Specific Personal Jurisdiction in light of Bristol Myers Squibb – The Supreme Court held in Bristol Myers Squibb v. Superior Court, 137 S. Ct. 1773 (2017) that a California state court did not have specific jurisdiction over nonresidents' claims in a mass tort action because the defendant corporation did not have sufficient minimum contacts with California and nonresidents were not injured in California. The case, however, left open ended the question of whether the holding applies to class actions in federal court. Courts of Appeal in the Fifth, Seventh, and D.C. Circuits have concluded that Bristol Myers Squibb does not apply to class actions in federal court. Therefore, nonresident class members need not establish personal jurisdiction at the pleading stage. Mussat v. IQVIA, Inc ., 953 F.3d 441 (7th Cir. 2020) (noting absent class members "are not considered parties" at the pleading stage); Molock v.