With no explanation, chose the best option from "A", "B", "C" or "D". v. Verizon Commc’ns, Inc., 478 F.3d 19, 24 (1st Cir.2007). B. Specific Jurisdiction “A court may assert specific jurisdiction over an out-of-state defendant “where the cause of action arises directly out of, or relates to, the defendant’s forum-based contacts.’ ” Negron-Torres, 478 F.3d at 24 (quoting United Elec., Radio and Mach. Workers of Am. v. 163 Pleasant St. Corp., 960 F.2d 1080, 1088-89 (1st Cir. 1992)). The First Circuit has affirmed that “the relatedness requirement is not an open door; it is closely read, and it requires a showing of a material connection. This court steadfastly rejects the exercise of personal jurisdiction whenever the connection between the cause of action and the defendant’s forum-state contacts seems attenuated and indirect.” Harlow, 432 F.3d at 61 (<HOLDING>) (internal citations and quotation marks

A: holding that convictions under  111 require at least some form of assault
B: holding that defendant who conclusively negates at least one essential element of plaintiffs cause of action entitled to summary judgment
C: holding misrepresentation must at least be partial cause of plaintiffs injury
D: holding that the defendants instate conduct must form an important or at least material element of proof in the plaintiffs case
D.