In Asahi Metal Indus. Co. v. Superior Court of Calif., 480 U.S. 102, 110-11, 94 L. Ed. 2d 92, 107 S. Ct. 1026 (1987), Justice O'Connor, writing for a four-member plurality, stated as follows: The "substantial connection" between the defendant and the forum State necessary for a finding of minimum contacts must come about by an action of the defendant purposefully directed toward the forum State. The placement of a product into the stream of commerce, without more, is not an act of the defendant purposefully directed toward the forum State. Additional conduct of the defendant may indicate an intent or purpose to serve the market in the forum State, for example, designing the product for the market in the forum State, advertising in the forum State, establishing channels for providing regular advice to customers in the forum State, or marketing the product through a distributor who has agreed to serve as the sales agent in the forum State. But a defendant's awareness that the stream of commerce may or will sweep the product into the forum State does not convert the mere act of placing the product into the stream into an act purposefully directed toward the forum State. Asahi, 480 U.S. at 110-112, 107 S. Ct. at 1031-1032.