The specific-jurisdiction requirement that “the suit must arise out of or relate to the defendant’s contacts with the forum” has existed for a long time. Id. at 1780. BMS cited cases from the mid-1980s, but its antecedents go back to International Shoe v. Washington, 326 U.S. 310 (1945), itself. While some courts (and some defense amici in BMS) interpret that requirement as requiring “causation,” the Supreme Court did not address that question.
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