In As You Sow v. Crawford Laboratories, Inc. (1996) 50 Cal. App. 4th 1859, there was no general jurisdiction when an Illinois paint manufacturer sold products to private California distributors and the General Services Administration (GSA). It shipped some of its products to a GSA depot in California. Products either remained in California or were shipped to 16 different western states and Pacific overseas locations. All contract negotiations with GSA took place outside of California. The defendant knew some of the products would remain in California, but had no control over the products' final destination. The court held the unilateral activities of the GSA could not provide California with jurisdiction over the defendant. (Id. at p. 1868.) "Merely knowing the product will enter California, without having some control over its ultimate destination, does not satisfy the due process clause of the United States Constitution." (Id. at p. 1869.) "No evidence showed the defendant intended to serve a market in California with the products it shipped to the G.S.A." (Ibid.)