performing his employment contract, and (iii) his three trips to plaintiffs Virginia headquarters, also in the course of performing his employment contract. Each of these contacts, taken individually, might well be insufficient to warrant a finding of personal jurisdiction. It is clear, for example, that entering into a business agreement with a resident of the forum does not, without more, subject a nonresident defendant to personal jurisdiction in Virginia. America Online, Inc. v. Huang, 106 F.Supp.2d 848, 855-56 (E.D.Va.2000); Ellicott Machine, 995 F.2d at 478. And, the mere exchange of telephone calls, faxes, and written communications with a party in Virginia also may not suffice, although it may. Compare Unidyne Corp. v. Aerolineas Argentinas, 590 F.Supp. 391, 396 (E.D.Va.1984) (<HOLDING>), with Peanut, 696 F.2d at 314 (holding the
recognizing that a transaction that lacks economic substance generally reflects an arrangement in which the basis of the property was misvalued in the context of the transaction holding that unrebutted evidence can and should form the basis for summary judgment holding that being a guarantor alone is an insufficient basis to invoke personal jurisdiction holding telex messages and letters negotiating a transaction are insufficient to form a basis for in personam jurisdiction recognizing step transaction doctrine whereby courts must consider all steps of transaction in light of entire transaction so that substance of transaction will control over form of each step