at 1046; Cornfeld, 619 F.2d at 920-21. Because the Zoelsch court correctly stated this standard, Zoelsch, 824 F.2d at 30-31, we assume that its speculation as to what the rule “seems to be” is a simple misreading of the cases that was not intended to work any sort of implicit change in the substantive law. In any case, the Zoelsch court explicitly adopted the Second Circuit’s test for jurisdiction, id. at 33, and thus cannot reasonably be read to have fashioned a new rule. 11 . SEC v. Kasser, 548 F.2d 109, 114 (3d Cir.1977); Continental Grain, 592 F.2d at 420-21; Travis v. Anthes Imperial, Ltd., 473 F.2d 515, 524 (8th Cir.1973); Butte Mining PLC v. Smith, 76 F.3d 287, 290-91 (9th Cir.1996); Grunenthal GmbH v. Hotz, 712 F.2d 421, 424-25 (9th Cir.1983). 12 . See Kasser, 548 F.2d at 114 (<HOLDING>); Continental Grain, 592 F.2d at 421 (holding
recognizing the constitutionality of at least some amount of political gerrymandering holding illinois wage law only applied where at least some work was performed within the state holding that the test is whether at least some activity designed to further a fraudulent scheme occurs within this country holding that convictions under  111 require at least some form of assault holding that at least where part of extensive scheme of other extortionate activity threat of litigation may constitute extortion under hobbs act