In Innovative Clinical & Consulting Servs. v. First Nat'l Bank, 279 Ga. 672 (620 SE2d 352) (2005), the Supreme Court of Georgia construed subsection (1) of the Georgia long-arm statute to extend jurisdiction to the maximum limits permitted by procedural due process. OCGA 9-10-91 (1). The trial court determined that Vibratech's activities in placing its dampers into the stream of commerce by manufacturing, selling and delivering them for resale were sufficient to satisfy the requirements of due process and to confer jurisdiction over the company. Vibratech counters, however, even under Innovative Clinical's expanded interpretation of subsection (1), the language of the statute requires more than merely putting merchandise into the stream of commerce; it still requires the actual transaction of business by the defendant in Georgia. In Innovative Clinical, our Supreme Court reaffirmed its prior holding in Gust v. Flint, 257 Ga. 129 (356 SE2d 513) (1987) that "the rule that controls is our statute, which requires that an out-of-state defendant must do certain acts within the State of Georgia before he can be subjected to personal jurisdiction." Innovative Clinical, 279 Ga. at 673. But the court stated that prior cases had "unduly limited the literal language" of the long-arm statute. Id. Addressing subsection (1), the court observed that nothing in the subsection's language requires the defendant's physical presence in Georgia or minimizes the importance of a nonresident's intangible contacts with the state. Id. at 675. Rather, the language of OCGA 9-10-91 (1) must be construed as reaching "to the maximum extent permitted by procedural due process." Id.