In a recent 10th Circuit decision, Health Grades, Inc. v. Decatur Memorial Hospital, the court found abuse of discretion in a lower court's failure to entertain evidence of frequent website use and consent to an online user agreement when looking at the issue of personal jurisdiction.  This copyright case involved the hospital's refusal to pay license fees with respect to ranking information posted on the Health Grades site.  The information was subject to an online user agreement.  The 10th Circuit panel ruled that the lower court erred in dismissing the case on jurisdictional grounds.  The decision bodes well for the enforcement of online user agreements.  It is also interesting that the court focused on the number of times the hospital visited the website, indicating that the decision may have some bearing on browse-wrap agreements.