ensures that a nonresident defendant will not be haled into court based upon “random, fortuitous or attenuated” contacts with the forum state. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985). This requirement is satisfied if the defendant “has taken deliberate action” toward the forum state. Panavision Intern., L.P. v. Toep-pen, 141 F.3d 1316, 1320 (9th Cir.1998). Application of the purposeful availment requirement differs depending on whether the underlying claim is in tort or contract. Ziegler v. Indian River County, 64 F.3d 470, 473 (9th Cir.1995). In tort cases, jurisdiction may attach if the defendant’s conduct is aimed at or has an effect in the forum state. See Calder v. Jones, 465 U.S. 783, 789-90, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (<HOLDING>); see also Panavision, 141 F.3d at 1321. Under
holding that an intentional tort knowingly directed at a forum resident satisfies the minimum contacts test holding that personal jurisdiction over a party is proper if the party has sufficient minimum contacts with the forum holding that minimum contacts exist if the defendant has purposely directed his activities at residents of the forum and the litigation results from alleged injuries that arise out of or relate to those activities holding that sufficient minimum contacts exist when nonresident defendant purposefully directed action toward texas holding that minimum contacts exist if the defendant has purposefully directed his activities at residents of the forum and the litigation results from alleged injuries that arise out of or relate to those activities