Horowitz, a Michigan lawyer, and his firm advised a Canadian company K.D. Trihn, Inc., in the marketing of notes and certificates in Florida through Florida agents in public seminar presentations. Horowitz advised that the notes and certificates were not securities under Florida law, which would require registration and would require licensure of agents. Wendt, one of the Trihn agents, later was sued for failing to meet the registration and licensure requirements. Wendt responded by bringing Horowitz into the suit as a third-party defendant. Horowitz moved to dismiss, arguing that Florida had no jurisdiction over him. The trial court ruled there was jurisdiction, but the Fifth District reversed on grounds that Horowitz' actions had not taken place in Florida.