directed towards the state by the defendant. This jurisdiction was initially limited to the particulars of the International Shoe Co. v. Washington holding, that is to jurisdictional inquiries regarding companies, but was soon extended to apply to all questions of personal jurisdiction. When an individual or entity has no "minimum contacts" with a forum State, the Due Process Clause of the Fourteenth Amendment prohibits that State from acting against that individual, or entity. The lack of "minimum contacts" with the owner of property also constitutionally prohibits action against that property (in rem jurisdiction) even when the property is located within the forum state. What constitutes sufficient "minimum contacts" has been delineated in numerous cases which followed the International Shoe decision. For example, in Hanson v. Denckla, the Court proclaimed the "unilateral activity of those who claim some relationship with a nonresident cannot satisfy the requirement of contact with the forum State. The application of that rule will vary with the nature and quality of the defendant's activity, but it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protection of its laws." The additional requirement of "'purposeful availment' ensures that a defendant will not be hauled into a jurisdiction solely as a result of 'random,' 'fortuitous,' or 'attenuated' contacts, or of the unilateral activity of another party or a third person". Jurisdiction may, however, be exercised, under some circumstances, even though the defendant never physically entered the forum state. In addition, the claim must arise from those contacts that the defendant had with the forum state. In addition to the minimum contacts test asserted in International Shoe, the assertion of specific personal jurisdiction must be reasonable. The Court in World-Wide Volkswagen Corp. v. Woodson asserted a five-part test for determining if the assertion of personal jurisdiction in a forum state was reasonable. This test considers: the burden on the defendant from litigating in the forum state; the interest of the forum state in having the case adjudicated there; the interests of the plaintiff in adjudicating in the forum state; the interests of the inter-state judiciary—that is, that a court's assertion of personal jurisdiction over an out-of state defendant would not overreach and preempt the interests and judicial sovereignty of another state; and the interests in preserving the