letter, the defendant “was purposefully defrauding [plaintiff] in California.” 912 F.2d at 1065. Similarly, in Brainerd v. Governors of the University of Alberta, 873 F.2d 1257 (9th Cir.1989), we held that an Arizona court could exercise specific jurisdiction over Canadian residents who, in response to telephone calls directed to them in Canada, made statements that allegedly defamed a person they knew resided in Arizona. Id. at 1259-60. Even though the Canadian defendants had not initiated the telephone calls, the statements they made about the plaintiff during the conversations were not “untargeted negligence” but rather were “performed for the very purpose of having their consequences felt in the forum state.” Id. See also Gordy v. Daily News, L.P., 95 F.3d 829, 833 (9th Cir.1996) (<HOLDING>); Lake v. Lake, 817 F.2d 1416, 1422-23 (9th
holding licensing agreement between defendant and nonparty texas resident was not relevant to specific jurisdiction holding that specific jurisdiction requires plaintiff to show that defendants forum contacts be related directly to the subject of the lawsuit holding that specific jurisdiction existed where defendant performed foreign acts for the purpose of having their consequences felt in the forum state holding that fraudulent joinder required a finding that either there was no possibility that the plaintiff could prove a cause of action against the resident defendant or that the plaintiff fraudulently pled jurisdictional facts in order to subject that resident defendant to the jurisdiction of the state court holding that specific jurisdiction existed in light of evidence of targeting of the plaintiff who was a forum resident