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 Input:
court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts

Ex Output:
holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort


Ex Input:
Chief Judge: The appellant, Craig G. Falk, appeals from a July 8, 1996, Board of Veterans’ Appeals (BVA or Board) decision denying his claim service connection for post-traumatic stress disorder (PTSD). As the appellant has limited his appeal to the denial of that claim, the Court deems the appellant to have abandoned his right to appeal with respect to the denial of entitlement to benefits under 38 U.S.C. § 1151. Bucklinger v. Brown, 5 Vet.App. 435, 436 (1993); see also Carbino v. West, 168 F.3d 32, 34-35 (Fed.Cir.1999) (<HOLDING>). Upon consideration of the pleadings of the 
 Holding statements: (A) holding that an issue not presented to the trial court will not be considered on appeal (B) holding that issues not presented in an appellants initial brief to the court need not be considered under this courts rules (C) holding that claims not raised in an appellants initial brief to our court are waived (D) holding that issues not raised in an appellants initial brief are deemed abandoned (E) holding an appellant may not use the reply brief to argue issues not argued in the initial brief

Ex Output:
holding that an issue not presented to the trial court will not be considered on appeal


Ex Input:
850, 853 (Tenn.1985). Therefore, we conclude that, under AR.S. § 12-1514, the trial court may make an award for attorney’s fees incurred in the confirmation proceedings themselves. As the attorney’s fees awarded by the trial court in this case included fees for both the arbitration and the confirmation proceedings, the judgment must be modified to exclude fees attributable to the arbitration itself. CONCLUSION AND DISPOSITION W.E.S. requests attorney’s fees incurred for the appeal. W.E.S. was only partially successful in the appeal. The arbitration award was confirmed, but W.E.S. lost on the lion’s share of attorney’s fees, which has been the core issue in this case for some time. Cf. Coldwell Banker v. Camelback Office Park, 156 Ariz. 214, 223-24, 751 P.2d 530, 539-40 (App.1987) (<HOLDING>), vacated in part on other grounds, 156 Ariz. 
 Holding statements: (A) holding that it is possible to have no successful party when one prevails on the complaint and the other prevails on the counterclaim (B) holding that where complaint seeks greater damages than counterclaim and court denied relief to both parties there is no successful party (C) holding that a party may recover attorneys fees under section 38001 only if the party prevails on a cause of action for which attorneys fees are available and recovers damages (D) holding that successful party is one who is the ultimate prevailing party in the litigation (E) holding attorneys fees not generally recoverable unless party prevails under cause of action for which attorneys fees are recoverable and damages are recovered

Ex Output:

holding that where complaint seeks greater damages than counterclaim and court denied relief to both parties there is no successful party