Showa Denko K. K. v. Pangle

In Showa Denko K. K. v. Pangle, 202 Ga. App. 245, 247 (414 SE2d 658) (1991), the Court applied a due process analysis to determine whether sufficient minimum contacts existed to extend jurisdiction under subsection (2) of the long-arm statute over a Japanese manufacturer of amino acids. The manufacturer shipped its product to several out-of-state U. S. manufacturers for inclusion in nutritional supplements, which were in turn distributed on a nationwide basis, including deliveries in Georgia. Showa Denko v. Pangle, 202 Ga. App. at 247. The court determined that "whether the introduction of a product into the stream of commerce establishes minimum contacts with a state in which the product is ultimately sold depends on the foreseeability that the product would be sold there." Id. at 247-248. The requisite foreseeability is "not the mere likelihood that the product will find its way into the forum State," but whether "the defendant's conduct and connection within the forum State are such that he should reasonably anticipate being haled into court there." Id. at 248.