Cross-Border Torts Over the Internet

Does a resident of State A commit a tortious act within State B by posting defamatory statements on a website accessible by users located in State B?  The Supreme Court of Florida thinks so.  In Internet Solutions Corp. v. Marshall, the court held that if material posted on a website about a Florida resident is not only accessible in Florida, but actually accessed by a person in Florida, that is sufficient to constitute the commission of the tortious act of defamation within Florida.  Comparing the following hypotheticals illustrates why the court is wrong.

First, suppose that a resident of California sends a letter to a resident of Virginia containing a defamatory statement about a Florida resident.  Nobody could reasonably argue that a tortious act was committed in Florida, even though the alleged tortfeasor must be aware that the recipient may copy and distribute the defamatory statement to whomever he wants, including Florida residents.  Moreover, if someone from Florida were to contact the Virginia resident and ask for a copy of the defamatory statement, I doubt that many courts would find that the California resident committed a defamatory act when the Virginia resident mails a copy of the letter to the Florida resident.

Now, suppose that a resident of California puts defamatory information on a website stored on a Virginia server.  Along comes a person in Florida who points their web browser to the internet address containing the defamatory information and sends a request to the Virginia server for the file containing the defamatory information.  According to the logic of the Florida Supreme Court, when the Virginia server transmits the information to the Florida resident, the California resident is actually committing a tort.  The absurdity of the result is apparent.  There is no meaningful difference between the two hypotheticals, yet the court would presumably treat them differently.