A federal judge in Kansas has dismissed the age verification lawsuit against Titan Websites, operator of the adult tube site HentaiCity.com. As the first age verification case filed by a private plaintiff to reach final resolution, the ruling suggests that private plaintiffs can lack personal jurisdiction to sue out-of-state website operators under the Kansas statute. The defendant was represented by Jeffrey Sandman of Sandman Law LLC.
Jane Doe v. Titan Websites, Inc., was filed in May 2025 by an unnamed plaintiff on behalf of her teenage son. The plaintiff alleged her son was able to access the defendant’s website in violation of Kansas law.
On Tuesday, the judge granted the defendant’s motion to dismiss the case, ruling that the plaintiff lacked personal jurisdiction to bring the suit. 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.
“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 decision that Titan Websites was based in another state, with 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 defendant purposefully aimed its conduct at Kansas, the judge dismissed the case. Importantly, the ruling did not address whether the website 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 ruling is 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.