Which of the following statements regarding minimum contacts in Internet jurisdiction cases is true?

a. Most courts apply the totality test.

b. Most courts apply the Zippo standard.

c. Most courts follow the Calder effects test.

d. Most courts apply a bright-line rule: Internet activity alone never generates sufficient minimum contacts consistent with due process.

e. The lower courts are split on the issue of Internet jurisdiction; this area of law is still developing.