this case is about smoking in the philippines planning this trip to mars i live in the philippines for the first sixty five years of his life and filed this lawsuit one week after he arrived in the united states he smoked salem cigarettes in the philippines for his entire adult life based upon advertising and marketing that he was exposed to in the philippines he claims that he developed can just give  chronic obstructive pulmonary disease as a result of smoking sales of cigarettes which was first diagnosed while he was still living in the philippines he claims that reynolds failed to warn consumers in the philippines about the health risks of smoking specifically he claims that reynolds manipulated the political and legislative process in the philippines to delay health warnings on cigarette packs and association in the philippines the philippine tobacco institute to mislead the public about the health risks of smoking mr rich wasn't using himself a lawyer in the  ramos contact with the state of washington are similar to its contacts in most other states and we submit do not support general jurisdiction in this i guess your position would be its corporate headquarters or manufacturing plants that you can't get general jurisdiction over rounds anywhere in the united states well i'm not sure exactly where the line is your honor and i don't think the supreme court has ever indicated exactly where the line is our position is certainly that where there is only a low small local sales presence there is not an interest under international sho from those activities whether there is no question that reynolds has substantial sales of cigarettes to wholesale customers in washington as it doesn't ever state but if sales volume alone were enough for general jurisdiction then virtually every fortune five hundred company would be subject to general jurisdiction if every city we submit sales by alone is not enough nor is having the small local sales has a small sales office with six or seven full time employees and in addition employees for approximately thirty to thirty three sales personnel who work out of their homes to call on the retail accounts reasonable  philippines for nearly thirty years after they were required to the united states plain it was alleging that reynolds misused the legal system in the philippines in order to further delay the effective date of health warnings conduct in the united kingdom and elsewhere but no hundreds in the state of washington but these are the sorts of issues we certainly are more appropriately decided in the philippines by filipinos w i think and another point that i would like to make is that apart from failing to consider the interests of the philippines if just for core fail to consider the interests of other states  headquartered that is to the state of washington where reynolds has no contacts that have anything to do with the philippines and no contacts with any have anything to do with sales outside the washington  territorial imitation of them the power of the respective states basically in this case can perceive on a general jurisdiction basis in washington it's really hard to see how  fortune five hundred company would be not subject to general jurisdiction in a century every state i don't think that's the law the supreme court has certainly never said that i don't believe this court has  had the power to impose reasonable conditions including a waiver a person dressed action and requested specifically that of the court did that better preserve around all statute of limitations defense used upon three centered in the united states and conducted in the united states for more than forty years and that that conspiracy was internationalized by the american conspirators through their that all fifty states in the united states a couple years ago settle an action against the major backer manufacturers in the united states including rentals is going on here purchases patients in a fifty year long conspiracy line where we can say on one side federal jurisdiction exists on the other side it doesn't exist i think the guiding principle for the court is does this the defen of washington each year if perry has a very efficient sales organization forty five full time employees we don't know how many parts time employees they have they may have known the question i think was asked to discover gold was ready answer but they may have some but they're here to make a lot of money in washington they have a big impact on the state they feel on taxes the state of washington they derive benefits  return they benefit by being able to sell those hundreds of millions of cigarettes there the market share leader in washington which is not their position nationally so they sell more cigarettes to the state of washington company their business enjoy the all the privileges and pleasures of a business permitted to do business in the state of washington her question police possible for every fortune five hundred corporation united states has a substantial continuous presence in every state and i think it's possible that in those cases genders diction might be asserted but that's there it was an alien place coming there from south america to texas to try to find a favorable form to pursue this case against the to document it fractures in this case moved to was and is a legal resident of the united to assert general jurisdiction over in the united states district court for the western district of washington massive in scale both in monetary terms in terms of the members of summers they do business with in terms of the number of units cigarettes or cigarette packs of cigarettes cards are really wished character continuous ongoing if rebels derive substantial benefit from his presence in idaho then the latvian who's become a citizen of the state of vital to be entitled to pursue his or her p guess and it's simply a guess and i certainly would be difficult for mr was and for me to move to the philippines to try this case i kind of suspect it might be sort of difficult for reynolds to pack up and move to the philippines the current case counsel mentioned the other side effect of the interstate judicial systems of interest in the most efficient resolution of the controversy and again i suggest the district court dealt with this in her discussion of reasonable going to be felt for the loss of his ability to economically contribute to the economy of the state is going to be felt that's all here it's all in washington then he does take the question there of the much broader allegations  the conspiracy centered in the united states that the major united states manufactures and their identified in the complaint together with a couple british benefactors of cigarette per product basically fifty three to conspire in the united states to conceal the truth about cigarettes to do everything they could to make sure that the public was confused as to whether cigarettes could harm them and  public remain confused as to whether cigarettes were taken and if the plaintiffs contention and i believe we can prove it through the development of evidence available in the united states reynolds employees perhaps employees of some of the other cigarette manufacturers documents located in the united states that sometimes makes the seventy's reynolds and the other american is fierce when international and exercised their ability to testified of the step position as a practicing attorney in the philippines that some cases took thirty years or more to resolve at one point he said in his deposition sometimes the case starts there isn't finished before the people's lives in which there  conditional dismissal reynolds finished reply brief and this is in the excerpts of record twenty seven the decision to impose conditions through a four month convenience dismissal including an agreement to submit to the jurisdiction of the alternative for him is entirely