SG’s Pick: Ohio State

Oklahoma State is no stranger to big games. Unfortunately, they haven’t learned how to win them.

8:00 pm

Thur., Dec. 30

Continental Tire Bowl

25 Boston College vs North Carolina

SG’s Pick: Boston College

North Carolina has a lack of “big game” experience while Boston College has the “secret to success” for winning bowl games, they’ve won 4 straight.

1:00 pm

Emerald Bowl

New Mexico vs Navy

SG’s Pick: Navy

Did we say Navy? That’s right! These guys finally learned how to play football.

4:30 pm

Holiday Bowl

4 California vs 23 Texas Tech

SG’s Pick: California

Cal will punish Texas Tech for being pushed out of the BCS picture.

8:00 pm

Silicon Valley Bowl

Troy vs Northern Illinois

SG’s Pick: Northern Illinois

Troy has never been to a bowl game and they’re not ready to win one either. N. Illinois has a ground attack that will out-muscle this Troy defense.

11:00 pm

Fri., Dec. 31

Music City Bowl

Alabama vs Minnesota

SG’s Pick: Alabama

This isn’t because we like the SEC. Minnesota isn’t playing at home…

12:00 pm

Sun Bowl

Purdue vs 21 Arizona State

SG’s Pick: Purdue

Arizona State is coming with their 2nd string QB that Purdue’s young, yet darn good, defense should contain. Expect Purdue to light up the score board in this one!

2:00 pm

Liberty Bowl

10 Boise State vs 7 Louisville

SG’s Pick: Louisville

This may be bowl game of the year. If you like fast attack offenses and aggressive scoring, this game is for you! Vegas will be exploding with “total points” bets on this one.

3:30 pm

14 Miami (FLA.) vs 20 Florida

Peach Bowl

SG’s Pick: Florida

If Chris Leak (Gators) isn’t the best QB in the land he will be. When the Gators are operating on all cylinders I would pick them to beat anyone in the country. Keep an eye on this one because it should be a money maker!

7:30 pm

Sat., Jan. 1

Cotton Bowl

15 Tennessee vs 22 Texas A&M

SG’s Pick: Tennessee

The Vols simply ran out of time in the SEC championship. I suspect they will pick up where they left off. Neither team “should” be here so it will definitely be one of the better games to watch.

11:00 am

Outback Bowl

16 Wisconsin va 8 Georgia

SG’s Pick: Georgia

Wisconsin can play offense buy GA’s fast defense will stop the run and force Wisconsin to throw resulting in too many mistakes to overcome. Georgia wins.

11:00 am

Gator Bowl

17 Florida State va West Virginia

SG’s Pick: Florida State

Florida State has put the lost to Florida behind them. Bowden’s ability to dominate bowl games has a “W” written all over it.

12:30 pm

Capital One Bowl

11 Iowa vs 12 LSU

SG’s Pick: LSU (restrictions apply…)

LSU is young but managed to fight their way to a good bowl game this year. If LSU’s defense can keep the score close they can pull this one off.

1:00 pm

Rose Bowl

13 Michigan vs 6 Texas

SG’s Pick: Texas

If Mack can persuade his players they’re as good as he did the nations coaches Texas will overcome a solid Michigan team.

4:30 pm

Fiesta Bowl

5 Utah vs 19 Pittsburgh

SG’s Pick: Utah

Pittsburgh slipped through the back door to win the Big East but I’m afraid Utah will show Pitt what it’s like to play with the Big Boys.

8:30 pm

Mon., Jan. 3

Sugar Bowl

3 Auburn vs 9 Virginia Tech

SG’s Pick: Auburn

Auburn should be playing for the national title. Look for Auburn to win big for the slight possibility of sharing the title.

8:00 pm

Tue., Jan. 4

Orange Bowl

1 Southern California vs 2 Oklahoma

SG’s Pick: Oklahoma

This one should come down to the last quarter. Oklahoma should prevail with stamina.

8:00 pm

Isla Verde, Puerto Rico Casinos

Fashionable Isla Verde, Puerto Rico is the destination of choice for many visitors to the island these days. Not only is the area home to several top notch hotels, but it is close to the airport, the lively city of San Juan, and an easy drive from top tourist attractions. The area boasts beautiful beaches as well as fine dining and entertainment, and gaming enthusiasts will find a number of Isla Verde casinos to sample.

From the crystal chandeliers to the nattily dressed staff, everything about the casino in the El San Juan Hotel and Casino whispers elegance. Gamblers can enjoy live shows that they can see from their seats at the tables and slot machines in this Puerto Rican casino, and televisions broadcasting sporting events are placed where gamblers can watch. The casino features a variety of slot machines and table games like blackjack, roulette, craps, poker and mini baccarat.

El San Juan Hotel & Casino

6063 Isla Verde Avenue

Carolina, Puerto Rico 00979

787-791-1000

The Courtyard by Marriott Isla Verde Beach Resort is home to the Casino del Sol. Not only can gamblers enjoy more than 400 slot machines and table games like baccarat, craps, roulette, poker and blackjack, but they can wager on horse races and take part in lotteries.

Casino del Sol

7012 Boca de Cangrejos Avenue

Carolina, Puerto Rico 00979

787-791-0404

At the casino in the Ritz-Carlton there are around 380 machines, including slots and other gaming machines. If you want games, they’ve got plenty. Spend a thrilling evening playing roulette, let it ride, mini baccarat, blackjack and several different versions of poker.

Ritz-Carlton San Juan Casino

6961 Avenue of the Governors

Carolina, Puerto Rico 00979

787-253-1700

The Intercontinental San Juan Resort boasts table games like blackjack, roulette, craps, poker, Caribbean stud poker and three card poker. More than 300 gaming machines are available for play at this Isla Verde casino, including video lottery.

Intercontinental San Juan Resort & Casino

5961 Isla Verde Avenue

Carolina, Puerto Rico 00979

787-791-6100

World’s Top Golf Resorts: Train and Play for Your Vacation!

The finest golf resorts in the United States, Europe, Mexico and the Caribbean can be your choice for your next vacation. Make it a train-and-play golf vacation! So many package deals are available to make your trip much more than a break from your routine. A golf vacation will be a practical experience of improving your golf game, enjoying a phenomenally peaceful and luxurious setting, and visiting a different state or a different country! This planning guide will point you to some of the best-rated golf resorts in the world.

Whether you ultimately book for yourself or through an experienced golf travel specialist, begin your research online where you can find premium golf courses and travel bargains. Rates, resort amenities and golf course details are available. But look further for the packages that include airfare, hotel accommodations and green fees to get your best value. The typical packaged Golf Resort Vacation will include most of these features:

  • Airfare
  • Resort Accommodations
  • Confirmed Tee Times
  • Prepaid Green Fees
  • Shared Cart for 18 Holes
  • Equipment Rental
  • Golf Lessons
  • Meals at Exclusive Restaurants
  • Transfers to the Course
  • Transfers to the Airport
  • All Taxes and Service Charges

Golf courses are planned in lovely surroundings where you can take in sea breezes or views of lush vegetation, and you can combine golf with other resort amenities to provide a well-rounded vacation.

For instance, try one of the many glamorous Club Med Golf Resorts with beautiful fairways in the most unforgettable, inviting locations around the world. Club Med offers deals including the best equipment and golf lessons for all levels! Its locations include Cancun, Mexico, as well as Punta Cana in the Dominican Republic. Other locations span the world: Turks and Caicos, Mauritius, Portugal, France, Italy, Brazil, Thailand, Morocco, Egypt, Senegal, and in the United States–Sandpiper Bay, Florida.

Scotland has some of the most beautiful golf courses in the world and there are approximately 100 resorts, called “golf hotels,” among the 500-plus golf courses throughout the country. Best known are Turnberry, Gleneagles and The Old Course Hotel St. Andrews. Each of these has spa, leisure facilities, excellent restaurants and “golf tuition” packages for all levels.

Mexico has numerous golf resorts perched in luxurious coastal locations. There are golf resorts at Cancun, Acapulco, Puerto Vallarta and Los Cabos. Also, Mexico has its championship Baja version of California’s famous “Pebble Beach” golf resort, called Bajamar, only a few hours’ drive from San Diego in Ensenada.

For the United States, check online for some of the golf resorts suggested by key magazines such as Golflink‘s which publishes The Top 100 United States Golf Courses. This issue ranks the best out of more than 21,000 public and private golf courses across the country. However, within that one hundred courses, you want to search for the resorts with package programs and golf lessons. Among the top hundred, you will find that the main vacation-destination states with golf resorts are in Arizona, California, Florida, Nevada, South Carolina and Texas. Let’s review these states for their best locations:

  • In sunny, always temperate Florida, Club Med’s Sandpiper Bay Golf Academy offers 2-day and 3-day golf courses. The Academy includes all aspects of the game, such as Chipping, Putting, Bunker, Pitching and Lob Shot, Full Swing with Irons and Woods. A video analyzing your swing is provided, as well as an optional video comparing your swing to that of a pro player. Also, the area within and around Miami has regional golf resorts for year-round vacationing. Each resort offers on-site amenities and services, both on and off the course, and minutes away from major Miami attractions, like South Beach and Miami MetroZoo. You will have a multitude of options during a golf vacation here.
  • Arizona has a climate that is suitable for many months of the year and Scottsdale has nearly 200 golf courses, many with the picturesque backdrop of the Sonoran Desert. It is a golf destination with golf schools and pro shops. Here, many resorts offer high-quality accommodations and championship golf courses. Most golf resorts offer packages where hotel guests can have discounted green fees. Also, Sedona, Arizona, offers numerous golf resorts with a mild year-round climate and spectacular red-rock scenic views.
  • In California, Pebble Beach has been known for being a small coastal golf destination nestled in beautiful Monterey County. It is home of the prominent Pebble Beach Golf Links, the Pebble Beach Lodge and the prestigious Inn at Spanish Bay. Each year, golfers return to rub shoulders with golf professionals and experience nature at its finest on the magnificent golf course laid out by leading golf course designers. The harmony of golf layouts and the majestic coast are awe-inspiring!
  • Another golfer’s paradise is conveniently located along the south Atlantic coast at Hilton Head Island, South Carolina. It combines natural beauty and world-class golf on a barrier island 12 miles long and five miles wide. Nicklaus, Palmer and other golf legends have frequently played these championship courses. Since the first course opened at Sea Pines in 1961, there are now emerald links at Harbour Town and outstanding courses in Bluffton, as the Hilton Head area has become a major golf center. It is legendary for its spectacular views of the Atlantic Ocean, scenic marshes, and maritime forests with abundant wildlife. The temperate climate and year-round sunshine also makes Hilton Head Island the perfect place to tee off.
  • Las Vegas, Nevada, is quietly emerging as one of the United States’ fastest growing golf destinations amidst the glitz and glamour of its casinos. The city’s huge convention center and innumerable hotel rooms make it a natural haven for large-scale golf events. With the year-round sunshine and mild temperatures, and plenty to do after a full day of playing golf from gambling to seeing entertaining shows, this golf destination will continue to grow.
  • CNN ranked Austin, Texas the No. 1 city for golf in its Golf.com of 2010. Framed by the Texas Hill Country, Austin’s golf courses are among the best in the United States. The region is highlighted by the Wolfdancer Golf Club which was named No. 56 in Golfweek‘s top 100 resort golf courses in 2009. In addition to being a great contemporary music city, and home of numerous celebrities, Austin offers vacationing golfers great barbeque, an idyllic, year-round climate and luxury accommodations.

Your best package deal will be at all-inclusive resorts, where air flight, lodging, meals and golf activities are rolled into one price. On the other hand, consider traditional hotels and resorts in the locations suggested. With a little online planning, one of the finest golf resorts in the world can be your affordable choice. Enjoy the location, the exploration of the region while you improve your golf game and provide a joyful, well-rounded vacation for your family and loved ones!

(c) 2012 Elizabeth McMillian