Ash v. Burnham Corp.

How later courts describe this case

• finding that contacts including advertising in national magazines, small sales solicited by independent sales representatives within the forum, and the ownership of a subsidiary in North Carolina were insufficient to support general jurisdiction
• where “subsidiary’s presence in [N.C.] is primarily for ... its own business and the subsidiary has preserved some semblance of independence from [defendant], jurisdiction over [defendant] may not be acquired on the basis of the local activities of the subsidiary”