In Burger King Corp. and Commonwealth ex rel. Pappert v. TAP Pharmaceutical Prods., Inc., 868 A.2d 624 (Pa. Cmwlth. 2005) the Supreme Court explained that the Due Process Clause protects liberty interests by requiring fair warning to individuals that particular activity may subject them to the jurisdiction of a foreign sovereign and that: "Where a forum seeks to assert specific jurisdiction over an out-of-state defendant who has not consented to suit there, this 'fair warning' requirement is satisfied if the defendant has 'purposefully directed' his activities at residents of the forum, ... and the litigation results from alleged injuries that 'arise out of or relate to' those activities." Burger King Corp., 471 U.S. at 472. There are several reasons why a forum may exercise personal jurisdiction over a nonresident who purposefully directs his activities toward forum residents, and "a State generally has a 'manifest interest' in providing its residents with a convenient forum for redressing injuries inflicted by out-of-state actors." Id. at 473. Although the unilateral activity of one who claims some relationship with a non-resident defendant cannot satisfy the requirement of contact with the forum state, "jurisdiction is proper, however, where the contacts proximately result from actions by the defendant himself that create a 'substantial connection' with the forum State." Id. at 475.