In J. McIntyre Machinery, Ltd. v. Nicastro (2011) 564 U.S. 873, a British equipment manufacturer challenged a New Jersey court's finding of personal jurisdiction in a personal injury case brought by a worker who was injured by equipment manufactured by the defendant. The defendant argued it was not subject to personal jurisdiction because (1) all its sales were made through an independent distributor; (2) the defendant's officials had attended annual conventions in the United States, but never in New Jersey; and (3) "no more than four machines ... ended up in New Jersey." The New Jersey Supreme Court concluded the state court could exercise personal jurisdiction over the defendant because the defendant had placed its product in the "'stream-of-commerce'" and, thus, "knew or reasonably should have known 'that its products are distributed through a nationwide distribution system that might lead to those products being sold in any of the 50 states' ... ." (Ibid.) The United States Supreme Court held that more was required: "The defendant's transmission of goods permits the exercise of jurisdiction only where the defendant can be said to have targeted the forum; as a general rule, it is not enough that the defendant might have predicted that its goods will reach the forum state."