LAW 521-002 – Civil Procedure I
Stream of Commerce
Stream of commerce theory permits jurisdiction when the defendant delivers his product into the stream of commerce through a distributor with the expectation that it will be purchased by consumers in the forum state such that he should reasonably anticipate being haled into court there.
There are two rules on the sufficiency of stream of commerce:
Courts will likely begin to lean toward McIntyre rule.
One must check which rule his jurisdiction is following.
Fourth Circuit follows McIntyre. However, it accepts that sufficient contacts exist if a defendant "targeted the forum" with it goods.