2. In Helicopteros, also discussed in Goodyear, the Court held that general jurisdiction could not be exercised in a wrongful death action despite defendant’s business trip to the forum state for a negotiation session, more than four million dollars of purchases from an instate company, receipt of five million dollars drawn from a bank in the forum state, and the company’s sending pilots and other personnel to the forum state for training and other purposes. After Goodyear, do you agree that defendant’s unrelated purchases and sales within the forum state will not meet the standard for general jurisdiction? What if the company keeps eighty percent of its inventory in a state? Or the company does eighty percent of its sales in the state (but the product that caused the injury was sold out-of-state, and specific jurisdiction is not available)? What activities, short of being incorporated or having a principal place of business within a state, will support the exercise of general jurisdiction?

See Pielemeier, Goodyear Dunlop: A Welcome Refinement of the Language of General Personal Jurisdiction, 16 Lewis & Clark L. Rev. 969 (2012).