the in-state banking activities of these French and Japanese banks and Plaintiffs’ claims arising from a terrorist attack that occurred in Israel with the support of the Iranian government. It certainly cannot be said that Plaintiffs’ claims “directly arise” out of the banking activities of these local branches. See GCIU, 565 F.3d at 1024. Thus, under traditional legal principles, specific jurisdiction is lacking. Although the Seventh Circuit • has not addressed this issue, two Circuits have reformulated the minimum-contacts inquiry in cases involving third-party discovery, focusing more narrowly “on the connection between the nonparty’s contacts with the forum and the discovery order at issue.” Gucci, 768 F.3d at 137; see also S.E.C. v. Knowles, 87 F.3d 413, 418 (10th Cir.1996) (<HOLDING>)., It is unclear whether this test is proper,
holding that standing alone defendants 4 million in sales in the forum state over a sevenyear period may not have been sufficient to support the exercise of general jurisdiction but that the numerous other contacts with the forum in the case including advertising relationships with dealers and more than 150 visits tipped the balance and led the court to conclude that there were sufficient contacts to allow the exercise of general jurisdiction holding that specific jurisdiction requires plaintiff to show that defendants forum contacts be related directly to the subject of the lawsuit holding no specific jurisdiction where alleged tortious conduct was not related to defendants contacts with texas holding that courts exercise of specific jurisdiction was proper where subpoena enforcement action arose out of nonpartys contacts with the forum holding that personal jurisdiction over a party is proper if the party has sufficient minimum contacts with the forum