In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[EX Q]: the in-state banking activities of these French and Japanese banks and Plaintiffs’ claims arising from a terrorist attack that occurred in Israel with the support of the Iranian government. It certainly cannot be said that Plaintiffs’ claims “directly arise” out of the banking activities of these local branches. See GCIU, 565 F.3d at 1024. Thus, under traditional legal principles, specific jurisdiction is lacking. Although the Seventh Circuit • has not addressed this issue, two Circuits have reformulated the minimum-contacts inquiry in cases involving third-party discovery, focusing more narrowly “on the connection between the nonparty’s contacts with the forum and the discovery order at issue.” Gucci, 768 F.3d at 137; see also S.E.C. v. Knowles, 87 F.3d 413, 418 (10th Cir.1996) (<HOLDING>)., It is unclear whether this test is proper, 
 Holding statements: (A) holding that standing alone defendants 4 million in sales in the forum state over a sevenyear period may not have been sufficient to support the exercise of general jurisdiction but that the numerous other contacts with the forum in the case including advertising relationships with dealers and more than 150 visits tipped the balance and led the court to conclude that there were sufficient contacts to allow the exercise of general jurisdiction (B) holding that specific jurisdiction requires plaintiff to show that defendants forum contacts be related directly to the subject of the lawsuit (C) holding no specific jurisdiction where alleged tortious conduct was not related to defendants contacts with texas (D) holding that courts exercise of specific jurisdiction was proper where subpoena enforcement action arose out of nonpartys contacts with the forum (E) holding that personal jurisdiction over a party is proper if the party has sufficient minimum contacts with the forum
[EX A]: holding that standing alone defendants 4 million in sales in the forum state over a sevenyear period may not have been sufficient to support the exercise of general jurisdiction but that the numerous other contacts with the forum in the case including advertising relationships with dealers and more than 150 visits tipped the balance and led the court to conclude that there were sufficient contacts to allow the exercise of general jurisdiction

[EX Q]: Apr. 14, 2011). Accord Wright v. Goord, 554 F.3d 255, 274 (2d Cir.2009) (dismissing a retaliation claim whose only causal basis was a letter that plaintiff wrote many weeks before the allegedly retaliatory acts, implicating officers other than named defendants). See also Def. Mem. at 11 ("[A] claim that one defendant took action against the plaintiff in retaliation for a complaint made against a different [officer] [should be] viewed with particular skepticism."). 40 . Def, Mem. at 17. 41 . See id. (citing exclusively to Eighth Amendment cases). 42 .Id. 43 . See Wright, 554 F.3d at 274. 44 . Def. Mem. at 18. 45 . Def. Mem. at 19. 46 . Davis, 320 F.3d at 353. 47 . Dawes, 239 F.3d at 493. 48 . Compare Hofelich v. Ercole, No. 06 Civ. 1369, 2010 WL 1459740, at *2 (S.D.N.Y. Apr. 10, 2010) (<HOLDING>), with Rembert v. Cheverko, No. 12 Civ. 9196, 
 Holding statements: (A) holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim (B) holding that a verbal threat of being fired is not an adverse employment action for purposes of title vii (C) holding that verbal threats if they are specific can constitute adverse action for retaliation purposes (D) holding that a suspension with pay may constitute materially adverse action for the purposes of retaliation claims depending on the facts of the case (E) holding that a transfer of job duties can constitute an adverse employment action
[EX A]: holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim

[EX Q]: filed an Anders brief that did not mention the U.S.S.G. § 4A1.2(a)(2) sentencing issue, Defendant did not have the assistance of counsel in raising this claim or obtaining access to the information needed to challenge this particular aspect of his sentencing. This claim was therefore rejected on direct appeal because the evidence refuting the PSR’s erroneous information was not brought to t of sentencing error does- not rise to the level of “a miscarriage of justice” and thus is not cognizable under § 2255. See United States v. Talk, 158 F.3d 1064, 1070 (10th Cir.1998) (“[N]umerous cases have held that sentencing errors typically do not give rise to a miscarriage of justice sufficient to excuse procedural default.”); cf. Narvaez v. United States, 674 F.3d 621, 627 (7th Cir.2011) (<HOLDING>); Talk, 158 F.3d at 1070 (assuming without 
 Holding statements: (A) holding that failure to consider an improper jury instruction would constitute a miscarriage of justice (B) holding that error in classifying defendant as a violent offender caused a miscarriage of justice (C) holding that courts of appeal should only correct a forfeited error at the trial level in those circumstances in which a miscarriage of justice would otherwise result (D) holding that courts may only review claims for fundamental miscarriage of justice (E) holding some evidence standard applicable to cdoc decision classifying inmate who had not been convicted of a sexual offense as a sex offender
[EX A]:
holding that failure to consider an improper jury instruction would constitute a miscarriage of justice