Page "Minimum contacts" Paragraph 8

Merely placing products in the " stream of commerce " is insufficient to provide minimum contacts with the states where the products end up.

The defendant must make an effort to market in the forum state or otherwise purposefully avail himself of the resources of that state.

However, since only four of the nine Supreme Court Justices joined the opinion that required a defendant to do more than place his products in a " stream of commerce ," some lower courts still rule that doing so is adequate for a court to exercise personal jurisdiction.