thank you mr chief justice and may have please the court specific jurisdiction requires that the defendant have engaged in related conduct in the form say that having gaging conduct relevant to the plaintiff's claims in the form state if those requirements mean anything is that the defendant's form state conduct must be at least above for cause of the plaintiff claim conduct that does not cause a claim is by definition irrelevant to the point the claims would be the same with or without the conduct once the court except for causation is the minimum proximate cause ation the proximate cause standard recognizes that there are some for causes that are to attenuated to be illegal cause of the pla claim and keeps those distinct causes from creating jurisdiction an approximate cause standard lines up with this court's cases since international shoe and the principles of federalism fairness predictability and administer ability of long govern this cour analysis respondents primary arguments have forty it's subject to jurisdiction in minnesota and montana because it carries on similar unrelated business there is the same argument this court rejected in bristol myers  all that respondents add is that they are former residents injured in the form state the court rejected that argument and walden when explained that an injury is quote jurisdictionally relevant only in so far as it shows the defendant has formed a contact with the for state and no one claims that respondents form state injuries show that ford has formed contacts with montana and minnesota the vehicles were brought to the forums through the unilateral actions of rd parties and respondents would have been injured wherever they happen to be when the vehicles crashed in the end respondents press heavily on the notion that montana and minnesota have an interest in providing a forum to their injured resident but that runs afoul of this court's cardinal rule of the due process cla protect defendant not plaintiffs and not form state decisions below should be reversed mr marotta court advertises in all fifty states right it does advertise and market vehicles to some extent in all fifty states right so if somebody is in an accident and they think the vehicle might have had something to do with it is it enough under your theory for them to say one reason i  bought a ford was because i saw one of their ads and i was persuaded that they make good cars i think that would satisfy but for causation mr chief justice because the purposeful of ailment through marketing isn't the bus for change it may not satisfy proximate cause ation depending on the nature of the claim for a routine design defect claim the mere fact that you saw before dad and were persuaded to buy it has nothing to do with the stuff and claim by contrast if your claim was special i mean you wouldn't you wouldn't be in the car if you didn't were persuaded to buy it why doesn't that have a lot to do with the claim well as present as professor brown meyer says if you're telling the story of this car accident the fact that they saw a ford ad has no substantive relevant to either the story or to any of the legal elements of the claim but by contrast if your claim is that ford made certain promises to me in that ad you know they warranted that the air bags were deployed and i relied on that no but that's a hypothetical question and so if you do for dad said you know we make the safest cars on the road then any claim of a defect you would satisfy the jurisdictional requirement  was satisfied but for cause it may not satisfy proximate cause depending on the substantive law that an issue merely saying we make safe cars might not rise to the level of a warranty that would be enforceable but again plaintiffs don't even  the lower but for standard in this case but if the if the if the issue that's going to be litigated on liability is say for example was the accident caused by a car defect or was the accident caused by the negligence of the driver you've suddenly made that a jurisdictional question because if the if the accident is caused proximate cause and due to the car then you would say well there is jurisdiction but if it's the driver's negligence that doesn't have anything to do with ford's presence so it seems to me that's a serious and unfortunate consequence of your position i don't think it is mr chief justice because we're not asking the court of personal jurisdiction to decide the merits of what the cause is rather proximate cause describe the directness of the connection between the claims or the allegations that the plaintiff has made and the the due process clause to your proximate cause argument seems to be a long journey i'd like you to at least praise god through me at least as far as international the lineage for this proximate cause requirement certainly justice thomas so worldwide volkswagen itself says that the international shoe framework is consistent with the original understanding of the constitution and of the th amendment so then when you look back to international issue is that that specific jurisdiction is that you engage in certain conduct in the fore and then you create obligations through that condo and then you can be sued for claims that arise out of that condo so that the face i'd buy for causation but it's the lower courts that recognize your face only but for causation you could have  and the fact that a designer you know went to high school in a certain state is in the but for chain of causation and so all that proximate cause ation does is it takes those attenuated for causes out of the analysis to prevent certainty that's how you trace it that you know the that's the that confusing to me but let me ask you just the practical question let's say that st of all for in the united states is fairly big with us so the if i'm in a city like bristol tennessee and i notice on the internet that there was a used for the raptor vailable for sale at a great  can the president of tennessee who lives in tennessee and wreck the car or had the accident tennessee sue in tennessee for that in tennessee i think it would depend how you came to your awareness that there is a good value and rowena if somehow for connected you to that through the inventory of a used car dealer perhaps but if it's just that you saw on the internet through you know a classified ad that there's a great value across the state line the answer is no because that's the action of rd parties ok i'm ok he did not understand i'm just trying to figure out the sense of this if i bought the rafter in bristol tennessee could sue for it in bristol under the same circumstances i saw the exact same math but it was bristol tennessee if you bought it from you know just a private party you know if you purchased it new from your local ford dealer ye prior why isn't there general jurisdiction here it's just a preliminary there's there's no general jurisdiction it's been conceded there's no general jurisdiction because ford is not at home in minnesota or montana it's not incorporated there and it's not headquartered there all right so the whole point of this whole doctrine i take it is not to put a dependent  connection but they do do a lot of business with the same cars there and so intensely do a lot of business with the same kinds of cars there they have to be prepared to defend against this kind of suit so what's unfair about it took place outside or what was well it's true that the plaintiff wasn't in california and the area is in montana but this court held in walden unanimously that the location of the plaintiff doesn't matter and that the place of injury does not matter as i quoted in my opening statement this court held that the injuries are irrelevant except to the fact that sometimes they shed light on whether a defendant has contact with the form so trying to take bristol myers squi came to the conclusion the case law didn't govern what to what's unfair about it well i think what's unfair about it is that for have to be subject the rulings of montana and minnesota judges the subject of the verdicts in there's no sliding scale you can just say well if there's a lot of business perhaps the last related because that is exactly alito let me pick up on a hypothetical that you have in your reply brief modified slightly for purposes of simplicity so suppose a product is sold in a particular state where the manufacturer as or sizes this product as a very safe product a person purchases that is injured by the product  would there be personal jurisdiction there or would it be necessary for the injured individual to prove that the advertising as to the safety of this product was the proximate cause of the purchase of the product in your hypothetical justice alito where the purchase occurs in the foreign state the advertising i think is just icing on the cake the sale is what provides the proximate lincoln are all right suppose that the  sale occurs in a different stay in that particular instance i think and i don't want the court to get hung up on the phrase proximate cause because it carries with it certain weight from the merits inquiry all we're saying is that it has to be a sufficiently direct cause of it so in that case it would depend on the particular claims that you're bringing claims in this case i don't think merely saying i saw an ad i bought the vehicle somewhere else would be sufficient for other claims it may very well be advertising in montana regarding the safety of this product and then is injured in montana what would with their be personal jurisdiction if the particular claims were only the design and manufacturing claims that we have here no if it were based upon promises made in the advertising perhaps yes but again in these cases there is no allegation that advertising because anyone to do anything for these decades old vehicle and were not even it was particularly to the crown victoria were not even being advertised or sold at the time they were purchased well if we step back and this is a little bit like justice thomas question we're talking about due process which the international court court felt the international shoe court felt free to say well that just means fair play if that's what we're talking about either fair play for ford or what was at issue and bristol myers squibb which is a law suit in a suit that has in a state that has little connection with anything involved in this in the suit what would be the justification for ruling in your favor here justification for a ruling in our favor is that the state that the form states don't have a connection to what's relevant which is or to conduct in a wall th the court talked about the challenge conduct has to occur in the form that the relevant conduct have to occur in the forum relevant conduct here from th perspective and remember to process the defendant  is also an element of proof of the plaintiff's case because one of the elements of a product defect claim is that the manufacturer introduced the article in the commerce and that the vehicle has not changed condition since that st sale all right so let's assume that a ford vehicle was assigned in michigan manufactured in kentucky sold to a dealership in kansas city missouri but purchased by us residents of kansas city shore and a ford advertisement  plaintiff wants to assert various planes for this side defect manufacturing defect false advertising and negligence is there any single state where the pla so you can bring it where the vehicle was designed michigan where the vehicle was both kentucky i think where the with the advertisements were sold which was in the story and where the vehicle was purchased in kansas so you would say any one contact would be enough but how about if the airbag if the defect was in the air bag would majority still have jurisdiction over ford or qantas you said qantas would in the car that caused it how do we determine jurisdiction that you would determine your stiction then because the pair that was made a ford authorized dealership which is on top with or with the forum that where the vehicle was repaired would be proper jurisdiction perhaps not the place they took it back to you and i understand that if you live on the border of those two states like that you may treat them as interchangeable and of course the court has repeatedly said that in personal apple computer in new york i i move to california the computer catches on fire i get injured you're saying i can sue in new york where i bought  that reason right but you know i moved to illinois doesn't matter that's right yes understood yes so so essentially your substitute and what i think people have assumed in these products cases which is if if you're in a place on the injury takes place in a place because of a manufacturing defect or a design defect you get to sue you're saying no it doesn't really matter where the entry took place what matters is where these automobiles in exactly the same way in these two states and that was the same argument that was made in bristol myers squibb tell i say you could say bristol myers but you know bristol myers there was absolutely no connection the plaintiffs weren't residents of california they didn't use the product there they hadn't been injured there now that's three differences from this case and i think even going back further than to  walden and he says the plaintiffs connections to form don't matter and the plaintiffs and walden says the injury in the form doesn't well so involved and the defendant has absolutely no connection to the forum state but here as we distinction between specific and general jurisdiction for many years we say a specific jurisdiction has to arise out of everybody seems to know what that means nobody knows what relates to means the other part of the test and so i guess i guess i want to take you back to st principles along the lines of justice thomas what does due process require i suppose one could say it's whatever fair play whatever we think fair play means and which case you might run into some of the troubles we've been hearing some of the questions about what it could mean due process could mean a couple of things one it could mean the law of the land are you being held in the court in accordance with the of the land and surely that that's met here in the state long arm statute no one contests that it reaches you or it might mean that as originally understood the due process clause and then the ideas behind the due process would not allow the defendant to be hailed in the court in these kinds of circumstances i didn't see a lot in the briefs addressing that question so it's really something i wanted to ask you and your colleagues today about you have anything you want to comment there specific jurisdiction civic jurisdiction is you go into a state and you perform certain that you are then liable for a claim that arise out of those acts but here the form cases are seeking to hold for liable for  manufacture or design and of sale that occurred in other states remember if ford had done nothing in montana and minnesota in these cases the claims park exactly the same as they are before and that's  personal jurisdiction but that's an option that of shoes or to that and the fact that ford may you know litigate in these forums anyway you know think of the smaller manufacturers who sell minimal amounts of products in the for may have never late again a product case there or will you announce today is going to apply to those manufacturers to and should i think the equal if not greater in your consideration if we look at the been a lot of questions about our president but the you lose correct i don't think so just have an office that this was about purposeful of ailment you have to put that in contact the fence before it says one a corporation start interrupt if we just follow what the sentence says so if the sale of a product of a manufacturer just distributor arises from the efforts of the manufacturer distributor to serve directly or indirectly the market for its products in other states is not unreasonable to subjected to suit and one of those states is if it's allegedly defective merchandise has there been the source of injury to its owner or to others we just call that sentence you lose correct i don't think so just have it all because it's unclear and i think ambiguous from the sentence whether the c referring to sale of the product in that forum or a sale on the product of another form and of course the issue that we're talking about today wasn't before the court and worldwide folks wagon because audi and both wagon having contested personal jurisdiction in this  that sense of been quoted in other cases and has formed the basis for well it's been quoted in several other cases correct aspects of that paragraph have been burger king talk about talk about the sentence after which is the personal jurisdiction of a corporation but the reverse product which i think again creates that ambiguity and again talks about i think that's aimed at not so the sense about the saudi invokes wagon has really never else popped up in the courts cases just the fences around it you know the lower courts of emphasizes the law for causation is at least a minimum and all this court has to decide to resolve these cases as happened when the th circuit was then judged for such as you have to hold it's just some causal standard and you can leave for another day whether it's proximate cause or some other degree of causation and the nd is to take it back to the st principle is that fortune only be held to account for things he did in the form days that are challenged by this and here or did not do anything in these forums and that is challenged by respondents to if the conduct and it happened the claims are the same and that's how you know it's irrelevant for him conduct which cannot be the basis of specific  thank you council mr gupta mr chief justice inmate please the course this court has never read the due process clause to deprive the states of their sovereign powers to try cases in their own courts and protect people injured within their own borders on anything like the facts presented here that is where the following two things are true the defendants product injured the plaintiff in the forum state and the defendant through its in state activity has deliberately cultivated the market for that product in that state over the objection of forty state attorneys general ford asks this court to extinguish the state's traditional authority even in this parodic matic scenario based on  cause standard and i think we just heard how elusive it is jurisdictional rules should be simple ford standard would introduce tremendous uncertainty and generate needless litigation it would break up garden variety accident cases it would leave innocent local businesses holding the bag for foreign companies as the home builders and main street business briefs explain and it would send injured plaintiffs on an irrelevant scavenger hunt to trace the route of the particular pill or toaster that caused injury just to try to figure out where to sue the constitution does not compel such an arbitrary regime ford standard would create practical problems without any countervailing benefits of fairness or federalism demanded by the d process clause the plaintiffs here aren't forum shopping they suit where everyone would expect them to suit and for can't even credibly claim that it would be unfair or burdensome to face suit there or identify any sovereign with any greater interest ultimately ford's position turns personal jurisdiction into a game the defendant can cut off access to the court not because the forum state overreached or because fairness compels it but simply because it makes it harder for people to get access to justice that is not due process council one of your miki the national association of homebuilders has a test that relies on the so called stream of commerce theory and i understand your theory to be different could you tell me what you understand that theory to be and exactly why yours is different yes mr chief justice i think that the the stream of commerce test is answering a different question from the one that's presented here the stream of commerce test tells you whether there is purposeful of ailment whether there are the requisite contacts and that theory relies on the idea that even if the defendant hasn't done  what would subjected to suit in the in the forum otherwise that the stream of commerce there he can supply the requisite context because either because the manufacturer has has put the goods into the stream and they end up there or depending on whether you accept justice o'connor's view there is something else that has occurred but here purposeful of ailment is conceded and so the question is once you have the the requisite context as ford does with the forum is the suit  related enough to the forum and the contacts that the defendant has in the forum that that's that this is specific jurisdiction and not general jurisdiction counsel let's say there's a retired guy in a small town he be sued in any state if some harm arises from the decoys you know say it you know it has lead paint or something by putting some ties but on the internet is he exposing himself to suit everywhere in the country no and i do think that's a much harder problem i think st we'd have to ask are there isolated sales or is he really doing something to inject himself into the forum state if he doesn't have any advertising that's targeted to a particular state it may be that his sales are sufficiently isolated that he's not even going to purposeful of ailment won't even be satisfied but but assuming that it is assuming that there is a there are sales in the forum and he knows that  expects that it encourages that it's possible that that that is going to give rise to specific jurisdiction for that injury but we would need to know at the st step whether he's really doing something to deliberately cultivate a market in the farm state i think that it would be best in there they get the internet wherever in the country and that's how he's trying to cultivate a market is that enough or not well two you know i mean i think we would need to know has he ever sold let's say the suit is in california he'd never sold something in california as he only sold in new england but in theory they could sell the california and then there's one sale in california i'm not sure that's going to be enough for purposeful of ailment but i really do think justice justice thomas thank you mr chief justice the good would like to pick up there too you use the term related to and the discussion thomas and i think you can pick up where you left off in b m s and and b m s is i think the case that that is most on point about relatedness what you said there that a suit relates to the defendant's contacts with a forum where there is an affiliation between the forum and the underlying controversy principly an occurrence where we know that happened here there was an occurrence in the forum that was subject to the state's regulation and we think relatedness under your cases can basically be distilled down to two inquiries a test and products cases st you have to ask with the defendant be submitting to the coercive power of the state with little interest in the controversy that was the problem in b m s right the state of california had little interest in the controversy because those people were injured elsewhere and really had nothing to do with california and then nd i think relatedness is asking about whether the reciprocal legal obligations at issue were created by the defendants in state contacts and  plaintiff claims really come within those contacts and justice to my my friend in answer to your question about you know what does this all have to do with due process an international issue invoked that concept of reciprocal obligations we think that's critical here you're really asking when you ask about the defendant's context are what kind of legal obligations arose from that and here are the legal obligations pretty simple it's the legal obligation that you've got to compensate people when you sell all these this exact product  the forum and it hurts somebody advertising go you advertise is a lot the st new bought it didn't use is dealer though even has some there and you think under those circumstances you can bring in a lawsuit is that right does make a big difference so what i thought now the problem i think that the other side is saying is they are who how much business does he have to do i mean if john deere has a defective lawnmower and under what circumstances he said that's totally unclear that's why they go to their room well justice breyer let me try to give you some comfort on that because i think if this is if the fight here is over whose rule is more predictable and certain i think we win hands down our test is pretty simple it's always going to be possible to know whether the person was injured in the forum state and then i think it's usually quite easy to figure out what was that exact product sold in the state so in your example  john deere tractors but it doesn't sell the harvester in illinois then that is not going to support the same product how many of the same products so so that's a question on purpose well of ailment right is it is it's is it isolated is it enough but once you've satisfied purposeful of ailment which again of course is conceded here then the question is are those sales that are not isolated that have targeted the market are they the same as are they of the same product and i think if you have the same make model in here it's going to be the same product we're talking about mass produced goods it's not a difficult inquiry and i think the inquiry is basically an objective one the the defendant has the choice to differentiate its products if it wants to sell cars in california but it doesn't want to sell trucks in california because it doesn't like the way california regulates it is free to do that and then it would not be subject on our test to specific jurisdiction in rebuilt and it is advertised on the internet and purchased in one state driven into another state an accident occurs in the other state the claim is that the design of this car was negligent will there be personal jurisdiction i don't think so justice alito i think you know there's one case of yours that talks about custom products in the goodyear case you said the problem there was that the accident hadn't occurred in north carolina and also that the same type of tire wasn't distributed in north carolina but there were custom deliveries of tires for concrete trucks and various other kinds of trucks there and the court distinguish that so i think when you have custom products that are design bespoke products designed for particular people that cannot easily be assimilated into a test that it's designed for mass produced products but advertised on the internet as the only way anybody learns about it and purchases are made over the internet someone purchases that in another state and is injured in that state w five international shoe traveling salesman question so we are in we could perhaps decide this case within the contours of our existing cases because there's nothing particularly  century about what happened here but one we're in a strange situation where we are not purporting to apply due process was understood to mean when the th amendment was adopted we are applying a so you might just say well decide this on the basis of your existing case live not propose anything grander but if you have a solution to the bigger problems that have been friend by some of the questions it would be interesting to hear  it's a it's a very fair point justice alito and i think it is true that the evolution of the cases particularly in the early th century reflected changing market realities that as we have more of a national economy  more integrated economy the jurisdictional standards began to reflect that and i think it is fair to say that there's been some states this since then and you've left open a lot of questions in cases like nicastro in asahi about about where to draw the lines and those are those could be very difficult questions for the lower courts and they'd appreciate some clarity but i also think something that that the concurrence by justice breyer and you just as we know in the castro is important in there that concurrence cautioned against trying to write rules with a broad brush that will apply across different market contexts with and have on into supported consequences and so thank you that's why justice soto count so i just have one question about your same product rule how about if it's a claim about a defective hair back and it wasn't in there in one car so by for it but it turned another car millions of cars that are still to minnesota but this one car is not sold in minnesota which you still have jurisdiction so i think if if ford says look we didn't sell that airbag in that state and you know they might have done it on purpose they might for example in california there are emissions standards that are different i think the defendant has the ability at least in our tests that the defendant has the ability not to sell that product in that in that form but it has to be objective lead discernible to everyone that it's a different product and i think in your hypothetical it would be they would be saying we're not marketing the same car we're marking a different car but you know it has to be objective we discernible because i don't think we want to test that turns on you know what's in the guts of the car but if they say look there's the model x and we sell it in minnesota and then there's the model law and we don't sell that in minnesota than that would not satisfy our test a special kind of pickup truck and i decide really the market for this pickup truck is the southeast part of america and i only advertise it there and i only sell it there then if somebody takes the pickup truck to forecloses some alternative possibility of specific jurisdiction and i think this goes to justice alito is question and some of the other questions about stream of commerce if you know when the court if the court picks up the stream of commerce question and decides what constitutes a purposeful of ailment when you don't have the kind of the same kinds of sales in the forum as you do here then i think you could answer that question and you could conclude there would be specific jurisdiction but it would be an on an alternate theory it wouldn't be on our test that that we think decides these cases and i think decides a whole lot of products liability cases i see what you're saying and on your test focusing on us test how about if ford does something you know a little bit different it says we have this is the track and mostly we're going to market it in the southeast we can't say we do nothing in the northwest you know we do a little bit as one dealer who's out there selling these pickup trucks what happens then well if that one dealer is really selling those pickup trucks in the state i think that that would satisfy our test pretty easily i mean i think but i do think the reason why i say that you know it matters whether they're selling the same thing in the state is because the defendant has the ability to structure their primary conduct of basically you know we want to sell some stuff somewhere we don't want to sell some and to take the cold the southern states example maybe they sell a car that doesn't work very well in cold climates and they know that and they don't want to be sued in alaska for the car that they only sell when in florida and arizona so they have the right to do that you're cases of always acknowledged that you can exit a market you can exit a market partially but if i could just interrupt mr got the final question is you talk a lot about fairness and the sergeant my understanding of our law sm cuts very strongly in our favor i mean it's why you have forty states coming in and urging you not to do what florida urges and that's because the states have a manifest interest in trying cases within their borders applying procedures to their own law and protecting people within their own borders and and you dealt with this in b m s i think that the driving force of the opinion in b m s was a concern for interstate federalism and in particular a concern about one state meddling in the affairs of another state say california saying we want to hear the claims of ohioans when ohio has a right to apply its own procedures to its own laws you don't have any kind of meddling like that just just this force which the morning mr ago i think the ch justice and others have pointed out the difficulty of our purposeful of ailment test in an internet age and some of it was cabin by a rise out of one that had some causal link but now we're blowing past that dorning relate to to mean something more which i and i totally understand and i get your same product test as a limiting way and i think there are there are issues there what if exist for example ford didn't sell explorers in montana but the part that allegedly failed in the explorer for your client in montana is also sold by ford and lots of other models in montana which is the relevant product is it the explorer or is it the part and ice for see a lot of difficulties there all of which again takes me back to at least lease me to these st princip factor there do you have anything about the original meaning of the due process clause that you want to argue here that might provide some helpful guidance ok just of course if that was a lot we've got the internet the components blurring the lines between specific and general and the original meaning let me try to take the really quickly st on the internet there for you to have at it thank you you know on the internet again i just think that is probably the most issue in personal jurisdiction and i do think if you had a case that was about personal jurisdiction on the internet you'd have a whole lot of amicus briefs you would you would you would get some sense of the unanticipated consequences that when i don't want to waste my time again that i think ok ok the component one is i want to make sure i answer that i do think that product liability turns on the finished product that's all that if you think about your air liquid case which is all about that and i think again it has to be objective we discernible so if there's some component in there but we know that the defendant has made a decision about how it's going to submit itself to the market i don't think you know that you know the howard sells this defective component in millions of cars in montana let's say we know right i would think right next to you may not be are going to but you're a friend of yours will be here right fast saying that's the same product right well i think the way our test works is the defendant gets to choose how it assembles the product and what it puts out into the world and what it's how it's submitting to the state so i would say i would not want the test to turn on just the components i don't think what we're proposing blurs the lines of sp's specific in general at all i hope it  clarity and continues the project at this part is had of separating these two different bases for jurisdiction because you know what could be more specific than the place where the person had the injury and the specific make model in your product and then and then finally on original meeting justice course i think you know the framers would have been pretty surprised by a lot of the personal jurisdiction jurisprudence i think my grand on the other side is asking  you to announce a constitutional rule that turns on the st sale of the widget five sales ago to somebody else in a state that has no interest in the concert i guess agree with you i was just curious what you would have us say that's ok i've run out of time i'm sorry and you counsel justice cavanaugh thank you chief justice and welcome back mr good first of all can you explain to your test what you think you have to show to satisfy conceded i think it was before it was right to concede it because you know this is an easy case for purposeful of ailment as some of the questions have shown it can be more difficult but i think you're case is talk a lot more about what constitutes a purposeful of ailment and i think what you've said is you've got to target the market you've got to be you know deliberately cultivating the market as i've said there are difficult questions about the stream of commerce and can we just bracket those for the moment and say as long as you have you know purposeful of ailment that doesn't rely on a stream of commerce test the distinct thing that related this does that's different is that it says once you've got those contacts we're now going to try to figure out are those contacts sufficiently related to the claim here the person's injury where it occurred and the and the obligation i'm sorry to interrupt i think you're saying the purposeful vaillant's been satisfied then so long as the injury was in the form of state that's going to be good enough no justice k quite i mean i think yes you have to have the injury in the state but then you've got to figure out is the plaintiff's claim coming within the scope of the legal obligations that the defendant has subjected itself to in the form so like for example if if a company sells you know computers in the state they may be purposefully availing themselves but if my claim is really about software that they haven't sold in the state you're going to have purposeful of ailment but you won't have related you heard the response to the world wide volkswagen you had emphasized the case quite heavily in your briefs and you heard the response from the other side your response to that well i think what that  is you know it's it's hard to answer the question on the other side i think worldwide folks wagon had precisely this kind of situation in mind the reason they did is because votes wagon and audi hadn't raised a jurisdiction objection but there were four audi dealerships in the state in oklahoma in one hundred and eighty and they were selling these cars and my friend below in the courts below referred to that passage as a description of what would have happened if audi revokes wagon had raised a strange jurisdictional objection frankly just like everyone has always assumed that's the easy case and that's why you've referred to it over and over that passage is kind of the parodic matic example of a specific jurisdiction and you did so most recently in your unanimous opinion in goodyear so i i get that you know you can say that it's addictive but it's very important victor that's been repeated over and over again relied on by the lower courts and reflects kind of a core scenario of specific jurisdiction that i think is satisfied here thank you minute to wrap up mister thank you at the end of the day i think any sensible resolution of these cases is go have to be grounded in some combination of intrastate federalism fairness to the defendant predictability and frankly common sense those are the the things that i think the due process clause or is trying to accomplish in this area and i think ford's approach flunks all three tests when it comes to federalism they just can't get around the fact that their approach extinguishes the sovereign power of the states that have the greatest interest in  cases like this and shuffles it arbitrarily to states that may have no interest all in the service of the extremely difficult to apply proximate test cause inquiry when it comes to fairness for claims no unfairness if you really press them and tried if you if you were to try to explain to the public how this result is grounded in fairness i think it would be very difficult to do and finally their approach would inject a tremendous uncertainty and unpredictability into the american litigation system  basis in the common law or in the courts allow consider the questions we posed at page one thousand and twenty of the reply brief and they've been the ones that were discussed today for product sale so they have to be the same type of product the same model is a similar product sufficient doesn't have to be the same features that are alleged to be defective in the case or take advertising which has been posited as one of the contacts that can create jurisdiction so that half of the sale of the product directly near technical support or warranty support how about merely raising brand recognition and how long does this have to take place one year of sales many years of sales these are the questions they're going to trouble the lower court for years if you adopt that test a call to test by contrast has a rich history in the common law and it's in fact the majority rule in the courts that have applied that have confronted this question and they carry out the application of a causal  without any real trouble and that's because of this court noted lexmark these are principles that have been widely known to judges and can be applied easily even if there are odd corner cases and finally our role is trance obstinate you can apply our appropriate one second the discussion confirms that the respondents argument is essentially just bristol myers squibb plus the occurrence of injury in the form in other words a sale of sufficient number of the same product plus the occurrence  injury but going back to st principle all the way back to helicopter parents which announced a rise out of or relate to the court made clear that even regular purchases of a product in the forum are not sufficient to create jurisdiction where the contrary to every principle this court has laid out in its cases which allows the plaintiffs claim to direct the analysis and finally the interest analysis and the weighing analysis that respondents propose has been rejected by hans this court's enhancing the form does not acquire jurisdiction by being the center of gravity of the controversy or the most convenient location for litigation the issue is personal jurisdiction not choice of law and has this court set all the way back in world wide a volkswagen there can be cases where it is not unfair to the defendant from a practical standpoint or perhaps the state even has the greatest injured interest from a choice of law standpoint but yet still that role as an acting as an instrument of interstate of interstate