Penny, a Pennsylvania Plaintiff, is upset at In-N-Out burger, a California defendant, for not delivering delicious "animal-style" burgers to her hometown of Philadelphia. In-N-Out has no stores in Pennsylvania and does not ship any of its products there, except for a quick 3-week period over Christmas where the company sends food trucks as a holiday promotion. Having to drive all the way to California, Penny ended up damaging her Maserati in the amount of $50,000. She sues In-N-Out in State Court in Pennsylvania (PA). Before trial, In-N-Out argues that the case should not be in Pennsylvania. The best argument that either party can bring is: