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:
were convicted of conspiring to use, carry, or possess a firearm in furtherance of, inter alia, a conspiracy to violate the Neutrality Act and a conspiracy to provide services to the Taliban. 18 U.S.C. 924(c),(o); J.A. 3223. Both Count Five and Count Eleven, in other words, expressly allow one conspiracy to serve as the predicate for another conspiracy. Nothing about this statutory framework is unconstitutional, improper, or even unusual. Courts have recognized that one conspiracy can serve as the predicate for another conspiracy when the "[overarching] conspiracy and the predicate conspiracy are distinct offenses with entirely different objectives." United States v. Pungitore, 910 F.2d 1084, 1135 (3rd Cir.1990); see also United States v. Ruggiero, 726 F.2d 913, 918 (2nd Cir.1984) (<HOLDING>); United States v. Brooklier, 685 F.2d 1208,
Holding statements: (A) holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman (B) holding that congress intended to allow multiple punishments for rico conspiracies and conspiracies to commit the underlying predicate offense even though the offenses were the same under the blockburger test (C) holding that conspiracies can serve as predicate acts for a rico conspiracy (D) holding that judge erred in not explaining to jury that it could consider predicate acts listed in relation to substantive rico count when deciding whether defendants had also conspired to violate rico (E) recognizing money laundering as a predicate act under rico

Ex Output:
holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman

Ex Input:
that the use of the mails will follow in the ordinary course of business, or where such use can reasonably be foreseen, even though not actually intended.' " Altman, 48 F.3d at 102-03 (quoting Per-eira v. United States, 347 U.S. 1, 8-9, 74 S.Ct. 358, 98 L.Ed. 435 (1954)) (alteration in original). We hold that this requirement was easily satisfied here given that the settlement checks issued by the insurance companies (i.e., the fruition of the scheme) were sent by mail. In addition, several of the bribes were invoiced and paid by mad. Finally, the appellants' mandatory filings with the New York State Office of Court Administration, which were adulterated to help conceal the fraud, were sent by mail. See Schmuck v. United States, 489 U.S. 705, 712, 109 S.Ct. 1443, 103 L.Ed.2d 734 (1989) (<HOLDING>). Appellants argue that their prosecution under
Holding statements: (A) recognizing that proof of a business system of preparing and mailing letters and compliance with such a custom in the particular instance is sufficient to establish proof of mailing (B) recognizing that a mailing must be sufficiently related to the fraudulent scheme to support a charge of mail fraud (C) holding that mailing of titleregistration forms satisfied mailing requirement because they contributed to success of the scheme (D) holding that rule 6e is inapplicable where the time for filing begins to run on the date of mailing (E) holding that the first element of mail fraud knowing participation in a scheme to defraud can extend beyond the specific mailing and that the loss calculation for a mail fraud conviction may include any loss from the fraudulent scheme that the mailing furthered

Ex Output:
recognizing that proof of a business system of preparing and mailing letters and compliance with such a custom in the particular instance is sufficient to establish proof of mailing