578 (finding purposeful availment because of foreign corporation’s “additional conduct through which it aimed to get extensive business in or from this state”). Indeed, specific jurisdiction over foreign manufacturers is often premised on sales by independent distributors. See, e.g., Bridgeport Music, Inc. v. Still N The Water Publ’g, 327 F.3d 472, 483-84 (6th Cir.2003) (finding specific jurisdiction under “additional conduct” standard based in part on nationwide distribution agreement with independent distributor); Kuenzle v. HTM Sport-Und Freizeitgerate AG, 102 F.3d 453, 458 (10th Cir.1996) (noting that “[t]he actions of an independent distributor may not insulate a foreign company from specific jurisdiction”); Tobin v. Astra Pharm. Prods., Inc., 993 F.2d 528, 533-34 (6th Cir.1993) (<HOLDING>); see also Pennzoil Prods. Co. v. Colelli &
holding that the exercise of personal jurisdiction over a nonresident auto distributor whose only connection to the forum resulted from a customers decision to drive there failed to provide the defendant with clear notice that it would be subject to suit in the forum state and thus an opportunity to alleviate the risk of burden some litigation there holding that personal jurisdiction over defendant car manufacturer was inappropriate when defendants only contacts with the forum resulted from plaintiffs unilateral activity of driving defendants product into another state holding that foreign drag manufacturer who marketed its product in kentucky through independent distributor was nonetheless subject to personal jurisdiction in forum under asahis additional conduct standard holding defendant a foreign manufacturer was not subject to the personal jurisdiction of a wyoming court because the plaintiff failed to introduce sufficient evidence to establish an agency relationship between the defendant and its us distributor holding consumers unilateral act of taking product to forum state insufficient to subject manufacturer to jurisdiction there