The 'minimum contacts' test is used by courts to determine whether they have personal jurisdiction over an out-of-state defendant. Established in the landmark case International Shoe Co. v. Washington, the test holds that for a court to exercise power over a non-resident, the defendant must have sufficient ties to the state such that the lawsuit does not offend 'traditional notions of fair play and substantial justice.' Contacts are evaluated based on their quality and nature. If a company purposefully avails itself of the benefits of a state—such as by advertising there, shipping products to its residents, or maintaining an office—it is generally fair to subject that company to the state's courts. However, if a defendant's contact with a state is merely accidental or isolated, the court likely lacks jurisdiction. The rise of internet commerce has complicated this, with courts debating whether simply having a passive website accessible in a state constitutes a 'minimum contact.'