With no explanation, chose the best option from "A", "B", "C" or "D". and Kee-ton to find that a Texas court could properly exercise personal jurisdiction over a non-resident defendant in a defamation case for the distribution of allegedly defamatory printed material in Texas and elsewhere. Paul Gillrie Inst., Inc. v. Universal Computer Consulting, Ltd., 183 S.W.3d 755, 761 (Tex.App.-Houston [1st Dist.] 2005, no pet.). In that case, the Paul Gillrie Institute allegedly defamed a corporation with its headquarters and principal place of business in Texas and mailed the trade publication containing the article to subscribers across the country, including approximately fifty subscribers in Texas, some of whom were customers of the corporation. Id. at 760-61. I would hold that this case is similar to Calder a 875 (Tex.App.Houston [14th Dist.] 2004, no pet.) (<HOLDING>). Wilkerson argues that he did not purposefully

A: holding that postincident conduct does not establish the purposeful availment necessary to exercise personal jurisdiction
B: recognizing that the mere operation of a commercially interactive website is not by itself an adequate basis for the exercise of personal jurisdiction anywhere the site can be viewed
C: holding that a trial courts decision on whether to exercise jurisdiction in a proceeding under the uniform child custody and jurisdiction enforcement act is reviewed for an abuse of discretion
D: holding that single substantial act can support exercise of personal jurisdiction
D.