third party that it was their insured giant in their insurance form up their respective insurance giant formula but if you look at there's a policy that requires a search pre approval or search approval before any additional insured can be added to the one contact but it's not the kind of human obligations not clear to me that even if we call the contacts it's and now well that raises i think my second point which is the co i actually under your theory i'm not sure i can see why because you're resting the theory not on the fact that truck was located in wisconsin you're resting your theory of fact that they derived economic benefit from covering accidents that happened in any of the fifty states so that really isn't dependent on where truck is located because you're distinguishing mickey it sounds to me like i say what's not really so much about the relationship between insurance insurance as it is about the economic benefit it could get for saying yeah well not dependent on where the insured is located if it matters where the insured is located it's more about the contacts or the relationships that the insurance companies have had with the insured in that particular location and there are not i'm so i'm in wisconsin right except for the fact that they have this you know i dish knowledge and sure you know i mean track there were no other contacts with wisconsin but i understood you to be but the thing that's really different here is that they get an economic benefit you've got a pretty good argument a personal jurisdiction based on the could least on the contract that the from the defendants but usually that means you have to take the bitter with the sweet and that would include both the venue provision in time and in the arbitration provision was  contribution would be proving that zurich in time an organ obligation and that would be that where the contract comes in but the other elements such as you know one party paying more than their fair share some pretty clear guidelines to us in the jamie mcintyre case that the court made it clear that it is the defendant's actions not their expectations that control whether or not they're subject to personal jurisdiction in wal court made clear that it is the kind of contact with the form itself and not merely its relationship with a foreign resident that controls that the relationship with a plaintiff or third party state alone it's a contractual relationship or otherwise is not enough it's very clear of continuing our relationship is not enough up the fact that relationship somehow continues over time doesn't somehow make the mere relationship with our resident exactly exactly there's not that there's a relationship on paper to the extent that there are they are named as an additional insured under the giant policy but there's no interaction whatsoever to the bottom line answer to the chants and yes it matters here that this was formula one not based on any activity by the defendants purposely directed towards constance economy or its residents correct this is the sounds as if you are parties to your own contract you all agreed to name trekking as an additional insured correct specific it's a it's an insurance based theory that however contingent in probabilistic it is if you agree to take money for insuring risk for somebody you know another jurisdiction that establishes a good ongoing contractual set of obligations the insurance surprise anybody that you're subject to jurisdiction there there may be issues about venue but those can be sorted out  they have found personal jurisdiction they're trying to measure the context of this relationship whether it's e mails whether it's the felon case dealing with a board a condominium purchase in mexico you think it makes a difference whether there are good paying premium paying insured or an additional insured well i think it makes a difference for purposes of jurisdiction because all of the case law are almost uniformly goes through the exercise all agreed to cover worldwide obligations right yes but it doesn't mean to covering the worldwide obligations that's not it's not tantamount to a consent worldwide jurisdiction but you also in terms burden indicated that under the policy you have the right to control the defense of your named insurance the main insurance correct yes so that ordinarily contemplates the notion of defending them where they get sued world wide right well i think all insurance policies run the risk of getting sued wherever they go however absolutely what's unfair about that you guys are on this business of covering people who get sued worldwide it is the issue of our personal jurisdiction in a forum where there is essentially no contact and i'm saying essentially no contact because clearly they have is an additional insured a corporation that was government filed in wisconsin i'm confused about your theory that what's your connection to texas well if you mentioned it yeah i mean i get i get you're saying like ok well you know the accident happened in texas and that's what we agreed to cover up and that's  not and i understand your position to be that it's not consistent with the due process for your client to be held in to court in wisconsin and texas can't by statute we're going to authorize more personal jurisdiction that you process doesn't allow well it doesn't really and that there are minimum contacts and that would be saying the reason there is no personal jurisdiction is because the action as an arise out of this kind well i think the the the additional insured status of correct is the argument here you don't have to kind of ancillary contact simply because it's not necessary zircon time and promised insurance the insurance was there the unless your honour's have any questions