above, that is not the proper legal standard. 10 . Defendant submits that this is too remote, and that for confusion to be a direct effect, the international consumers would themselves need to be confused, come to America, and pass that confusion along to the point that Bell’s sales would decline more than a trivial amount. Def.’s Mem. at 4-5. 11 . Bell cites other cases supporting the proposition that the harm caused by copyright or trademark infringement is inflicted at the location of the injured company, but CYBERsitter is its most relevant supporting case. The other cases were used to establish personal jurisdiction over the defendants, not subject-matter jurisdiction, and they did not involve the FSIA. See Penguin Grp. (USA) Inc. v. Am. Buddha, 640 F.3d 497, 500-01 (2d Cir.2011) (<HOLDING>); McGraw-Hill Cos. v. Ingenium Techs. Corp.,
holding that a district court may assert personal jurisdiction over a nonresident defendant to the extent permissible under the law of the state in which the district court sits holding that the superior court had no jurisdiction over the division of marital property when the district court had properly invoked jurisdiction over the property holding that the court had no jurisdiction over an alleged breach of a plea agreement holding that the district court had personal jurisdiction over the defendant when the site of a copyright owners alleged injury is the location of the copyright owner holding that court did not have personal jurisdiction over nonresident defendant because plaintiff failed to show that defendant was assignee of assignor over whom court had personal jurisdiction