US v. Swiss American

Case Date: 09/10/1999
Court: United States Court of Appeals
Docket No: 99-1012

United States Court of Appeals
For the First Circuit




No. 99-1012

UNITED STATES OF AMERICA,
Plaintiff, Appellant,

v.

SWISS AMERICAN BANK, LTD., ET AL.,
Defendants, Appellees.



APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. William G. Young, U.S. District Judge]



Before

Selya, Boudin and Lipez,

Circuit Judges.



Stephen R. Heifetz, Trial Attorney, with whom Gerald E.
McDowell, Chief, Asset Forfeiture and Money Laundering Section,
Criminal Division, U.S. Dep't of Justice, Stefan D. Cassella,
Assistant Chief, and Richard L. Hoffman, Assistant United States
Attorney, were on brief, for appellant.
Howard Wilson, with whom Howard Fischer, Rosenman & Colin LLP,
Michael B. Keating, Sarah Cooleybeck, and Foley, Hoag & Eliot LLP
were on brief, for appellees Swiss American Bank, Ltd. and Swiss
American National Bank.
William Shaw McDermott, with whom Irene C. Freidel, Edward S.
Horton, and Kirkpatrick & Lockhart LLP were on brief, for appellee
Bank of New York Intermaritime Bank (Geneva).





September 8, 1999



SELYA, Circuit Judge. This appeal raises issues of first
impression, requiring us to delineate the circumstances under which
foreign corporations may be brought before the federal courts
through the medium of a recently enacted provision of the Civil
Rules. In the underlying case, the government brought suit in the
United States District Court for the District of Massachusetts
against several foreign banking concerns in an effort to recover
assets accumulated by a convicted felon and later forfeited to the
government as part of a plea bargain. The district court accepted
the defendants' argument that they were not within its
jurisdictional reach and thus were not amenable to suit. At the
same time, the court denied the government's request for
jurisdictional discovery. The United States has appealed both
rulings. We vacate these orders and remand for further proceedings
consistent with this opinion.
I. BACKGROUND
We start by introducing the appellees and then turn to
the forfeiture proceedings and what transpired below.
In its suit, the United States named four corporations as
defendants. Two of these entities, Swiss American Bank, Limited,
and Swiss American National Bank (collectively, "Swiss American" or
"the Swiss American banks"), are institutions organized under the
law of Antigua and Barbuda ("Antigua"), and headquartered there.
A third defendant, Bank of New York-InterMaritime Bank ("IMB"), is
organized under Swiss law and based in Geneva. Prior to December
28, 1987, IMB owned all the shares of the fourth defendant, Swiss
American Holding Company ("SAHC"), a Panamanian corporation, and it
owned at least some of SAHC's stock until December 15, 1988.
Throughout that period, the Swiss American banks were wholly-owned
subsidiaries of SAHC.
In mid-1993, the government entered into a plea agreement
with John E. Fitzgerald. As part of this bargain, Fitzgerald pled
guilty to manifold charges of engaging in a racketeering conspiracy
and attempted money laundering. He simultaneously conceded that
the monies on deposit in various accounts that he had opened were
fruits of his criminal activity. These funds included
approximately $7,000,000 that Fitzgerald had laundered through
several shell corporations and eventually deposited with Swiss
American between 1985 and 1987.
Notice of the impending forfeiture was published in
newspapers of general circulation in both Massachusetts and
Antigua. No competing claims to the funds were filed, although
Swiss American informed the district court that the Antiguan
government had frozen the accounts in question. The court
subsequently entered a final order of forfeiture, see 18 U.S.C. 
1963, which decreed, inter alia, that "any and all interest of John
E. Fitzgerald in the principal and accrued interest in the
[subject] bank accounts" be "condemned, forfeited and vested in the
United States." United States v. Fitzgerald, No. 93-10149-RWZ (D.
Mass. May 4, 1994).
Despite the district court's ukase, Swiss American
apparently disbursed some $5,000,000 from the subject accounts to
the Antiguan authorities and confiscated the rest. The government
of Antigua then took the position that, although it had not
demanded that any part of Fitzgerald's assets be transferred to it,
the monies it had received were no longer available to the United
States. The United States responded by filing the instant action
against the four defendants whom we have identified, asserting
claims of conversion, unjust enrichment, and breach of contract.
The defendants moved to dismiss for want of personal jurisdiction.
See Fed. R. Civ. P. 12(b)(2). The lower court agreed with the
central premise of the defendants' motions, overrode the
government's request for jurisdictional discovery, and dismissed
the action. See United States v. Swiss American Bank, Ltd., 23 F.
Supp. 2d 130 (D. Mass. 1998). This appeal followed.
II. ANALYSIS
We divide our substantive discussion into four parts. We
begin with the anatomy of the personal jurisdiction inquiry, in
hope of providing a template for the more specific analyses that
follow. We then proceed to address the government's two main
jurisdictional arguments. Finally, we comment upon a separate
point advanced exclusively by IMB.
A. Personal Jurisdiction: An Overview.
It is common ground that, for a court to render a binding
decision consonant with due process, it must have personal
jurisdiction over the parties, that is, the power to require the
parties to obey its decrees. See Burnham v. Superior Court, 495
U.S. 604, 608-09 (1990). Because a plaintiff ordinarily consents
to a court's jurisdiction by filing suit, disputes over personal
jurisdiction typically feature the forum court's relationship to
one or more defendants. Here, the jurisdictional analysis depends
upon whether any statute or rule authorizes the forum court to
exercise its dominion over the defendants, and if so, whether the
court's exercise of that jurisdiction would comport with due
process.
The constitutional inquiry proceeds in three steps:
relatedness, purposeful availment, and reasonableness. See
Foster-Miller, Inc. v. Babcock & Wilcox Canada, 46 F.3d 138, 144
(1st Cir. 1995). At the first stage, the court must ask whether
the claim at issue arises out of or is related to the defendant's
conduct within the forum state. See id.; see also Ticketmaster-New
York, Inc. v. Alioto, 26 F.3d 201, 206-07 (1st Cir. 1994). At the
second step, the court must scrutinize the defendant's contacts
with the forum state to determine whether those contacts constitute
purposeful activity, such that being haled into court there would
be foreseeable. See Foster-Miller, 46 F.3d at 144; Ticketmaster,
26 F.3d at 207. Lastly, the Constitution imposes an overall
reasonableness restraint on the exercise of personal jurisdiction.
See World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 292
(1980); United Elec., Radio and Mach. Workers v. 163 Pleasant St.
Corp., 960 F.2d 1080, 1088 (1st Cir. 1992). An exercise of
personal jurisdiction thus complies with constitutional imperatives
only if the defendant's contacts with the forum relate sufficiently
to his claim, are minimally adequate to constitute purposeful
availment, and render resolution of the dispute in the forum state
reasonable.
These constitutional requirements comprise a final hurdle
for an aspiring plaintiff. A court need not even consider them
unless it possesses statutory authorization to exercise specific
personal jurisdiction over defendants of the type that the
plaintiff targets. This authorization may derive from a federal
statute, see, e.g., 15 U.S.C.  22 (providing for worldwide service
of process on certain corporate antitrust defendants), or from a
state statute of general application, see, e.g., Mass. Gen. Laws
ch. 223A,  3 (providing "long-arm" jurisdiction). A state long-
arm statute furnishes a mechanism for obtaining personal
jurisdiction in federal as well as state courts. See Fed. R. Civ.
P. 4(k)(1)(A).
In limited circumstances, the requisite authorization can
be provided by Rule 4(k)(2), quoted infra Part II(C), which
functions as a sort of federal long-arm statute. When a plaintiff
depends upon this recently adopted rule to serve as the necessary
statutory authorization for the exercise of specific personal
jurisdiction, the constitutional requirements are the same as those
limned above, but the analytic exercises are performed with
reference to the United States as a whole, rather than with
reference to a particular state. The defendant's national contacts
take center stage because the rule applies only to situations in
which federal courts draw jurisdictional authority from the federal
sovereign (unreinforced by "borrowed" state statutes), and, thus,
the applicable constitutional requirements devolve from the Fifth
rather than the Fourteenth Amendment. See Fed. R. Civ. P. 4
advisory committee note; 4 Charles Alan Wright & Arthur R. Miller,
Federal Practice and Procedure  1067.1 (1999 Supp.); Gary B. Born
& Andrew N. Vollmer, The Effect of the Revised Federal Rules of
Civil Procedure on Personal Jurisdiction, Service, and Discovery in
International Cases, 150 F.R.D. 221, 225 (1993).
With this general schematic in place, we proceed to
consider the government's two suggested bases for the assertion of
personal jurisdiction over the defendants in the District of
Massachusetts: the Massachusetts long-arm statute, Mass. Gen. Laws
ch. 223A,  3(a) & (d), and Rule 4(k)(2). Our review of the
district court's ruling in this respect is plenary. See Foster-
Miller, 46 F.3d at 147-48; Boit v. Gar-Tec Prods., Inc., 967 F.2d
671, 675 (1st Cir. 1992); see also Swiss American, 23 F. Supp. 2d
at 133 (accepting as true the government's properly documented
factual averments and evidentiary proffers).
B. Massachusetts Long-Arm Jurisdiction.
Somewhat paradoxically, we begin our inquiry into the
reach of the Massachusetts long-arm statute by citing the federal
procedural rule that imbues it with relevance for present purposes.
The rule states that:
Service of a summons . . . is effective to
establish jurisdiction over the person of a
defendant who could be subjected to the
jurisdiction of a court of general
jurisdiction in the state in which the
district court is located.

Fed. R. Civ. P. 4(k)(1)(A). Because the United States sued in the
District of Massachusetts, Rule 4(k)(1)(A) permits recourse to the
Massachusetts long-arm statute. The government directs our
attention to two subsections of that law. We mull each in turn.
1. Section 3(a). Section 3(a) of the Massachusetts
long-arm statute permits courts to exercise personal jurisdiction
"over a person, who acts directly or by an agent, as to a cause of
action in law or equity arising from the person's . . . transacting
any business in this commonwealth." Mass. Gen. Laws ch. 223A, 
3(a). We need not linger long over this proviso. For present
purposes, it suffices to say that the United States did not argue
section 3(a)'s applicability below. Consequently, we may reject
the government's belated claim of statutory authorization out of
hand. See Pleasant St., 960 F.2d at 1096 (holding that a plaintiff
had waived an argument by which it attempted to salvage personal
jurisdiction on appeal because it had not raised the point in the
lower court); Teamsters, Etc., Local No. 59 v. Superline Transp.
Co., 953 F.2d 17, 21 (1st Cir. 1992) (holding that legal theories
not advanced in the trial court ordinarily are deemed waived on
appeal).
2. Section 3(d). Section 3(d) of the Massachusetts
long-arm statute authorizes personal jurisdiction over one who
causes "tortious injury in this commonwealth by an act or omission
outside this commonwealth if he regularly does or solicits
business, or engages in any other persistent course of conduct, or
derives substantial revenue from goods used or consumed or services
rendered, in this commonwealth." Mass. Gen. Laws ch. 223,  3(d).
Although the government properly preserved its claim of
jurisdiction premised on this statutory ground, the claim lacks
merit for two reasons.
First and foremost, there is no showing here that the
United States suffered tortious injury in Massachusetts. The legal
injury occasioned by the tort of conversion is deemed to occur
where the actual conversion takes place. See Cycles, Ltd. v. W.J.
Digby, Inc., 889 F.2d 612, 619 (5th Cir. 1989). In this instance,
the bank accounts were depleted and the forfeited assets redirected
in Antigua, and, thus, the claimed injury occurred there. See Wenz
v. Memery Crystal, 55 F.3d 1503, 1507-1508 (10th Cir. 1995)
(holding that, under a similar long-arm provision, the tortious
injury underlying an action for conversion of funds from London
accounts by London-based tortfeasors occurred in London). By like
token, since the government's claim of unjust enrichment is
essentially a claim for restitution based on the alleged
conversion, see Restatement of the Law on Restitution, Quasi
Contracts, and Constructive Trusts  128 (1937), the legal injury
stemming from it also must be presumed to have taken place in
Antigua.
To blunt the force of this reality, the government
replies that the forfeiture order was issued in Massachusetts.
Fair enough but this fact at most demonstrates that, upon the
occurrence of the alleged conversion and the consequent unjust
enrichment, the United States felt the effects of a tortious injury
in the forum state. See Carty v. Beech Aircraft Corp., 679 F.2d
1051, 1064-65 (3d Cir. 1982) (collecting cases that distinguish
tortious injury from the resulting economic harms). And since
section 3(d) requires that the injury itself occur in
Massachusetts, and does not apply merely because the plaintiff
feels the effects of a tortious injury there, see Crocker v. Hilton
Int'l Barbados, Ltd., 976 F.2d 797, 799-800 (1st Cir. 1992);
Cunningham v. Ardrox, Inc., 40 Mass. App. Ct. 279, 282-83 (1996);
see also Friedr. Zoellner (N.Y.) Corp. v. Tex Metals Co., 396 F.2d
300, 302-03 (2d Cir. 1968) (holding that a similar jurisdictional
statute "is not satisfied by remote or consequential injuries
[flowing from a conversion] which occurred in [the forum state],"
notwithstanding that "the plaintiff is domiciled, incorporated or
doing business in th[at] state"), these observations effectively
end the matter.
The second reason why the government's invocation of
section 3(d) misfires, involves the statutory requirement that the
plaintiff must show that the defendant derived substantial revenue
from services rendered in Massachusetts. In this instance,
Fitzgerald (the money launderer who generated the cash) journeyed
to Antigua to open the subject accounts and transferred the funds
to the Swiss American banks from other foreign locations. On these
facts, the government's plea reduces to an assertion that the
defendants derived substantial revenue from within the commonwealth
because the deposits originated with a Massachusetts resident. The
statute specifies that substantial revenue must be derived from
services which are "rendered . . . in" Massachusetts, Mass. Gen.
Laws ch. 223(A),  3(d), and the residency connection, standing
alone, is simply too attenuated to satisfy this benchmark. For
aught that appears, any services rendered by the defendants in the
instant case were rendered in Antigua.
Inasmuch as the government has not met either of the
dispositive criteria for authorization of personal jurisdiction
under section 3(d), we uphold the district court's ruling that
personal jurisdiction cannot be premised on the Massachusetts long-
arm statute. See Swiss American, 23 F. Supp. 2d at 134.
C. Jurisdiction Under Rule 4(k)(2).
The government claims, in the alternative, that the
district court possessed in personam jurisdiction under Rule
4(k)(2). The rule, first enacted in December 1993, provides:
If the exercise of jurisdiction is consistent
with the Constitution and laws of the United
States, serving a summons or filing a waiver
of service is also effective, with respect to
claims arising under federal law, to establish
personal jurisdiction over the person of any
defendant who is not subject to the
jurisdiction of the courts of general
jurisdiction of any state.

Fed. R. Civ. P. 4(k)(2). The rule's fabric contains three strands:
(1) the plaintiff's claim must be one arising under federal law;
(2) the putative defendant must be beyond the jurisdictional reach
of any state court of general jurisdiction; and (3) the federal
courts' exercise of personal jurisdiction over the defendant must
not offend the Constitution or other federal law. Despite a
suggestion that the government had waived the right to rely on Rule
4(k)(2), the district court reached the merits of the government's
claim and found it wanting on the second of these grounds. See
Swiss American, 23 F. Supp. 2d at 136. Taking our cue from the
district court, we begin with this element.
1. The Negation Requirement. By its terms, Rule 4(k)(2)
requires that the putative defendant not be subject to jurisdiction
in any state court of general jurisdiction. The government argues
that this requirement encompasses both subject matter and personal
jurisdiction, and that, therefore, it can satisfy the negation
requirement simply by showing that the state courts have no subject
matter jurisdiction over a particular cause of action. Building on
this porous foundation, the government then argues that 28 U.S.C.
 1345 the statute under which it brought this suit grants
exclusive subject matter jurisdiction to the federal courts.
We find this reasoning unconvincing. Whether or not
section 1345 provides an exclusive grant of subject matter
jurisdiction a matter on which we take no view we nonetheless
consider it pellucid that Rule 4(k)(2)'s reference to defendants
who are "not subject to the jurisdiction . . ." refers to the
absence of personal jurisdiction. We explain briefly.
Service is the traditional means by which a court
establishes personal jurisdiction over a defendant. See Burnham,
495 U.S. at 610-11. Section (k) of Rule 4 governs the
circumstances in which service (or waiver of service) will suffice
to confer personal jurisdiction. The rule's two subsections both
speak of the means by which "jurisdiction over the person" of a
defendant can be established. See Fed. R. Civ. P. 4(k)(1)-(2). In
this setting, it strains credulity to suggest that the mention of
the unmodified word "jurisdiction" should be construed as anything
other than a reference to "personal jurisdiction," when that
understanding of the term makes reasonable sense in application (as
it does here). It is, therefore, unsurprising that courts and
commentators consistently have construed Rule 4(k)(2)'s allusion to
the "jurisdiction" of the state courts to relate to personal
jurisdiction. See, e.g., World Tanker Carriers Corp. v. MV Ya
Mawlaya, 99 F.3d 717, 720 (5th Cir. 1996); CFMT Inc. v. Steag
Microtech, Inc., Civ.A. No. 95-442-LON, 1997 WL 313161, at *7 (D.
Del. Jan. 9, 1997); see also Born & Vollmer, supra, 150 F.R.D. at
226-27; Leslie M. Kelleher, The December 1993 Amendments to the
Federal Rules of Civil Procedure A Critical Analysis, 12 Touro L.
Rev. 7, 35 (1995).
The case law under Rule 4(k)(1) bolsters this
interpretation. Under that rule, federal courts routinely have
determined whether state courts would have personal jurisdiction
over a defendant, even in cases of exclusive federal jurisdiction.
See, e.g., Janmark, Inc. v. Reidy, 132 F.3d 1200, 1201 (7th Cir.
1997) (commenting on the paradox of asking whether a state court
would have personal jurisdiction in a federal copyright case). If
the term "jurisdiction" in the text of Rule 4(k)(1) entailed
subject matter as well as personal jurisdiction, the rule would
never provide a means for federal courts to obtain jurisdiction
over matters under exclusive federal jurisdiction. Because the two
subparts of Rule 4(k) must be read in pari materia, this logical
extension of the government's argument demonstrates its fatuity.
The advisory committee's explanation of the rationale
behind the adoption of Rule 4(k)(2) cinches matters. The drafters
created this proviso to deal with a gap in personal jurisdiction
noted by the Supreme Court in Omni Capital Int'l, Ltd. v. Rudolf
Wolff & Co., 484 U.S. 97, 111 (1987). Before Rule 4(k)(2) was
conceived, federal courts "borrowed" from state law when a federal
statute did not otherwise provide a mechanism for service of
process (regardless of the state courts' subject matter
jurisdiction). Accordingly, foreign defendants who lacked single-
state contacts sufficient to bring them within the reach of a given
state's long-arm statute (whether by reason of the paucity of the
contacts or of limitations built into the statute itself), but who
had enough contacts with the United States as a whole to make
personal jurisdiction over them in a United States court
constitutional, could evade responsibility for civil violations of
federal laws that did not provide specifically for service of
process. See id.; see also former Fed. R. Civ. P. 4(e) (superseded
by the 1993 Amendments), quoted in Omni Capital, 484 U.S. at 105
n.8.
To close this loophole, the drafters designed the new
Rule 4(k)(2) to function as a species of federal long-arm statute.
See Fed. R. Civ. P. 4 advisory committee note. The rule's final
clause, restricting its application to those cases in which the
putative defendant "is not subject to the jurisdiction of the
courts of general jurisdiction of any state" works to cabin the
rule's sweep and ensure its application only in the relatively
narrow range of cases identified by the Omni Court (in which the
states' personal jurisdiction rules prove impuissant). The
government's self-serving interpretation of the term
"jurisdiction," as used here, would extend the rule's scope well
beyond its intended purpose and, in the bargain, would allow
plaintiffs with claims falling within exclusive federal
jurisdiction statutes complete discretion to forum-shop without any
regard for concentrated contacts. Apart from a linguistic fortuity
the word "jurisdiction" is protean and has a wide variety of
meanings, depending on the context in which it is used there is
nothing to endorse so expansive a construction of Rule 4(k)(2). We
hold, therefore, that the absence of state court subject matter
jurisdiction does not enter into the negation equation.
The government's better argument is that its case falls
within the limits of Rule 4(k)(2) even when the rule is interpreted
as it must be to require negation of personal jurisdiction over
the defendant in any state court. The defendants' rejoinder is
that, while the government alleged in its complaint that Rule
4(k)(2) supplied the necessary means for obtaining personal
jurisdiction, it failed to plead or prove facts demonstrating the
absence of personal jurisdiction over the defendants throughout the
fifty states. This thrust and parry raises an issue of first
impression concerning the order and allocation of proof in respect
to Rule 4(k)(2)'s negation requirement, for no appellate court has
offered a clear resolution of that problem. In a world of
exponential growth in international transactions, the practical
importance of this issue looms large.
The defendants (and the district court) certainly are
correct in their insistence that a plaintiff ordinarily must
shoulder the burden of proving personal jurisdiction over the
defendant. See Foster-Miller, 46 F.3d at 145; 5A Wright & Miller,
supra,  1351. Some district courts, relying on this shibboleth,
have assigned outright to plaintiffs the burden of proving the Rule
4(k)(2) negation requirement. See, e.g., United States v. Offshore
Marine Ltd., 179 F.R.D. 156, 160 (D.V.I. 1998); Dorian v. Harich
Tahoe Dev., No. C-94-3387, 1997 WL 626109, at *2, *5 (N.D. Cal.
Oct. 11, 1997); CFMT, 1997 WL 313161, at *7-*8. This paradigm in
effect requires a plaintiff to prove a negative fifty times over
an epistemological quandary which is compounded by the fact that
the defendant typically controls much of the information needed to
determine the existence and/or magnitude of its contacts with any
given jurisdiction. There is a corresponding problem with
assigning the burden of proof on the Rule 4(k)(2) negation
requirement to defendants: doing so threatens to place a defendant
in a "Catch-22" situation, forcing it to choose between conceding
its potential amenability to suit in federal court (by denying that
any state court has jurisdiction over it) or conceding its
potential amenability to suit in some identified state court. See
Dora A. Corby, Comment, Putting Personal Jurisdiction Within Reach:
Just What Has Rule 4(k)(2) Done for the Personal Jurisdiction of
Federal Courts?, 30 McGeorge L. Rev. 167, 196 (1998).
Faced with such dilemmas, courts historically have
tailored special burden-of-proof regimes for specific classes of
cases in order to strike an equitable balance. Cf., e.g.,
McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-05 (1973). We
believe that Rule 4(k)(2) is fertile territory for such an
innovation. The architects of the rule and Congress, by adopting
it clearly intended to close the gap identified by the Omni Court
and to ensure that persons whose contacts with this country
exceeded the constitutional minimum could not easily evade civil
liability in the American justice system. At the same time,
however, the drafters also wrote the rule to preserve the
established modalities for obtaining personal jurisdiction
previously available under Rule 4(k)(1)(A) as the primary avenue to
service on foreign defendants. The desire to achieve this
secondary purpose led the authors of the rule to restrict its reach
to those defendants with sufficient nationwide contacts to subject
them to federal jurisdiction, but whose contacts were too exiguous
to permit any state court to exercise personal jurisdiction over
them. Viewed in this light, the application of traditional burden-
of-proof principles to Rule 4(k)(2) cases not only would be
inequitable, but also would shield foreign defendants who were
constitutionally within the reach of federal courts from the
exercise of personal jurisdiction, and, thus, thwart the core
purpose that underlies the rule.
In our view, this core purpose can be achieved much more
salubriously by crafting a special burden-shifting framework. To
accomplish the desired end without placing the judicial thumb too
heavily on the scale, we will not assign the burden of proof on the
negation issue to either party in a monolithic fashion. We prefer
instead to draw upon the burden-shifting arrangement devised by the
Court to cope with somewhat analogous problems of proof in the
discrimination context. See, e.g., St. Mary's Honor Ctr. v. Hicks,
509 U.S. 502, 506 (1993); Texas Dep't of Community Affairs v.
Burdine, 450 U.S. 248, 252-56 (1981); McDonnell Douglas, 411 U.S.
at 802-05. We etch the contours of this proposed standard in
detail below.
We hold that a plaintiff who seeks to invoke Rule 4(k)(2)
must make a prima facie case for the applicability of the rule.
This includes a tripartite showing (1) that the claim asserted
arises under federal law, (2) that personal jurisdiction is not
available under any situation-specific federal statute, and (3)
that the putative defendant's contacts with the nation as a whole
suffice to satisfy the applicable constitutional requirements. The
plaintiff, moreover, must certify that, based on the information
that is readily available to the plaintiff and his counsel, the
defendant is not subject to suit in the courts of general
jurisdiction of any state. If the plaintiff makes out his prima
facie case, the burden shifts to the defendant to produce evidence
which, if credited, would show either that one or more specific
states exist in which it would be subject to suit or that its
contacts with the United States are constitutionally insufficient.
See generally Stephen B. Burbank, The United States' Approach to
International Civil Litigation: Recent Developments in Forum
Selection, 19 U. Pa. J. Int'l Econ. L. 1, 13 (1998) (suggesting a
broad outline for a similar burden-shifting regime vis-