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:
to landslide, even though earth movement was the most immediate cause). We therefore conclude that this is a case of multiple causation. B. We must now determine whether the deterioration or the fungicide manufacturers' failure to warn is the "proximate efficient cause" of the damage to Berry's irrigation pipes. In Sabella, the California Supreme Court defined "proximate efficient cause" both as "the one that sets others in motion" and as "the predominating or moving efficient cause." Sabella, 27 Cal.Rptr. at 695, 377 P.2d at 895; see Garvey, 257 Cal.Rptr. at 296, 770 P.2d at 708 ("Sabella defined 'efficient proximate cause' alternatively as the 'one that sets others in motion' and as 'the predominating or moving efficient cause.'") (citations omitted); Howell, 267 Cal.Rptr. at 716 (<HOLDING>); Brian Chuchua's Jeep, 13 Cal.Rptr.2d at 445
Holding statements: (A) recognizing the existence of purely jurisdictional elements (B) recognizing existence of two tests (C) recognizing first two exceptions (D) recognizing that the existence of an agency relationship is ordinarily a question of fact (E) recognizing the existence of the special relationship

Ex Output:
recognizing the existence of purely jurisdictional elements

Ex Input:
Hill's case, Ischa the drug dog was called out to inspect Hill's car after Hill had already been arrested. Since the use of a canine here did not result in any seizure of Hill or his car beyond what he would have otherwise endured, officers did not need any justification for holding the car pending the canine inspection. By Edwards's account, Ischa alerted on the outside of the car. Given Hill's nervous behavior, his warrant for a controlled substance crime, his reputation for engaging in drug activity, and, most importantly, the indication from a qualified drug dog that drugs were in the vehicle, we hold the district court did not err in finding there was probable cause to search the vehicle's interior for such contraband. See United States v. Linkous, 285 F.3d 716, 721 (8th Cir.2002) (<HOLDING>); United States v. Munroe, 143 F.3d 1113, 1116
Holding statements: (A) holding that where a qualified drug dog alerts to the presence of contraband in a vehicle officers have probable cause to search the vehicle (B) holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes (C) holding that officers had probable cause to arrest driver and two passengers where cocaine and contraband were found in glove compartment and backseat armrest of vehicle and none of the men offered any information regarding the ownership of the drugs and contraband on the ground that the drugs and contraband could have been in the possession of any one of the three vehicle occupants or all three of them jointly (D) holding that the court of appeals properly concluded that the odor of marijuana emanating from defendants vehicle constituted probable cause to search the vehicle (E) holding that the smell of marijuana gave the police probable cause to search the vehicle

Ex Output:
holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes