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Stream of Commerce PLUS

P sues Cheng who has 3rd party against Asahi – P settles, so Cheng and Asahi are fighting for contribution

D must purposefully avail actions toward forum state & have substantial connection

What is purposeful availment?  Sandra Day says:  stream of commerce + purposeful conduct for targeting the state - Look at Four Factors:
• Designing the product for the market in the forum state
• Advertising in the forum
• Channels to customers
• Marketing through a distributor

FIVE (majority) justices say stream of commerce is enough -
• Brennan:  benefiting economically from retail sales of product in the forum state – regular and anticipated flow of products from manufacturer to distributor to sale
• Stevens:  meeting first prong of WWVW of purposeful availment is determined by volume, value, and hazardous character of product

o All justices say need to meet reasonableness