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.

[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
[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


[Q]: Discipl. LEXIS 78, *9 (attorney disbursed all settlement proceeds to client less amount he retained for himself, after having been placed on notice that prior attorney claimed an in terest in any settlement funds in violation of Colo, RPC 1.15(b)). III. ANALYSIS OF SANCTION In both the Dunn and McCarthy matters, Rishel engaged in knowing conversion by obtaining funds from third parties for a stated purpose, failing to utilize the funds for that purpose, retaining the funds for an extended period of time after the third parties had withdrawn authorization, and failing to refund the amounts paid to the third parties despite their demand that he do so. The presumptive sanction for knowing conversion of the property of another is disbarment. People v. Dice, 947 P.2d 339, 340 (Colo.1997)(<HOLDING>); Motsenbocker; 926 P.2d at 577 (attorney 
 Holding statements: (A) holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause (B) holding that a lawyers knowing misappropriation of funds whether belonging to a client or third party warrants disbarment except in the presence of extraordinary factors of mitigation (C) holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors the attorneys clients did not suffer actual harm and the attorney established several mitigating factors (D) holding that permanent disbarment was appropriate for failure to remit 2000 in settlement funds to client and failing to answer the charges (E) recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person
[A]: holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause


[Q]: (2001); 7 DCMR §§ 312.2,312.8 (2011). 10 . Capitol Entm't Servs., 25 A.3d at 22; see also D.C.Code § 51-110(b)(l)-(2). 16 A.3d 130, 135 (D.C.2011) (" '[I]mplicit in [the] definition of 'misconduct' is that the employee intentionally disregarded the employer’s expectations for performance.'") (quoting Washington Times v. D.C. Dep't of Emp't Servs., 724 A.2d 1212, 1217-18 (D.C.1999)); Chase v. D.C. Dep't of Emp’t Servs., 804 A.2d 1119, 1124 n. 12 (D.C.2002) (noting that a finding that the employee's misconduct was intentional "may be required even for a finding of simple misconduct”). 21 . Odeniran, 985 A.2d at 428. 22 . Id. at 426. 23 . Id. at 428. 24 . Doyle v. NAI Pers., Inc., 991 A.2d 1181, 1183 (D.C.2010). 25 . See Badawi v. Hawk One Sec., Inc., 21 A.3d 607, 615 (D.C.2011) (<HOLDING>). 26 . See Hegwood v. Chinatown CVS, Inc., 954 
 Holding statements: (A) holding the findings of fact required to support an alimony award are sufficient if findings of fact have been made on the ultimate facts at issue in the case and the findings of fact show the trial court properly applied the law in the case (B) holding that this court could not affirm the aljs finding of gross misconduct because the alj failed to make findings on every material contested issue of fact (C) holding that an issue was not properly before the court on appeal because the trial court did not have the opportunity to make any findings of fact regarding it (D) holding that where adequately supported credibility findings are for the alj to make (E) holding remand proper on circuit courts own motion in a workers compensation case where the commission failed to make essential findings of fact because to hold otherwise would in such cases make the determination of the rights of the parties turn upon the neglect of the commission to make essential findings of fact or require the appellate court to make the omitted findings of fact which our statute forbids
[A]:
holding the findings of fact required to support an alimony award are sufficient if findings of fact have been made on the ultimate facts at issue in the case and the findings of fact show the trial court properly applied the law in the case