QUESTIONS: If the following suit is filed in California, what is the realistic expectation of compelling the out of state defendant to appear, and also would the judgment be recoverable in the defendant's home state of Mass? Also, I've looked up the Civil Code section governing this and although it allows for "Exemplary damages" I cannot find an explanation of what monetary limits there may be on them (if any) and if California allows the plaintiff to collect them or if they instead go to the State.

FACTS: I'm the aggrieved party and have a very strong cause of action for libel which meets the standard for libel so far for every state in which I've looked it up. The libelous party is a moderately high income earner and HAS attachable assets so that a damage recovery should be possible. The libeled party is a private individual, operating as a nationwide online business. The libelous party posted the libel in an internet forum that the party hosts and publishes him/herself, with the entire forum having the express intention of disparagement. The libel is provably false by a volume of documentation. The libelous party can be shown to have been acting with both a) Negligence and b) Malice. The libelous party has a clearly written intent a) to put libeled parties out of business b) to continue that activity. There are indications that the libelous party may seek to profit from the activity. The libelous party has cohorts engaged in similar activity which makes the case for exemplary damages to deter others even stronger.

PROBLEM: As with many libel cases, the actual damages are very real but impossible to monetize since potential customers turned away by the libel cannot be documented. The libelous party resides in Massachusetts which does not allow for punitive(exemplary) damages for libel. The libeled party is based in California.

QUESTION: Can the cause of action be brought in a state other than Massachusetts where the libelous party lives? (The libel is published on a website hosted by a California based company, and defames a California based party). If so, will there be difficulty actually compelling the party to appear in that state? Will a judgment in another state be enforceable in Massachusetts in so far as any necessary liens, garnishments, etc. And if so, what then is the best state to bring such a case in (if not California), specifically as it pertains to the awarding of punitive damages? (Some states don't allow punitive for libel. Some that do require bifurcated trials, separating trial for actual damages from the trial for punitive damages. Some that do allow punitive require that 100% go to the state rather than the aggrieved party, others, a different percentage to the state, etc. What does California law require in that regard, OR where can I look that up?) Any help is greatly appreciated!