Whether the 'minimum contacts' requirement for specific jurisdiction is satisfied whenever a defendant has made limited sales of products to customers based in the forum State, even when there is no evidence that those customers used or resold those products in that State

QUESTIONS PRESENTED This Court has held that a state court can exercise specific personal jurisdiction over a non-resident defendant with respect to a plaintiff’s cause of action consistent with the Due Process Clause of the Fourteenth Amendment only when (1) the defendant has sufficient minimum contacts with the State that show that it has purposefully availed itself of the privilege of conducting activities in the State; (2) the plaintiff’s cause of action arises out of or relates to those forum contacts; and (3) the exercise of personal jurisdiction would comport with traditional notions of fair play and substantial justice. Ford Motor Co. v. Montana Eighth Judicial Dist. Ct., 141 S. Ct. 1017, 1024-1025 (2021). In this case, the Oklahoma Supreme Court found this standard satisfied solely because there was evidence that the defendant made a small number of sales of some of its allegedly defective products to customers based in Oklahoma even though there was no evidence that those customers used or resold the products in Oklahoma. The questions presented are: 1. Whether the “minimum contacts” requirement for specific jurisdiction is satisfied whenever a defendant has made limited sales of products to customers based in the forum State, even when there is no evidence that those customers used or resold those products in that State. 2. If the answer to question 1 is yes, whether a plaintiff’s cause of action can be said to relate to or arise out of the defendant’s forum contacts in the absence of evidence about which of the defendant’s products allegedly caused the plaintiff’s injury.