Unlike the Connecticut statute, the District's general jurisdiction long-arm statute permits the Superior Court to exercise jurisdiction even if a plaintiff's claim does not arise out of an out-of-state defendant's activities in the forum. See D.C. Code 13-334 (a). 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 Cos. v. Seabest Foods, Inc., 14 Cal. 4th 434, 926 P.2d 1085, 1096 (Ca. 1996). Unlike its counterpart in the District, California's long-arm statute does not have an "arising from" requirement. Rather, California's long-arm statute states that "[a] court of this state may exercise jurisdiction on any basis not inconsistent with the Constitution of this state or of the United States." Cal. Code Civ. Proc. 410.10 (1999).