In A. Uberti & C. v. Leonardo, 181 Ariz. 565, 569, 892 P.2d 1354, 1358 (1995), an Italian gun manufacturer made and distributed a replica of a handgun popular in the American West in the nineteenth century. 181 Ariz. at 567, 571-73, 892 P.2d at 1356, 1360-62.
Because the defendant manufacturer was an international seller of firearms and had knowingly directed its goods at the United States as a whole, our supreme court ruled Arizona's exercise of jurisdiction did not require a showing that the defendant had a "specific intent to market the gun in Arizona." Id. at 573, 892 P.2d at 1362.
Rather, "an intent to sell across America was enough." Id.
Of particular concern to the Uberti court was the fact that, if the defendant manufacturer were not subject to Arizona's jurisdiction merely because it had not specifically intended to sell its product in this state or focused its marketing activities toward Arizona in particular, by the same reasoning, it would not be subject to personal jurisdiction in any American court. Id.
As the court stated:
"Due process does not give foreign companies a safe harbor to manufacture goods designed for and shipped to America and at the same time immunize them from the penalties of noncompliance with American safety standards." Id. at 574, 892 P.2d at 1363.