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]: 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 A]: 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 Q]: 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA's one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, U.S. -, 121 S.Ct. 78, 148
Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
[EX A]: holding that issues not raised before the district court cannot be raised for the first time before this court

[EX Q]: was a "substantial factor" or "motivating factor" in Walker's allegedly retaliatory actions. Abrams argues that a reasonable jury could infer, as a result of this chronology, that he was "falsely arrested" and that he was arrested "because of what [he] said." Abrams then opines that "the arrest was for an illegal purpose" and finally that "[a]nger often leads to unthinking retaliation." After reviewing the record and the standards presented in our line of cases, we agree with the district court's finding that this chronology is unconvincing, as it fails to present "definite, competent evidence to rebut the motion," Michael v. St. Joseph County, 259 F.3d 842, 845 (7th Cir.2001), contains mere speculation, and demands the making of unreasonable inferences in suppo -84 (11th Cir.1998) (<HOLDING>). We recognize that such a step would not be
Holding statements: (A) holding that qualified immunity applies only if an officer had arguable probable cause to arrest (B) holding that probable cause is a complete defense to an action for false arrest (C) holding that the existence of probable cause for an arrest is a complete defense to a first amendment retaliation claim under the doctrine of qualified immunity (D) holding that the existence of probable cause is a complete defense to a 1983 claim alleging false arrest (E) recognizing first amendment retaliation right
[EX A]:
holding that qualified immunity applies only if an officer had arguable probable cause to arrest