Herbal sued defendant for Lanham Act violations, an intentional tort.  Accordingly, the court applied the Calder effects test to determine whether Arizona could assert personal jurisdiction over the defendant.  Defendants purposefully directed their tortious activities toward Arizona by selling to Arizona residents on an interactive website.  The alleged harm arose from those sales, among others.  And Herbal’s pre-suit cease-and-desist letters told defendant it was causing harm in Arizona.  It was reasonable under the circumstances for Arizona to assert personal jurisdiction over the defendant.