omitted). 68 . See Cossaboon, 600 F.3d at 33 (citing Noonan v. Winston, 135 F.3d 85, 93 (1st Cir.1998)) (discussing how a court's exercise of general jurisdiction depends on its view of the contacts in the aggregate but may separately examine each of the contacts). 69 . Fiske v. Sandvik Mining & Constr. USA, LLC, 540 F.Supp.2d 250, 256 (D.Mass.2008) (citing Sandstrom v. ChemLawn Corp., 904 F.2d 83, 90 (1st Cir.1990)). 70 . Sandstrom, 904 F.2d at 90 (explaining that a forum state could not constitutionally exercise general jurisdiction over a party that was both registered to do business in the state and was involved in litigation in that state (internal citations omitted)). 71 . See Newman v. European Aeronautic Defence & Space Co. EADS N.V., 700 F.Supp.2d 156, 168-69 (D.Mass.2010) (<HOLDING>). 72 . See Cossaboon, 600 F.3d at 31 (noting
holding that the court must look for continuous and systematic general business contacts  ie general jurisdiction  if the causes of action do not arise from or relate to the foreign defendants contacts with the forum state 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 the district court could not exercise general jurisdiction over the simcom defendants where defendants derived 136 of its revenue from the forum state but were not registered to do business in massachusetts and had no massachusettsbased employees holding that defendants activities were not sufficient to support general jurisdiction where it did not maintain an office do business itself in the state nor have an agent in the state holding that a company that derived revenue from leasing its property was in business for purposes for the coal act