In December, 2016, NBF attorneys Chris Nicoll and Noah Jaffe prepared and filed two amicus curiae briefs with the Washington Supreme Court on behalf of the Washington Defense Trial Lawyers Association. The first was filed in Noll v. Special Electric Co., No. 91998-4, and concerns the proper test for specific personal jurisdiction in a case involving a manufacturer of a component product that was marketed in Washington by the manufacturer of the end product. The case focuses on whether a component part manufacturer can be subject to jurisdiction in a state where its product ended up even if the component manufacturer was unaware that the end product manufacturer was marketing the product in the forum state. Chris and Noah teamed up again to author and file an amicus brief for the Washington Defense Trial Lawyers Association in Swank v. Valley Christian School, No. 90733-1, analyzing in detail the case against exercising specific personal jurisdiction over an Idaho doctor sued in Washington for care he rendered to an Idaho patient in Idaho, but who later traveled to Washington where he was injured and died. Both cases provided NBF with an opportunity to add to the debate about specific personal jurisdiction that has been reignited by recent decisions of the United States Supreme Court.