In Monroe Distrib., Inc. v. McClung, 1983 Ohio App, the court held that due process was not satisfied where "the defendant's sole contacts with Ohio were his dealings with the plaintiff"; "his contacts were initiated by the plaintiff in West Virginia and maintained via the mail and telephone"; "the defendant never supplied goods or services in Ohio, nor did he solicit business here"; and the "contacts were merely communication, the mailing of checks, and the return of two items of purchase." Id. at 4.