lp solutions may i reserve two minutes for rebuttal thank you are that the question presented in this appeal is whether there are sufficient minimum contacts between defendants and state of maine to support specific personal jurisdiction more particularly the critical issue is whether jurisdiction over defendants in was foreseeable under the purposeful of ailment element at the trial court level and the jurisdiction is proper in the state of maine looking at the standards for bailment it is important to note that under existing precedent only one contact with a form is needed so long as it is meaningful under burger king the test for foreseeability requires that defendants contacts must be of a nature that defense could reasonably anticipate being held in to court this court has analyzed whether the defendant has benefited from its for forseeable the supreme court burger king also stated that a defendant purposely avails itself when its actions create a substantial connection with the form this court has state that a substantial connection can arise whenever the defendant deliberately directs his efforts toward the form state based on the standards the inquiry is there for in contact with defendants deliberately directed their efforts to the obligations between the dependents and resident forms have been created the answer these questions is yes you know brief we've noted a number of contacts that are substantial and meaningful the key contact i'd like to identify are start with the contrasts themselves the option agreements and sign agreements which call for long term obligation payments to his emotions in the state of maine this speaks to the continuing obligation aspect of the contract cost analysis in addition in the honor if you look at the option agreement that requires payment l p s and l p s is defined in the first paragraph as being limited liability company with the principal place of business that to seventeen  your honor the way i would describe it is that the limit of partnership interest is essentially a payment stream and lp solutions purchased that payment stream from the defendants after the assignment agreements were consummated at the of the defendants there was a very large distribution from the from the partnership and based on the large size of the situation it was what you might call seller's remorse they did not for those distribution still be solutions even though had they had done so in the there is litigation going on in illinois in which the heart said i i believe that the family members could not substitution as a limited partner and then assignment of an economic interest and in the illinois matter the general partner has taken issue with what it used to be substitution of limited partnership status and also the benefit of the remainder the consideration consents confirmations checks made checks deliver the payments to me and i would refer the court to the opinion in adams versus adams which has an identical fact that adams versus adams it was a promissory note and the recipient of the payment sort of a promissory note was identified as residing in massachusetts but the case but the note did not otherwise identify where the payments by the policy were to be sent and the court relied on that well i think it depends for relatedness purposes we don't we don't think so the question for relatedness purposes is first formation and second breach if the contract did not require us to deliver payments into maine then we couldn't have breached in maine when we failed to do that i think floor for c ability purposes the fact that the payments were sent to maine is we can see that's a relevant contact for purposes of prosy ability but the key point there is that they were insignificant in number if you contrast the number of payments in our case to the number of payments in cases like upward to a very large number of payments so the contrast i would draw would be between for instance copia communications which only analyzes for c ability and which includes a few discrete payments into the for jurisdiction but nevertheless as you know that's just not enough it's not enough payments it's not enough contacts versus something like baskin robbins which was a multi decade franchise relationship with analysis about where the contract was formed he applied restatement section sixty three b which is under for option contract so we believe that the appropriate section is section sixty three which is for a typical contract i think the confusion here is around the fact these contracts were titled option contract but that that term is not though the usage of the term option contract in every statement but a restatement an option contract is a contract where the offer was ability to revoke is limited by the offer or there's nothing in the record to suggest that these were those sorts of contracts so this was a standard contract that in it so under section sixty three a that type of the second point on formation is putting aside what the restatement may say about when you've crossed the line into a form to contract when contract law deems that to  that question doesn't change the facts of what actually happened what actually happened was they call called us in illinois we had no idea who they were or how they got our names and phone numbers they then followed up with continued solicitations all directed until annoy and we we never trouble to maintain a goshi at the contract and so putting aside what contract law says about when the contracts were formed from a personal jurisdiction perspective the actual contacts as they those they sent us these mailings out of the blue we received them they then followed up with a phone call in to illinois that they initiated that phone call again that they introduced into your door we told them we don't like what you sent us and they said well we have option b why don't we send you off should be we then agreed to receive option b but we didn't reach into maine with any sort of counterproposal we didn't draft any of these documents they were all off the shelf and sent to us  direct the court's attention to appendix page one hundred fourteen which i believe temporal already is the first reference to this tax question to the specific question about these eight hundred eighty two forms  that is a letter from l p s again directed into illinois and the letter says the general partner thinks these transactions are not kosher but it doesn't agree with them on what we want you to do or what we will ask you to do is please send us your tale ones and we will send you back be eighty two forms so with respect to these this is the what i would call a dialogue it's two points of right to make with respect to relatedness even if they were somehow related it's a very dim in this factor compared with the fact that there was a formation and a breech both in illinois so that's what i would say with respect to the relevance of tax to the relatedness with respect to foreseeability then yes i make but the point that you just made your honor with respect to proceed billy they initiated the tax a dialogue not us are family members executed an assignment document that would in our view would least what we think the purpose of the contracts what was the execution of that assignment transfer the entire partnership interest to l p s and but the general partner says that they're no good but you have all mine oh we have received all of that the allegation your honor is that we have all along we think illinois is a far more appropriate forum for this case and alternately contracts related to formation and one of the contacts were to breach all of the formation and breach contests we argue all occurred in illinois and we think we think you can affirm judge won't be ruling based on his reasoning relevant and we do have payments that are being sent to me in the regular basis over a multi year period counsel also made note of the quantity of payments this court and also the supreme court has been very clear about not applying a mechanistic approach it's every case that rises or falls on its own merits there is a constellation of facts that have to be analyzed and then this court makes a decision as to whether it's appropriate to maintain jurisdiction or not so i don't think that there's any magic number of payments the duration if you look at burger king there's reference to the duration of the relationship as opposed to the number of payments per se and i think that we have a very long duration here in this instance with respect