states are not standing still waiting for Quill to be overturned, but instead are moving aggressively to use the tools at their disposal. For example, in April 2008, New York State passed legislation asserting nexus for any retailer that has sales affiliates in the state that generate a combined total of $10,000 or more annually in revenues for the retailer.38 In 2009, at
least two state legislatures (Rhode Island and North Carolina) have enacted laws that assert nexus when remote retailers compensate in-state websites for displaying the retailer’s advertisements.