Every state has a law called a long-arm statute which details under what circumstances a court in that state may assert jurisdiction over an out-of-state defendant. Typically a long-arm statute will grant a court jurisdiction over a non- resident if the non-resident has minimum contacts within the court's jurisdiction. In International Shoe Co. v. Washington, 326 U.S. 310 (1945), the Supreme Court held that for a defendant to have minimum contacts, the defendant needs some combination of the two following factors: (1) systematic and continuous activity within the forum jurisdiction; and (2) a cause of action arising from that activity Given the test in International Shoe, do Clean's activities meet the requirements for minimum contacts