In Spirits, Inc. v. Superior Court (1980) 104 Cal.App.3d 918, a California resident was injured in Arizona when a bottle of Pepsi-Cola she had purchased in Arizona exploded in her hand, injuring her, also in Arizona. In the ensuing California action, the trial court declined to quash service of summons upon the defendant Arizona retailer who had sold plaintiff the offending bottle of Pepsi-Cola. On petition for writ of mandate by the defendant, the Court of Appeal directed the trial court to grant the motion to quash service of summons on the defendant. The plaintiff in Spirits urged the application of the concept of commercial actuality, renamed "economic reality," as the basis for deeming the defendant's sales in Arizona as having in legal effect occurred in California. Impliedly, this in turn would allow jurisdiction to attach without offending traditional notions of fair play and substantial justice. ( Id. at pp. 922-923.)