489 U.S. 1018, 109 S.Ct. 1135, 103 L.Ed.2d 196 (1989); Taubler v. Giraud, 655 F.2d 991, 995 (9th Cir.1981); United States v. Toyota Motor Corp., 561 F.Supp. 354, 356 (C.D.Cal.1983); Meyers v. Asics Corp., 11 USPQ 1777, 1780 (C.D.Cal.1989). This assessment is an overstatement; existing authority, at best, is split on this issue. Many cases sensibly conclude that the practice of sending shipments FOB is one of many factors to be considered in assessing the propriety of personal jurisdiction. See, e.g., Ben & Jerry's Homemade, Inc. v. Coronet Priscilla Ice Cream Corp., 921 F.Supp. 1206, 1211 (D.Vt.1996) (finding "the place of passage of title and risk of loss relevant to the exercise of personal jurisdiction”); Federal Ins. Co. v. Lake Shore, Inc., 886 F.2d 654, 658-59 (4th Cir.1989) (<HOLDING>); Lemme v. Wine of Japan Import, Inc., 631
holding that a choice of law provision is not sufficient to confer personal jurisdiction over a nonresident defendant recognizing south carolina as the governing law and finding no south carolina cases directly on point the court referred to applicable law from other jurisdictions recognizing south carolina as a jurisdiction where service on statutory agent is exclusive holding nonresident partnership not subject to personal jurisdiction of texas court although it sold and shipped to texas plaintiff goods that were subject of breach of contract claim holding nonresident defendants sales to south carolina insufficient to confer personal jurisdiction because in part the sold products were shipped fob michigan