given the rigorous requirements for establishing a famous mark. See, e.g., Washington Speakers, 33 F.Supp.2d at 502-03. (noting that famous marks must meet high standard and that marks famous only in specialized segment of market may be protected from dilution, if at all, only when diluting uses are directed narrowly at same market segment). In any event, these issues need not be resolved given the uncontested applicability of § 8.01-328.1(A)(4). 10 . In Bochan, the constitutional prong of the analysis was satisfied by the purposeful direction of the defamatory remarks at a Virginia defendant regarding activities presumably occurring in Virginia. See Bochan, 1999 WL 343780, at * 5, — F.Supp.2d at —; see also Calder v. Jones, 465 U.S. 783, 789-90, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (<HOLDING>); First American First, Inc. v. National Ass’n
holding that the ninth circuit is bound by the california supreme courts interpretation of california law holding that california courts assertion of personal jurisdiction over floridabased reporters did not violate due process when allegedly defamatory article that was the basis of the suit focused on the california activities of california residents recognizing that california has a valid interest in protecting a california company from copyright infringement holding that personal jurisdiction in california was appropriate over nonresident journalist where harmful effects of allegedly defamatory article would be exclusively felt in california and california was the state of newspapers greatest circulation recognizing a hypothetical situation where california law left a party free to sue on a claim in maryland even after the claim was precluded in california because the california statute of limitations had expired