Purposeful availment

The purposeful availment requirement in determining personal jurisdiction ensures that a nonresident defendant will not be haled into court based upon "random, fortuitous or attenuated" contacts with the forum state. This requirement is satisfied if the defendant "has taken deliberate action" toward the forum state. It is not required that a defendant be physically present or have physical contacts with the forum, so long as his efforts are "purposefully directed" toward forum residents.