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:
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 Output:
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 Input:
v. Paine, Webber, Jackson & Curtis, Inc., 565 F.Supp. 663, 667 n. 10, 669 (N.D.Ill.1983)). However, in all the cases on this issue, the courts made it clear that the client must have made disclosures to the attorney after manifesting an intent to seek legal advice. Herbes, 180 Ill.App.3d at 698-99, 129 Ill.Dec. 480, 536 N.E.2d 164 (finding that counsel for the plaintiff, who was suing a township over its open-space acquisition program, was ineligible to conduct said representation because he had previously engaged in an attorney-client relationship with the township when it interviewed only him for a possible position representing the township in the same program, evidencing the township's intent to hire him and therefore speak freely regarding the program), Hughes, 565 F.Supp. at 670 (<HOLDING>), Int'l. Paper Co. v. Lloyd Manufacturing Co.,
Holding statements: (A) holding that an attorney may only undertake to represent a new client against a former client where there is no confidential information received from the former client that is in any way relevant to representation of the current client (B) holding that in order to determine whether disqualification of plaintiffs attorney is appropriate because of a previous attorneyclient relationship he had with the defendant the court must determine whether confidential information was passed from client to attorney (C) holding that attorneys should be disqualified where the substantial relationship test is met in order to assure that the confidentiality of the attorneyclient relationship and the loyalty between attorney and client are preserved (D) holding that the district court did not abuse its discretion in drawing an adverse inference where the relief defendant refused to give information necessary to determine whether he still possessed any of the funds or whether he had a legitimate claim to them (E) holding that normal attorneyclient relationship does not bar rule 60b relief when the evidence is clear that the attorney and his client were not acting as one

Ex Output:
holding that an attorney may only undertake to represent a new client against a former client where there is no confidential information received from the former client that is in any way relevant to representation of the current client

Ex Input:
of the offense"). 14 . 544 U.S. 13, 16, 125 S.Ct. 1254, 1257, 161 L.Ed.2d 205 (2005); see also Gomez-Leon, 545 F.3d at 784. 15 . Snellenberger, 548 F.3d at 701. 16 . 520 F.3d 1072, 1078 (9th Cir.), cert. denied, - U.S. -, 129 S.Ct. 433, 172 L.Ed.2d 314 (2008); Gomez-Leon, 545 F.3d at 784. 17 . See United States v. Espinoza-Cano, 456 F.3d 1126, 1132 (9th Cir.2006) (quoting Shepard, 544 U.S. at 25, 125 S.Ct. at 1262). 18 . 414 F.3d 1038, 1044 (9th Cir.2005) ("Although police reports and complaint applications, standing alone, may not be used to enhance a sentence following a criminal conviction, ... the contents of these documents may be considered if specifically incorporated into the guilty plea or admitted by a defendant."). 19 .See, e.g., Almazan-Becerra, 537 F.3d at 1098-1100 (<HOLDING>); Espinoza-Cano, 456 F.3d at 1132 (district
Holding statements: (A) holding that based on the facts presented by the state and the defendants stipulation to the existence of a factual basis for his plea the court properly determined a factual basis for the plea existed (B) holding that district court abused discretion in denying motion to withdraw plea based on intervening supreme court decision that may have rendered factual basis of plea insufficient (C) holding that district court properly considered a police report that the defendant had stipulated contained a factual basis for his plea (D) holding that because the court could not consider police reports it could not rely on an attorneys argument based on the police report as the basis for determining the statutory basis for a conviction (E) holding that right to challenge factual basis is waived by guilty plea

Ex Output:
holding that based on the facts presented by the state and the defendants stipulation to the existence of a factual basis for his plea the court properly determined a factual basis for the plea existed