constitute sufficient contacts with Virginia, UHP does not even allege that Spir Star D. had such knowledge. UHP bases its argument that there are sufficient contacts on the fact that Spir Star D. has purposely availed itself of the United States market with no attempt to avoid Virginia. See UHP’s Brief at 6. There is absolutely no support in the case law for UHP’s theory of personal jurisdiction. Under UHP’s theory, anytime a company places a product into the stream of commerce, and does not take affirmative steps to keep its product out of a particular forum, the company would be subject to liability in that forum. In any event, the Fourth Circuit Court of Appeals has clearly rejected the stream of commerce theory. Federal Ins. Co. v. Lake Shore Inc., 886 F.2d 654, 659 (4th Cir.1989) (<HOLDING>). According to the court, placing a product in
holding court may rely on other evidence in the record where plaintiffs total time theory has been rejected holding that a plaintiff may not rely on an unadorned stream of commerce theory to justify the assertion of personal jurisdiction over defendants holding that a plaintiff may rely on the same evidence to prove both pretext and discrimination holding that the ij may not rely on a factually unsupported assertion in a state department report to deem an applicant not credible holding that court did not have personal jurisdiction over nonresident defendant because plaintiff failed to show that defendant was assignee of assignor over whom court had personal jurisdiction