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TrailBright LLC is organized and headquartered in State A. It sells hiking headlamps through its website. TrailBright buys search ads that appear only to users located in State B, runs a "State B winter trail" promotion, ships about 6,000 headlamps a year to State B customers, and maintains a State B toll-free customer-service number routed to its State A office.
Paula, a State B resident, bought a TrailBright headlamp through the website while at home in State B. TrailBright shipped the headlamp to Paula in State B. The headlamp overheated during a State B camping trip and burned Paula. Paula sues TrailBright in federal district court in State B on state-law product-liability claims. State B's long-arm statute reaches as far as due process permits. TrailBright moves to dismiss for lack of personal jurisdiction, arguing that it has no office, employees, bank account, or property in State B.
Should the federal court in State B exercise personal jurisdiction over TrailBright? Discuss.