1

Filed 3/21/ 22 SK T rading International v. Superior Co urt CA1/4

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT DIVISION FOUR

SK TRADING INTERNATIONAL CO. LTD., Petitioner,

v. THE SUPERIOR COURT OF SAN FRANCISCO COUNTY, Respondent; THE PEOPLE, Real Party in Interest. A 1 63590
( City & County of San Francisco Super. Ct. No. CGC

- 20

- 584456)

These writ proceedings arise out of an action brought by the People of the State of California against several oil and gas firms alleging their participation in a multiyear conspiracy to manipulate the California gasoline market to the detriment of California consumers. D efendant SK Trading International Co. LTD (SK Trading) , a South Korean co rporation , has petitioned for a writ of mandate to compel the trial court to reverse its order denying its motion to quash service of the summons for lack of personal jurisdiction. SK Trading argues that its limited contacts with California are insufficient to support the court’s exercise of specific personal jurisdiction

. We disagree and shall deny the petiti on.2 Factual and Procedural Background On May 4, 2020, the Attorney General filed the present action against

p etitioner SK Trading, SK Energy Americas , Inc. (SK En erg y ) , a California Corporation and subsidiary of SK Trading , and Vitol Inc. (Vitol) , a Del aware Corporation . The complaint alleg es violations of the Cartwright Act , Business and Professions Code 1 section 16720 et seq., and the Unfair Competition Law , section 17200 et seq

. The complaint generally refers to SK Trading and SK Energy collective ly as the SK d efendants or SK. The pleading alleges that SK Energy “functioned as the California trading arm” of SK Trading, that SK Energy’s trading was conducted within the “continuous and pervasive control and supervision” of SK Trading, that SK Trading was “directly involved in nearly every asp ect” of the employment of SK Energy’s head trader, and that SK Trading “specifically reviewed and approved key decisions to coordinate certain trading activities with Vitol.” The complaint provides the following background information on the gasoline mar ket in California : “California has vehicle emissions standards that are more stringent than the rest of the country. Gasoline produced pursuant to these standards is called California Reformulated Gasoline Blendstock for Oxygenate Blending ( ‘ CARBOB ’ ). The CARBOB specifications are unique to California; therefore, gasoline used in neighboring states generally does not meet CARBOB specification and cannot be used as a substitute source of supply. ”
G asoline for physical delivery within a short time frame is bought and
sold on “spot markets.” California has two spot markets, one for delivery in Northern California and the other for delivery in Southern California. P rices

1 All statutory references are to the Business and Professions Code unless otherwise noted.3

on the California spot markets are “usually but not always hi g her” tha n prices on other gasoline markets. Spot market trades in California “ are traded through non

- public transactions, sometimes called over

- the

- counter ( ‘ OTC ’ ) trades. These OTC transactions do not occur on a centralized open exchange .

. . , so prices on the C alifornia spot markets are not immediately public. Instead, market participants rely on price

- reporting services that report spot market prices from sources that participate in the market, such as traders, refiners, and brokers. [¶]

. . . The Oil Price Inf ormation Service, LLC ( ‘ OPIS ’ ) is the most widely used reporting service in California.” The Commodity Exchange Act, which gover n s the spot market trading in California prohibits a transaction that “is, of the character of, or commonly
known to the trade a s, a ‘wash sale’ or ‘accommodation trade’ ” (7 U.S.C. § 6c(a)(2)(A)(i)) and prohibits a transaction that “is used to cause any price to be reported, registered, or recorded that is not a true and bona fide price.” (7 U.S.C. § 6c(a)(2)(B). ) A “wash trade” is defined by defendants as “a prearranged, round

- turn transaction executed to avoid taking a bona fide position in the market and/or the risk of price competition.”
T he complaint alleges that beginning in late 2014 through 2015 , defendants entered into agreements with each other “to drive up and manipulate the spot market price for gasoline so that they could realize windfall profits on these large contracts to deliver gasoline and gasoline blending components.” The complaint alleges , “The goal of the scheme was simple: to drive up or stabilize the OPIS

- reported price during pricing windows and to realize supra

- competitive profits while limiting bona fide
market risk. [¶]

. . . While tactics employed by Vitol and SK during the
scheme varied and were often complex, there were two primary components: (1) engage in trades that were reported to OPIS for the purpose of inflating4

the OPIS

- published price in the spot Market Report, and (2) execute facilitating trades to hide or disguise the nature of the scheme, to limit or eliminate bona fide market risk on the reported trades, and to share profits
with each other. ” For example, defendants might complete an initial transaction during the early trading hours at an inflated price so that OPIS would report a n inflated purchase price to other market participants , signal ing artificially high demand . Then, defendants would conduct a second trade, which was not reported to OPIS , that was “in the opposite direction of
the OPIS

- reported trade. This type of round

- tr ip or round

- turn facilitating
trade .

. . effectively negated the volume of gasoline purportedly exchanged in the OPIS

- reported trade” and “ ensured that no gasoline would actually change hands as a result of the OPIS

- reported trade that inflated the price reported in the Spot Market Report.” While the prices were artificially high, defendants were able to reap “extraordinary and supra

- competitive profits

. ” The complaint alleges “alliances or j oint venture s ” between Vitol and
the SK defendants were “a crucial component” to the success of the scheme

. The “alliances or joint ventures” were “ not reduced to writing between the companies ” and defendants “ took steps not to reveal the nature of these agreements to other market participants. ” “ While the so

- c alled ‘ joint venture ’ agreements were being reached, SK and Vitol e ngaged in the trading manipulation described above to benefit their common interest. Therefore, while it may have appeared to market participants that Vitol and SK were competitors, in fact the two companies were working together. Despite the terminology used, the ‘ joint ventures ’ were effectively a sham or pretext for cooperation and were a method of engaging in prearranged transactions and avoiding competition. ”5

The c omplaint allege s California consumers paid for defendants’ increased profits through inflated prices at the pump. SK Trading moved to quash service of the summons on the ground that the court lacked personal jurisdiction over it. It argued that the compa ny has never had a presence in California or conducted business within the state,
and has never exercised control over SK Energy’s day

- to

- day operations

. I t asserted that SK Trading “has never executed a trade of physical gasoline in California or entered into a futures contract related to the California gasoline
market . It has never entered into a contract to buy or sell physical gasoline or a futures contract related to the California gasoline market. Nor has it ever entered into a joint venture o r other collaborative arrangement with another company in California.” Evidence of the following undisputed facts was produced in jurisdictional discovery: In January 2014, SK Trading conducted its “1st Half 2014 Strategic Meeting” at which it set forth a plan to improve SK Energy’s profits from trading on the spot market in California. The plan encouraged SK Energy to hire a new trader with California gasoline trading experience and expertise and called for the promotion of “alliances” or “joint ventures ” between SK Energy and other gas firms. Thereafter, a business plan was drafted for SK Energy incorporating the strategies previously discussed. SK Trading subsequently supported and approved the hiring of former
Vitol trader David Nieman n as SK Energy’ s new west coast gasoline trader. SK Trading received background information on potential hires, including their trading history and likelihood of being recruited

. SK Trading organized the information that SK Energy provided to its personnel committee in

s upport of its decision to hire Niemann. A SK Trading executive interviewed Niemann at SK Energy’s headquarters in Houston and provided final6

approval for his hire. The SK Trading executive then reported to the SK Trading CEO that he supported hiring Nieman n “ given his focus on teamwork, clear views based on more than 20 years of experience in the [U nited States West Coast ] market, and decent attitudes.” Niemann thought of SK Trading as his “manag ement” and accused SK Trading of

“ micromanaging every little aspect of the finances .”
Executives of both SK Trading and SK Energy met regularly with Vitol executives throughout 2014 and 2015. In early 2015, SK Trading’s CEO reported on a meeting with Vito l’s CEO and Global Distillates Bookleader , among other s , at which they “exchanged opinions on the overall issues of the oil industry such as oil prices” and “Vitol agreed to make mutual efforts to develop cooperative projects with SK .” In July 2016, a SK Trading executive visited Houston to meet with, among others , Vitol ’s west coast gasoline
trader

. Vitol’s trader informed him that Vitol “has been achieving good performance record last year and this year through JV [joint venture ] with SK

. . . in the USW C market” and that their “JV with Niemann is more effective and creates higher net profits than any other Regional Book.” The
Vitol trader also advised that “[d] ue to [his] lack of experience, he had quite a tough time in his first year of trading (year 20 14), but along with the super strong trend of USWC market in 2015, he has continued collaboration with
Niemann through Storage, cargo JV, etc. ” Throughout the relevant time period, SK Energy submit ted a weekly report to SK Trading. The report included pos ition and valuation information as well as information on CARBOB trading and the ongoing coordination with Vitol related to the California market.
T he trial court denied the motion to quash. The court concluded that SK Trading ’s contacts with California support ed the court’s exercise of7

specific personal jurisdiction. The court explained , “ Plaintiffs have presented
evidence that

. . . [ SK T rading] controlled and facilitated key aspects of the alleged conspiracy. It sought out and maintain ed a cooperative relationship with Vitol in California, including meeting with Vitol to disc us s California coordination, while holding the SK Defendants out as competitors to Vitol. [ SK T rading] also played a primary role in the hiring and supervision of former Vitol trader David Niemann. These connections with California are
more than sufficient. [Citation

. ] On this record, the c ourt concludes that the operative facts of the controversy are related to the defendant ’ s contact with
this state

. ”
S K Trading timely commenced these writ proceedings seeking to overturn the trial court’s order.
Discussion
1. General Principles of Personal Jurisdiction State courts may assert personal jurisdiction over nonresident defendants served with process only if those defendants have sufficient

“ minimum contacts ” with the state to ensure that the assertion of jurisdiction does not violate “traditional notions of fair play and substantial justice.” ( Aquila, Inc. v. Superior Court (2007) 148 Cal.App.4th 556, 568 ( Aquila ).) “Minimum contacts” may support either general ( also called “ all

purpose ”) jurisdiction or specific (also called “ case
- linked ”) jurisdiction

. ( Rivelli v. Hemm (2021) 67 Cal.App.5th 380, 391

- 392 ; Aquila, supra , 148 Cal.App.4th at p. 569 .) “ ‘[W]here the defe ndant’s contacts with the forum state are so “systematic and so continuous as to make it consistent with traditional notions of fair play and substantial justice to subject the defendant to the jurisdiction of the forum, even where the cause of action is

u nrelated to the contacts,” ’ ” then the exercise of general jurisdiction is8

proper. ( Aquila, supra , 148 Cal.App.4th at p. 569.) “ ‘Specific jurisdiction results when the defendant’s contacts with the forum state, though not enough to subject the defendant to the general jurisdiction of the forum, are sufficient to subject the defendant to suit in the forum on a cause of action related to or arising out of those contacts. ’ ” ( I bi d .) In this case, the People do not contend that general jurisdiction exists , but only that SK Trading’s contacts with California are sufficient to support specific jurisdiction.
A court “may exercise specific jurisdiction over a nonresident defendant only if: (1) ‘the defendant has purposefully availed himself or herself o f forum benefits’ [citation]; (2) ‘the “controversy is related to or ‘arises out of’ [the] defendant’s contacts with the forum ” ’ [citation s ] ; and (3) ‘ “ the assertion of personal jurisdiction would comport with ‘ fair play and substantial justice

. ’ ” ’ ” (

Pavlovich v. Superior C ourt (2002) 29 Cal.4th 262, 269

. )

“ ‘On review, the question of jurisdiction is, in essence, one of law. When the facts giving rise to jurisdiction are conflicting, the trial court ’ s factual determinations are reviewed for substan tial evidence. [Citation.] Even then, we review independently the trial court ’ s conclusions as to the legal significance of the facts. [Citations.] When the jurisdictional facts are not in dispute, the question of whether the defendant is subject to person al jurisdiction is purely a legal question that we review de novo.’ ” ( Aquila , supra, 148 Cal.App.4th at p. 568.)
2. Analysis of Specific Jurisdiction Applying the three

- part test, the trial court found that (1) SK Trading purposefully directed its activities at California residents by and through SK Energy, whose employees made trades on the California spot market and engaged in business in California o n behalf of SK Trading ; (2) the People’s “claims for collusion, market manipulation, and unfair competition are9

sufficiently related to [SK Trading’s] contacts with California to warrant the exercise of specific jurisdiction” ; and (3) the assertion of juri sdiction in this case would comport with fair play and substantial justice. 2

“ ‘The purposeful availment inquiry

. . . focuses on the defendant’s intentionality. [Citation.] This prong is only satisfied when the defendant purposefully and voluntarily directs his activities toward the forum so that he should expect, by virtue of the benefit he receives, to be subject to th e court ’ s jurisdiction based on’ his contacts with the forum.” ( Pavlovich v. Superior
C ourt , supra , 29 Cal.4th at p. 269; see also Burger King Corp. v. Rudzewicz (1985) 471 U.S. 462, 475 [ T he “ ‘purposeful availment’ requirement ensures
that a defendant wi ll not be ha i led into a jurisdiction solely as a result of ‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts , [citations], or of the ‘unilateral activity of another party or a third person.’ ”].) SK Trading emphasizes that when analyzing jurisdiction over a foreign parent corporation, courts “begin[] with ‘the firm proposition that neither ownership nor control of a subsidiary corporation by a foreign parent corporation, without more, subjects the parent to the jurisdiction of the state wh ere the subsidiary does business.’ ” ( BBA Aviation PLC v. Superior C ourt (2010) 190 Cal.App.4th 421, 430. ) SK Trading ’s contacts with California , however, reflect more than passive
investment or ownership of a subsidiary. T he record establishe s that SK
Tra ding actively adopted and implemented a plan designed to increase SK Energy’s profits derived from trading on the California spot markets

. SK

2 SK Trading’s argument that the trial court applied an incorrect legal standard in determining jurisdiction improperly conflates the first two prongs of the three

- part test. The trial court correctly considered first whether S K Trading intentionally engaged in economic activity directed at California and then whether that activity was sufficiently related to the allegation of the complaint to support specific jurisdiction.10

Trading actively participated in the hiring and management of SK Energy’s California trader and facilitated agreements between SK Energy and Vitol regarding gas oline sales in California . These are not, as SK Trading suggests, “general management activities common to paren t

- subsidiary relationships

. ”
In Sonora Diamond Corp. v. Superior C ourt (2000) 83 Cal.App.4th 523, 552, the court emphasized that “[t]he critical acts may be taken directly by the parent or indirectly through the subsidiary, but in all events must be
attrib utable to the parent corporation itself. Thus, the theory does not rest on a finding that the subsidiary is a sham corporation or an agent or representative of the parent. Rather, the focus is on the acts of the parent itself.” Here, the record establishes that S K Trading officers personally and directly participated in making t he decisions affecting the California gasoline
market that the People allege violated California law

. Contrary to petitioner’s argument, the trial court’s reliance on Anglo Irish Bank Corp., PLC v. Super ior C ourt (2008) 165 Cal.App.4th 969 ( Anglo
Irish ) was sound. In that case, the court held that plaintiffs could satisfy the personal availment prong of th e specific personal jurisdiction test based on activities undertaken on behalf of the non

- resident defendants , if the plaintiffs established that the defendant purposefully directed those activities at the forum state. ( Id . at p. 984 .) In so holding, the c ourt carefully distinguished the requirements for specific personal jurisdiction from the requirements to establish liability or personal jurisdiction based on agency principles. The court explained, “In our view, reliance on state substantive law of agenc y and alter ego to determine the constitutional limits of specific personal jurisdiction is unnecessary and is an imprecise substitute for the appropriate jurisdictional question. The proper jurisdictional question is not whether the defendant can be liabl e for the acts of another person or entity11

under state substantive law, but whether the defendant has purposefully directed its activities at the forum state by causing a separate person or entity to engage in forum contacts. That constitutional question d oes not turn on the specific state law requirements of alter ego or agency, although the inquiry may be similar in some circumstances.” ( Id. at p. 983 ; see also Empire Steel Corp. v. Superior Court (1961) 56 Cal.2d 823, 835 [trial court need not decide whether the parent was the alter ego of its subsidiary where “jurisdiction over [parent] has been established on the basis of the acts of the parent itself”].) As the trial court correctly reasoned , u nder Anglo Irish , it is sufficient, for purposes of the purposeful availment inquiry, that SK Trading directed SK Energy “towards California ‘for the purpose of engaging in economic activity with California residents.’ ” As set forth above, specific juri sdiction “ requires a showing not only that the defendant has ‘ “purposefully directed” ’ its activities at the forum but also that ‘the litigation results from alleged injuries that “arise out of or relate to” those activities.’ [Citation.] There must be ‘ a connection between the forum and the specific claims at issue.’ [Citation.] ‘If the operative facts of the allegations of the complaint do not relate to the [nonresident]’s contacts in this state, then the cause of action does not arise from that contact such that California courts may exercise specific jurisdiction.’ ” ( Rivelli v. Hemm
, supra , 67 Cal.App.5th at p. 399 .) “[T]he relatedness requirement is satisfied if ‘there is a substantial nexus or connection between the defendant’s forum
activities and the plaintiff ’ s claim.” ( Snowney v. Harrah ’ s Ent ertainment , Inc

. (2005) 35 Cal.4th 1054, 1068 ; see also Bristol

- Myers Squibb Co. v. Superior C ourt (2017) 137 S.Ct. 1773 , 1781 ( Bristol

- Myers ) [“In order for a court to exercise specific jurisdiction over a claim, there must be an ‘affiliation between the forum and the underlying controversy

. ’ ”] ; Ford Motor Co. v.12

Montana Eighth Jud. Dist. Ct . (202 1 ) 141 S.Ct. 1017, 1026 [ “ the phrase

‘ relate to ’ incorporates real limits, as it must to adequately protect defendants foreign to a forum” but does not require “proof of causation

— i.e. , proof that the plaintiff ’s claim came about because of the defendant ’ s in

- state conduct. ”] .) 3 Here, the People’s claims arise from SK Trading’s involvement in the
decision

- making that was undisputedly directed towards the California
market

. While SK Trading may not have directly engaged in specific trades on the California spot market , the evidence shows that its officers were directly involved in the formulation of the policies that the complaint alleges
constituted an anticompetitive scheme. A s noted above, SK Trading participated in hiring Niemann as SK Energy’s trader on the Califo rnia spot

3 As petitioner note s , in Bristol

- Myers, supra, 137 S.Ct. at p age 1781 , the Supreme Court disapproved the “sliding

- scale” formul ation of the “substantial connection” prong of the specific personal jurisdiction test previously applied by California courts. The c ourt explained, “Under the California approach, the strength of the requisite connection between the forum and the specific claims at issue is relaxed if the defendant has extensive forum contacts that are unrelated to those claims. Our cases provide no support for this approach, which resembles a loose and spurious form of general jurisdiction. For specific jurisdiction, a de fendant ’ s general connections with the forum are not enough.” ( Id. at p. 1781.) T he c ourt reaffirmed that “ ‘specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.’ ” (

Id. at p. 1780.) This is the test applied by the trial court and which this court now applies

. (See Rivelli v. Hemm , supra , 67 Cal.App.5th at p. 400 [noting that Bristol

- Meyers may have cast doubt upon the California Supreme Court’s “substantial connection” formulation of relatedness prong in Snowney v. Harrah’s Entertainment, Inc ., supra , 35 Cal.4th 1054 and assessing relatedness prong “under the assumption that a ‘substantial connection’ between the claim and the forum contacts satisfies forum

relatedness only when consistent with a finding that the claim ‘ “arise[s] out of or relate[s] to” ’ [citation] the forum

- related activities”].)13

markets and it was Niemann who ultimately undertook the challenged
trades. SK Trading encouraged and participated in the formation of the “alliances” or “joint ventures” between Vitol and SK Energy that the complaint alleges were “crucial” to the anti

- competitive scheme. Although the meetings between SK Trading executives and Vitol representatives did not take place in California, the record establishes that the purpose of the

mee ting s was , at least in part, to discuss and strategi ze regarding the California gasoline market

. T he People need not prove the merits of its case during this jurisdictional stage of the proceedings . ( In re Auto mobile Antitrust Cases I &
II (2005) 135 Cal.App.4th 100, 118.) Whether the arrangements that arose out of the meetings attended by SK Trading executives were in fact anti

competitive as the People allege remains to be determined , but those
executives ad mittedly participated in those discussions and the ir focus unquestionably was the California gasoline market

. T he applicable test is
whether plaintiff has offered substantial evidence “that persuades the trial
court that there is reason to believe that each of the named nonresident defendants might be linked to the alleged conspiracy

. . . . This evidence need not be strong or conclusive, nor need plaintiff s prove each element of their causes of action. However,

. . . they must provide some evidence allowing the
trial court

— as finder of fact on jurisdictional issues

— to conclude that these particular named defendants were involved in the alleged conspiracy.” ( Id. at

p p

. 118

- 119.) SK Trading’s involvement reasonably suggest s that it may be linked to the alleged illegal conspiracy.
The c ases cited by SK Trading are factually distinguishable. In Bristol

Myers Squibb Co. v. Superior Court , supra , 137 S.Ct. at p age 17 81 , the Supreme Court reversed a determination by the California Supreme Court14

that failed to identify “ any adequate link between the State and the
nonresidents ’ claims ” for damages arising out of injuries allegedly caused by

a nation ally marketed , Bristol

- Myers Squibb prescription drug called Plavix. The court explained, “ As noted, the nonresidents were not prescribed Plavix in California, did not purchase Plavix in California, did not ingest Plavix in California, and were not injured by Plavix in California. The mere fact that other plaintiffs were prescribed, obtained, and ingested Plavix in California

— and allegedly sustained the same injuries as did the nonresidents

— does not allow the State to assert specific jurisdiction over the n onresidents ’ claims. ” ( Ibid .) The court noted that what was missing was “ a connection between the forum and the specific claims at issue. ” ( Ibid .) Unlike the claims in Bristol

Myers Squibb , the claims here are brought on behalf of California consumers for injuries relating to SK Trading’s involvement in activity directed at and conducted solely in California. SK Trading’s reliance on BBA Aviation PLC v. Superior C ourt , supra, 190 Cal.App.4th 421 , is similarly misplaced. In that case, the court held that a nonresident parent company was not subject to specific jurisdiction on claims arising out of its subsidiary’s termination of plaintiff’s employment
where the re was no evidence that the parent com pany “was involved in his employment, let alone his termination.” ( Id. at p p. 435

- 437.) In contrast, as discussed above, the record here establishes a sufficient connection between SK Trading’s activity in California and the claims asserted in the complain t. Contrary to petitioner’s argument, our decision does not necessarily conflict with the determination by the federal district court in In re Cal. Gasoline Spot Mkt. Antitrust Litig. (N.D. Cal., Sept. 29, 2021, No. 20

- cv
03131

- JSC) 2021 U.S. Dist. Lexis 187318, that SK Trading is not subject to personal jurisdiction in California on claims arising out of similar alleged15

misconduct. The district court held there was no personal jurisdiction based on agency and ratification theories. As discussed above, an d as the court
determined in Anglo Irish, “activities that are undertaken on behalf of a defendant may be attributed to the defendant for purposes of personal jurisdiction if the defendant purposefully directed those activities at the forum state, regardle ss of the specific requirements of alter ego or agency,
and .

. . state law of alter ego and agency does not determine the constitutional limits to the exercise of specific personal jurisdiction.” ( Anglo
Irish , supra , 165 Cal.App.4 th at p. 974.) Plaintiff need not establish that SK Energy was acting as an agent of SK Trading so long as its claims relate to SK Trading’s own activities directed to the California market. To the extent the federal district court concluded that plaintiff failed to

esta blish a sufficient nexus between SK Trading’s activities and the claims alleged in the complaint, the court applied an inapt “but for” standard. The district court explained, “ ‘Plaintiffs have failed to offer evidence that supports a plausible inference t hat SK Trading’s actions were the but for cause of Plaintiffs’ injuries.” ( In re Cal. Gasoline Spot Mkt. Antitrust Litig.,

supra, 2021 U.S. Dist. Lexis 187318 at pp. *23

- *24.) But such a showing is not required to establish specific personal jurisdiction. ( Snowney v. Harrah’s Entertainment, Inc., supra , 35 Cal.4th at p. 1068; Ford Motor Co. v. Montana Eighth Jud. Dist. C ourt , supra , 141 S.Ct. at p. 1026.) As set forth more fully above, SK Trading’s activities directed at the California market have a direct nexus with the anticompetitive conduct alleged in the complaint, which is all that is necessary. In conclusion, p laintiff has met its burden of showing that SK Trading purposefully engaged in activities that sh ould have led it to reasonably anticipate being required to defend those activities in California legal16

proceedings

. SK Trading has not established that t he assumption of jurisdiction over it is unfair or unreasonable. T he trial court did not err in denying SK Trading’s motion to quash. Accordingly, the petition for writ of
mandate is denied.

POLLAK, P. J.

WE CONCUR:
STREETER, J. BROWN, J.