Pueblo De Bahia Lora, S.A., is a Costa Rican corporation owned by two U.S. citizens. It operates a fishing resort in Costa Rica called "Parrot Bay Village." Oldfield, a Florida resident, came across the Parrot Bay website, which is in English, uses a U.S. mailing address, and provides a toll-free number for potential guests to call. Oldfield made a reservation online and went to the resort. When at the resort, he went on a fishing trip on a charter boat. That arrangement was made by Parrot Bay, but the boat was owned and operated by a Costa Rican. Oldfield suffered an injury that he claims was due to the negligence of the boat operator. He sued Parrot Bay in federal court, claiming diversity of citizenship.
Parrot Bay did not respond; Oldfield was awarded a default judgment for $750,000 as requested. Parrot Bay appealed. What argument is on Parrot Bay's side? [Oldfield v. Pueblo de Bahia Lora, S.A., 558 F.3d 1210 (11th Cir., 2009)]