This Note discusses the evolution of the stream of commerce theory. First, it discusses the origin of the theory and the early split amongst state courts. Next, it discusses the modern Supreme Court jurisprudence on the issue, including the plurality decision on Asahi Metal Industry Co. v. Superior Court of California. Finally, this not discusses the evolution of the theory in the Eighth Circuit and argues that, while the case law is inconsistent, the results are equitable.

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