In Vons Companies, Inc. v. Seabest Foods, Inc. (1996) 14 Cal.4th 434, the Court explained that a forum state may exercise specific jurisdiction over a nonresident who purposefully avails himself or herself of forum benefits "because the state has 'a "manifest interest" in providing its residents with a convenient forum for redressing injuries inflicted by out-of-state actors. Moreover, where individuals "purposely derive benefit" from their interstate activities citation it may well be unfair to allow them to escape having to account in other States for consequences that arise proximately from such activities.' Further, 'because "modern transportation and communications have made it much less burdensome for a party sued to defend himself in a State where he engages in economic activity," it usually will not be unfair to subject him to the burdens of litigating in another forum for disputes relating to such activity.'" (Vons Companies, Inc., supra, 14 Cal. 4th at p. 447.) Vons Companies, Inc. added that "a claim need not arise directly from the defendant's forum contacts in order to be sufficiently related to the contact to warrant the exercise of specific jurisdiction. Rather, as long as the claim bears a substantial connection to the nonresident's forum contacts, the exercise of specific jurisdiction is appropriate. The due process clause is concerned with protecting nonresident defendants from being brought unfairly into court in the forum, on the basis of random contacts. That constitutional provision, however, does not provide defendants with a shield against jurisdiction when the defendant purposefully has availed himself or herself of benefits in the forum." (Vons Companies, Inc., supra, 14 Cal. 4th at p. 452.)