With no explanation, chose the best option from "A", "B", "C" or "D". continuous and systematic WEDGE Group, Inc., 882 F.2d 1087, 1089-90 (6th Cir.1989) (noting that the defendant’s contacts were not sufficient to maintain general jurisdiction since the defendant never directly conducted- business, held title to property, or retained employees in the forum state). In short, the district court erred in concluding that the exercise of general personal jurisdiction was proper. B. Specific Personal Jurisdiction The exercise of specific jurisdiction is proper where the claims in the case arise f , 619 F.2d 676, 678 n. 10 (7th Cir.1980) (noting that courts have declined to find specific jurisdiction when the defendant’s contact with the forum state is limited to an attempt to resolve the parties’ dispute); cf. Neal v. Janssen, 270 F.3d 328, 332 (6th Cir.2001) (<HOLDING>); American Greetings Corp. v. Cohn, 839 F.2d

A: holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction
B: recognizing a tort for the intentional spoliation of evidence
C: recognizing that where plaintiff is from the forum state and defendant is from an alternate forum each forum can claim a connection to one of the parties
D: holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort
D.