I don't know if we can purely look to the content of the speech to determine whether it was directed into a state. I think whether speech is directed into a state should be content independent. I mean... if he said the same thing in a New Jersey bar or on a phone call with someone in California, would Florida have jurisdiction? No.

The way I look at it is like this: He sent a letter to California. Florida officials walked into California and looked at the letter. That's how the internet works. People in Florida requested data from a post directed, at best, into California.