LOS ANGELES—Adult industry trade group the Free Speech Coalition (FSC) announced in a statement on Wednesday that a court in the state of Kansas has dismissed a set of age verification lawsuits.
The following was published on FSC's blog:
A federal judge in Kansas has dismissed two of the four private age verification lawsuits filed in May 2025 by an unnamed plaintiff on behalf of her teenage son. As the first age-verification cases filed by a private plaintiff to reach final resolution, these rulings suggest that private plaintiffs may lack personal jurisdiction to sue out-of-state website operators under the Kansas statute.
On Tuesday, the judge granted the defendants' motions to dismiss in Jane Doe v. Titan Websites, Inc. and Doe v. ICF Technology Inc., ruling that the plaintiff lacked personal jurisdiction to bring the suits. The judge found that simply operating a website accessible in Kansas – even one that Kansas residents could view – is not enough to establish liability. Under the U.S. Constitution, courts may only exercise power over defendants that have deliberately targeted or conducted activities in the state. Allowing lawsuits based solely on website accessibility, the court explained, would mean any website could be sued anywhere, a result long rejected by federal courts.
Defendant Titan Websites was represented by Jeffrey Sandman of Sandman Law LLC. "Judge Teeter issued a thorough, thoughtful, and persuasive decision reminding that personal jurisdiction involves a constitutional dimension that cannot be overwritten by a state legislature," says Sandman. "Due Process demands that a defendant without meaningful contacts with a forum state cannot be dragged into court to defend a lawsuit there. We are pleased to see these critical constitutional principles vindicated and hope that the Kansas Legislature will rethink its brazen effort to subvert the First and Fourteenth Amendments."
The court emphasized in its decisions that the defendants had no offices or employees in Kansas, no advertising or sales directed at Kansas, and no intentional targeting of Kansas users. Because the plaintiff could not show that the defendants purposefully aimed their conduct at Kansas, the judge dismissed the case. Importantly, the rulings did not address whether the websites violated Kansas’s age-verification law – only whether Kansas was the proper forum to decide that question.
“Yesterday’s ruling provides critical guidance for platforms who are confronted with laws in Kansas and elsewhere,” says Alison Boden, Executive Director of Free Speech Coalition. “While not precedent-setting, nor necessarily applicable in every case, the District Court’s rulings are an important victory against state laws enforced by private rights of action. In the meantime, the threat of litigation is real, and we encourage our members to continue to comply with all applicable laws.”
The plaintiffs have thirty-days to file notice if they intend to appeal the ruling.
Two related private age verification lawsuits (Doe v. Multi Media LLC and Jane Doe v. Techpump Solutions, SL) are still pending.
