On June 27, 2011, the Supreme Court of the United States decided two personal jurisdiction cases: Goodyear Dunlop Tires Operations, S.A. v. Brown, No. 10-76, and J. McIntyre Machinery, Ltd. v. Nicastro, No. 09-1343. In Goodyear Dunlop Tires, the Supreme Court addressed whether a state court can exercise general jurisdiction over a foreign defendant—i.e., a defendant outside the forum state—for the introduction of goods into the stream of commerce. And in J. McIntyre Machinery, the Supreme Court addressed the circumstances under which a state court can exercise specific jurisdiction over a foreign defendant—for an injury that occurred in the state—based on goods merely introduced into the stream of commerce. In both cases, the Supreme Court limited the ability of state courts to assert personal jurisdiction over foreign defendants.