Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111 (1st Cir. 1997). · Go Syfert
Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111 (1st Cir. 1997). Cases Citing This Book View Copy Cite
164 citation events (156 in the last 25 years) across 10 distinct courts.
Strongest positive: Robert A. Doane v. Python Leads, LLC, Jacquelyn Leah Levine, and Ali Raza (mad, 2025-12-04) · Strongest negative: The Scuderi Group, LLC v. Lgd Technology, LLC (mad, 2008-09-09)
Treatment trajectory · 1998 → 2026 · click a year to view as-of
1998 2012 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited "but see" The Scuderi Group, LLC v. Lgd Technology, LLC
D. Mass. · 2008 · signal: but see · confidence high
But see Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 113 (1st Cir.1997) (suggesting that where the contacts are sparse, they must have been instrumental (not incidental) in the formation of the contract in dispute).
discussed Cited as authority (rule) Robert A. Doane v. Python Leads, LLC, Jacquelyn Leah Levine, and Ali Raza
D. Mass. · 2025 · confidence medium
The statute must “be generously construed in favor of asserting personal jurisdiction,” with the court applying a but-for causation inquiry that asks whether “the defendant’s contacts with the Commonwealth constitute[d] ‘the first step in a train of events that result[ed] in the personal injury.’” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997) (quoting Tatro v. Manor Care, Inc., 416 Mass. 763, 770 (1994)); accord Doucet v. FCA US LLC, 492 Mass. 204, 207-10 (2023).
cited Cited as authority (rule) Greenspan v. MasMarques
D. Mass. · 2024 · confidence medium
Ashworth, Inc., 132 F.3d 111, 113 (1st Cir. 1997).
cited Cited as authority (rule) Sheldon v. DT Swiss AG
D. Mass. · 2023 · confidence medium
Mass. Jan. 14, 2019) (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
cited Cited as authority (rule) Salem Shift LLC v. Buffalo Pedal Tours, LLC
D. Mass. · 2023 · confidence medium
Mass. 2017) (alteration in original) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
discussed Cited as authority (rule) Frawley v. Nexstar Media Group, Inc. (2×) also: Cited "see"
D. Mass. · 2023 · confidence medium
Eventually, the question becomes a “but for” causation test which asks “[d]id the defendant's contacts with the Commonwealth constitute ‘the first step in a train of events that result[ed] in the personal injury.’” Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997) (quoting Tatro, 625 N.E.2d at 553 ).
discussed Cited as authority (rule) Reagent Fund II, LP v. Lotus Gunworks of South Florida, LLC
D. Mass. · 2023 · confidence medium
However, this may only be in instances wherein the Defendant’s contacts with Massachusetts are “instrumental (not incidental) in the formation of the contract in dispute.” Id. at 111 (citing Lyle Richards, Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 113 (1st Cir. 1997)).
cited Cited as authority (rule) Atlantic Specialty Insurance Company v. MCMC, LLC
D. Mass. · 2022 · confidence medium
Mass. 2017) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
discussed Cited as authority (rule) Stag Williamsport, LLC v. BHN ASSOCIATES, LLC
D. Mass. · 2022 · confidence medium
As utilized in M.G.L. c. 223A, § 3, the term “transacting” is construed broadly and employed “to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party[.]” Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997) (citation omitted).
discussed Cited as authority (rule) Nasuni Corporation v. ownCloud GMBH
D. Mass. · 2022 · confidence medium
The term “transacting” as utilized therein is construed broadly and employed “to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party[.]” Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997) (citation omitted).
discussed Cited as authority (rule) Lopez v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
“Accordingly, this Court may only exercise personal jurisdiction within the limits set by Massachusetts’ long-arm statute and the due process clause of the Constitution.” Kingston, 2021 WL 3022320 , at *5 (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
discussed Cited as authority (rule) Mora v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
“Accordingly, this Court may only exercise personal jurisdiction within the limits set by Massachusetts’ long-arm statute and the due process clause of the Constitution.” Kingston, 2021 WL 3022320 , at *5 (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
cited Cited as authority (rule) Walters v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
Mass. July 16, 2021) (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
discussed Cited as authority (rule) Restuccia v. H&R Block Tax Services LLC (2×) also: Cited "see"
D. Mass. · 2021 · confidence medium
Mass. July 16, 2021) (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
cited Cited as authority (rule) Harness v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
Mass. July 16, 2021) (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
discussed Cited as authority (rule) Pettit v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
“Accordingly, this Court may only exercise personal jurisdiction within the limits set by Massachusetts’ long-arm statute and the due process clause of the Constitution.” Kingston, 2021 WL 3022320 , at *5 (citing Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
discussed Cited as authority (rule) Jane Doe 1 v. Jetblue Airways Corporation
D. Mass. · 2021 · confidence medium
Although “transacting business” “has been construed broadly,” Tatro v. Manor Care, Inc., 625 N.E.2d 549, 551 (Mass. 1994) (citations omitted), the test “is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party,” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
discussed Cited as authority (rule) Jane Doe 1 v. Jetblue Airways Corporation
D.P.R. · 2021 · confidence medium
Although “transacting business” “has been construed broadly,” Tatro v. Manor Care, Inc., 625 N.E.2d 549, 551 (Mass. 1994) (citations omitted), the test “is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party,” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997)).
cited Cited as authority (rule) Kingston v. AngioDynamics, Inc.
D. Mass. · 2021 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) KPM Analytics North America Corporation v. Blue Sun Scientific, LLC
D. Mass. · 2021 · confidence medium
Mass. 2002) (“[T]he First Circuit Court of Appeals has ‘assume[d], without deciding, that a Chapter 93A violation would constitute a tortious injury under [subsection (c)].’”) (quoting Lyle Richards Int'l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir.1997))).
cited Cited as authority (rule) Avanti EOS Holdings, LLC v. EOS Petro, Inc.
D. Mass. · 2021 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
cited Cited as authority (rule) Michaud v. Solomon
D. Mass. · 2021 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) Clinton-Brown v. Hardick
D. Mass. · 2021 · confidence medium
See Gunner, 24 Mass. App. Ct. at 99 ; Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997) (non-resident’s contacts with forum state must be deliberate, not merely fortuitous).
discussed Cited as authority (rule) Clinton-Brown v. Hardick
D.R.I. · 2021 · confidence medium
See Gunner, 24 Mass. App. Ct. at 99 ; Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997) (non-resident’s contacts with forum state must be deliberate, not merely fortuitous).
discussed Cited as authority (rule) Ericson v. Conagra Foods, Inc.
D. Mass. · 2020 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997). interests of a thorough record, it will nevertheless analyze whether exercising personal jurisdiction over Defendants would be constitutionally permissible.
discussed Cited as authority (rule) Collision Communications, Inc. v. Nokia Corporation
D. Mass. · 2020 · confidence medium
The “‘transacting [any] business’ test under section 3(a) is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party.” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) Collision Communications, Inc. v. Nokia Corporation
D. Mass. · 2020 · confidence medium
The “‘transacting [any] business’ test under section 3(a) is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party.” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
cited Cited as authority (rule) Lifchits v. Key 4U Transporation Corp. Bus
E.D.N.Y · 2020 · confidence medium
Mass. 2017) (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). 1.
cited Cited as authority (rule) Lifchits v. Integon National Insurance Co.
D. Mass. · 2020 · confidence medium
Mass. 2017) (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). 1.
discussed Cited as authority (rule) JLB LLC v. Christian R. Egger
D. Mass. · 2020 · confidence medium
The arising from inquiry asks “[d]id the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the . . . injury.” Id. (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). “[T]he defendant’s involvement need not be major, as ‘just a few acts on [his] part can often suffice to satisfy [subsection (a)]’s threshold for transacting business.’” Scuderi Grp., LLC v. LGD Tech., LLC, 575 F. Supp. 2d 312, 319 (D.
cited Cited as authority (rule) Tomas v. Buckley
D. Mass. · 2020 · confidence medium
Mass. 2017) (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
discussed Cited as authority (rule) Brown v. Papa's Dodge, Inc. (2×) also: Cited "see"
D. Mass. · 2020 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
cited Cited as authority (rule) O'Grady v. Safety-Kleen Systems, Inc.
D. Mass. · 2020 · confidence medium
Mass. 2017) (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
cited Cited as authority (rule) CRG Financial, LLC v. Two Diamond Capital Corp
D. Mass. · 2020 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) HealthEdge Software, Inc. v. Sharp Health Plan
D. Mass. · 2020 · confidence medium
The inquiry asks only whether “the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the [relevant] injury.” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997) (first alteration in original) (quoting Tatro, 625 N.E.2d at 553 ). “[A] claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Access Now, Inc. v. Otter Prods., LLC, 280 F. Supp. 3d 287, 291 (D.
discussed Cited as authority (rule) Doucet v. FCA US LLC
D. Mass. · 2020 · confidence medium
The inquiry asks only whether “the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the [relevant] injury.” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997). “[A] claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Access Now, Inc. v. Otter Prods., LLC, 280 F. Supp. 3d 287, 291 (D.
cited Cited as authority (rule) Lin v. TipRanks, Ltd.
D. Mass. · 2019 · confidence medium
Mass. 2017) (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
discussed Cited as authority (rule) Nandjou v. Marriott International Inc.
D. Mass. · 2019 · confidence medium
The arising from inquiry asks “[d]id the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the . . . injury.” Id. (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). “[T]he defendant’s involvement need not be major, as ‘just a few acts on [his] part can often suffice to satisfy [subsection (a)]’s threshold for transacting business.’” Scuderi Grp., LLC v. LGD Tech., LLC, 575 F. Supp. 2d 312, 319 (D.
discussed Cited as authority (rule) Conning v. Halpern
D. Mass. · 2019 · confidence medium
The arising from inquiry asks “[d]id the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the . . . injury.” Id. (quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). “[T]he defendant’s involvement need not be major, as ‘just a few acts on [his] part can often suffice to satisfy [subsection 3(a)]’s threshold for transacting business.’” Scuderi Grp., LLC v. LGD Tech., LLC, 575 F. Supp. 2d 312, 319 (D.
cited Cited as authority (rule) Krua v. Sirleaf
D. Mass. · 2019 · confidence medium
Lyle Richards Intl, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) Nandjou v. Marriott International Inc.
D. Mass. · 2019 · confidence medium
The arising from inquiry asks “[d]id the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the . . . injury.” Id. (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)). “[T]he defendant’s involvement need not be major, as ‘just a few acts on [his] part can often suffice to satisfy [subsection (a)]’s threshold for transacting business.’” Scuderi Grp., LLC v. LGD Tech., LLC, 575 F. Supp. 2d 312, 319 (D.
cited Cited as authority (rule) Lewis v. Walt Disney Parks & Resorts U.S., Inc.
D. Mass. · 2019 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) Packs v. Bartle
D. Mass. · 2019 · confidence medium
The arising from inquiry asks “did the defendant’s contacts with the Commonwealth constitute the first step in a train of events that result[ed] in the . . . injury.” Id. (internal quotation marks omitted) (quoting Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997)).
discussed Cited as authority (rule) Filmore v. VSP North America LLC
D. Mass. · 2019 · confidence medium
While chapter 223A, § 3(a), has been interpreted broadly, the “‘transacting business’ test . . . is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party.” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir. 1997).
discussed Cited as authority (rule) Lyndon v. Nestle Waters North America, Inc.
D. Mass. · 2018 · confidence medium
The “arising from” inquiry ultimately boils down to a “but for” causation test, which asks whether “the defendant’s contacts with the Commonwealth constitute[d] ‘the first step in a train of events that result[ed] in the personal injury.’” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997) (quoting Tatro v. Manor Care, Inc., 625 N.E.2d 549, 553 (Mass. 1994)).
discussed Cited as authority (rule) Roy v. FedEx Ground Package Systems, Inc.
D. Mass. · 2018 · confidence medium
“The ‘transacting business’ test under section 3(a) is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party, see, e.g., Good Hope Indus., 389 N.E.2d at 82 , with a view to determining whether ‘“the possible need to invoke the benefits and protections of the forum’s laws was reasonably foreseeable . . . .”’” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112-13 (1st Cir. 1997) (alteration in original) (quoting Good Hope Indus., 389 N.E.2d at 82 )).
discussed Cited as authority (rule) Access Now, Inc. v. Otter Products, LLC
D. Mass. · 2017 · confidence medium
The inquiry ultimately boils down to a “but for” causation test which asks “[d]id the defendant’s contacts with the Commonwealth constitute ‘the first step in a train , of events that .resulted] in the personal injury.’ ” Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir. 1997) (quoting Tatro, 625 N.E.2d at 553 ).
cited Cited as authority (rule) American Paper Recycling, Inc. v. Renew Bahamas, Ltd.
Mass. Super. Ct. · 2016 · confidence medium
See Tatro v. Manor Care, Inc., 416 Mass. at 767 ; Lyle Richards Int’l Ltd. v. Ashworth, Inc., 132 F.3d 111, 113 (1st Cir. 1997).
discussed Cited as authority (rule) Cioffi v. Gilbert Enterprises, Inc.
D. Mass. · 2012 · confidence medium
The First Circuit has stated that the relatedness inquiry should be evaluated by applying a “but for” causation test — in other words, by asking whether the defendant’s contacts with the Commonwealth constituted “the first step in a train of events that resulted in personal injury.” Lyle Richards International, Ltd. v. Ashworth, Inc., 132 F.3d 111, 114 (1st Cir.1997).
cited Cited as authority (rule) Optos, Inc. v. TOPCON MEDICAL SYSTEMS, INC.
D. Mass. · 2011 · confidence medium
Lyle Richards Int’l, Ltd. v. Ashworth, Inc., 132 F.3d 111, 112 (1st Cir.1997).
Retrieving the full opinion text from the archive…
LYLE RICHARDS INTERNATIONAL, LTD., Plaintiff, Appellant,
v.
ASHWORTH, INC., Defendant, Appellee
97-1387.
Court of Appeals for the First Circuit.
Dec 22, 1997.
132 F.3d 111
Miehael J. Traft, Boston, MA, with whom Carney & Bassil was on brief for appellant., Toni G. Wolfman, Boston, MA, with whom Foley, Hoag & Eliot LLP was on brief for appellee.
Stahl, Godbold, Cyr.
Cited by 86 opinions  |  Published
Pinpoint authority: bottom 55%
[*112] CYR, Senior Circuit Judge.

Plaintiff Lyle Richards International, Ltd., a Massachusetts corporation, appeals from a district court judgment dismissing its contract action against Ashworth, Inc., a Delaware corporation with its principal place of business in California. We affirm.

I

BACKGROUND

In March 1994, Ashworth hired a former Lyle employee, Andrew Tarlow, to direct its new golf shoewear operations in California. Shortly thereafter, without direct or indirect solicitation from Ashworth, Lyle made overtures, through Tarlow, to serve as Ash-worth’s purchasing agent. Over the next two months, Lyle and Ashworth discussed the matter by phone and at meetings in California and China. At no time did Ashworth advertise for or solicit a purchasing agent in Massachusetts. .

Not later than July 1994, Ashworth, through Tarlow, proposed entering into a formal written agreement with Lyle. In due course, the Agreement, drafted and signed by Lyle in Massachusetts, was mailed to California, where Ashworth executed it on August 5. The Agreement designated Lyle as Ashworth’s purchasing agent for footwear manufactured in China and Taiwan, but required Ashworth to undertake no specific contractual responsibilities in Massachusetts.

Thereafter, Ashworth periodically forwarded purchase orders to Lyle in Massachusetts, which Lyle transmitted to the appropriate Chinese or Taiwanese factory. Ashworth communicated with Lyle in Massachusetts two or three times a week regarding ongoing contract performance, and from time to time placed orders with shoe-component suppliers which were instructed to bill Lyle directly. In addition, during the term of the Agreement an Ashworth representative attended three trade shows in Massachusetts, accompanied on two occasions by a Lyle employee.

The Agreement prescribed a one-year term. Absent written notice of termination from either party at least ninety days prior to its anniversary date, the Agreement renewed itself automatically. In August 1995, Ashworth provided written notice of termination to Lyle, dated April 19,1995.

Thereafter, Lyle filed suit against Ash-worth in a Massachusetts superior court, alleging breach of contract and unfair trade practices under Mass. Gen. Laws ch. 93A, §§ 2,11, claiming that the termination notice had been back-dated to April 1995 to conceal its untimeliness under the Agreement. Following its removal, see 28 U.S.C. §§ 1332(a) & 1441(a), and a nonevidentiary hearing, the action was dismissed for lack of personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2).

II

DISCUSSION [1]

A. The Breach of Contract Claim

In a diversity case, personal jurisdiction over a nonresident defendant is constrained both by the long-arm statute of the forum state and the Due Process Clause of the Fourteenth Amendment. . See Ticketmaster-New York, Inc. v. Alioto, 26 F.3d 201, 204 (1st Cir.1994). Massachusetts law permits Commonwealth courts to assert jurisdiction “over a person, who acts directly or by an agent, as to a cause of action in law or equity arising from the person’s ... transacting any business in this commonwealth _” Mass. Gen. Laws ch. 228A, § 3(a) (emphasis added).

The “transacting business” test under section 3(a) is designed to identify deliberate, as distinguished from fortuitous, contacts with the forum by the nonresident party, see, e.g., Good Hope Indus., Inc. v. Ryder Scott Co., 378 Mass. 1, 389 N.E.2d 76, 82 (1979), with a view to determining whether “ ‘the[*113] possible need to invoké the benefits and protections of the forum’s laws was reasonably foreseeable_Id. (quoting Product Promotions, Inc. v. Cousteau, 495 F.2d 483, 496 (5th Cir.1974)). Often, the “transacting business” test is importantly informed by ascertaining whether the nonresident party initiated or solicited the business transaction in Massachusetts. For instance, the Massachusetts Supreme Judicial Court (“SJC”) has held that a California corporation transacted business in Massachusetts by systematically advertising its California hotel in Massachusetts. See Tatro v. Manor Care, Inc., 416 Mass. 763, 625 N.E.2d 549, 551-52 (1994); see also Hahn v. Vermont Law Sch., 698 F.2d 48, 51 (1st Cir.1983) (nonresident law school transacted business by sending application for admission and notice of acceptance to plaintiff in Massachusetts); New Hampshire Ins. Guar. Ass’n v. Markem Corp., 424 Mass. 344, 676 N.E.2d 809, 812-13 (1997) (nonresident insured did not transact business by mailing premium payments to Massachusetts, since Massachusetts-based insurer solicited insurance business in New Hampshire).

An Ashworth affidavit — attesting that Lyle had proposed, in March 1991, to serve as Ashworth’s purchasing agent — went unopposed by Lyle. Instead, Lyle relied upon the inapposite fact that it was Ashworth which suggested, during the summer of 199k, that the precise terms of the business relationship previously proposed by Lyle be reduced to writing.

Although any effect a nonresident defendant’s activity may have had upon commerce in Massachusetts is also to be considered in determining whether it transacted business in the Commonwealth, see Droukas v. Divers Training Academy, Inc., 375 Mass. 149, 376 N.E.2d 548, 551 n. 5 (1978), the purely incidental contacts involved here were insufficient to support an assertion of personal jurisdiction over Ashworth. See, e.g., Whittaker Corp. v. United Aircraft Corp., 482 F.2d 1079, 1085 (1st Cir.1973) (finding defendant’s contacts with Massachusetts insufficient, and thus no personal jurisdiction, where there was “no requirement in any of the agreements that performance take place in Massachusetts”) (emphasis added); New Hampshire Ins. Guar. Ass’n v. Markem Corp., 424 Mass. 344, 676 N.E.2d 809, 812 (1997) (“That [plaintiff] then decided to conduct some administration ... in Massachusetts ... cannot be the basis for personal jurisdiction against [defendant] where [defendant] reasonably assumed it would be doing business with [plaintiff] in New Hampshire and did in fact conduct most of its business ... there.”) (emphasis added). See also Nichols Assocs., Inc. v. Starr, 4 Mass.App. Ct. 93, 341 N.E.2d 909, 912 (1976) (no significant involvement in commerce of Massachusetts, and thus no personal jurisdiction, where nonresident defendant’s “contact [was] limited to the ... acceptance of services which the plaintiff simply chose to perform in Massachusetts.”) (emphasis added).

For one thing, most performance required from Lyle under the Agreement was to be rendered outside Massachusetts. The Agreement did not even require that the internal administrative functions actually conducted by Lyle in Massachusetts be performed there, such as arranging for merchandise shipments from the Chinese-Taiwanese suppliers to Ashworth in California, receiving price quotes or product samples from the Asian factories, or reporting to Ashworth on market conditions and the availability of merchandise.

Nor does the Agreement indicate that Lyle either needed or intended to perform its “quality control” responsibilities in Massachusetts. Rather, most of its core contractual responsibilities relating to the inspection of merchandise would have had to have been performed in China or Taiwan, rather than Massachusetts. Thus, its performance of various attendant chores in Massachusetts was incidental to the formation of the Agreement. See Nichols Assocs., Inc., 341 N.E.2d at 912. [2]

[*114] Finally, Lyle notes, Ashworth attended three trade shows in Massachusetts, accompanied by a Lyle employee on at least two occasions, and Lyle performed two contract functions in Massachusetts: designing golf shoes and purchasing various golf-shoe components and the materials with which to package them for shipment to Asia. Nevertheless, as these initiatives were undertaken unilaterally by the respective parties, even though neither was responsible for their performance under the Agreement, this attempt to assert personal jurisdiction over Ashworth is unavailing since chapter 223A requires that the cause of action have “aris[enj from [Ashworth’s ] ... transacting any business in [Massachusetts]-” Mass. Gen. Laws ch. 223A, § 3(a) (emphasis added). We explain briefly.

The “arising from” clause in chapter 223A is to be generously construed in favor of asserting personal jurisdiction, by applying the following “but for” causation test: Did the defendant’s contacts with the Commonwealth constitute “the first step in a train of events that resulted] in the personal injury.” Tatro, 625 N.E.2d at 553. The plaintiff in Tatro almost certainly would not have selected the defendant’s California hotel but for the advertisements the defendant had placed in various Massachusetts media. Lyle, on the other-hand, does not contend that component purchases, shoe design, or attendance at trade shows comprised any part of the responsibilities of either party under the Agreement.

Since the extra-contractual- activities unilaterally undertaken by the respective parties in Massachusetts were extraneous to the formation of the Agreement, see Hahn v. Vermont Law Sch., 698 F.2d 48, 51 (1st Cir.1983) (holding, pre-Tatro: “we have no doubt that [the ‘arising from’ requirement] has been satisfied when the cause of action is for an alleged breach of contract and the business transacted was instrumental in the formation of the contract.”) (emphasis added), those activities did not constitute a “but for” cause for the alleged breach of contract, see Tatro, 625 N.E.2d at 553.

B. The Unfair Trade Practices Claim Under Chapter 93A

Finally, Lyle contends, since Chapter 223A grants jurisdiction over “a cause of action ... arising from [a defendant’s] ... causing tortious injury by an act or omission in [Massachusetts] ... [,]” Mass.' Gen. Laws ch. 223A, § 3(c), the federal district court possessed personal jurisdiction over Ash-worth in relation to the unfair trade practices claim under Mass. Gen. Laws ch. 93A. For present purposes we shall assume, without deciding, that a Chapter 93A violation would constitute a “tortious injury” under Chapter 223A. Cf. Burtner v. Burnham, 13 Mass.App.Ct. 158, 430 N.E.2d 1233, 1237 (1982) (“Whether a violation of ... chapter [93A] constitutes a ‘tortious injury’ within the meaning of c. 223A, § 3(c) may be open to some doubt.”).

Lyle alleges that Ashworth attempted to conceal the tardiness of its nonrenewal notice by backdating its untimely termination letter to Lyle, see supra p. 112, and that the alleged deception was designed to prevent Lyle from pursuing a contract action for wrongful termination of the Agreement. Assuming as much, we nonetheless conclude that Lyle cannot prevail on its Chapter 93A claim.

Chapter 93A, section 11, provides that “[a]ny person who engages in the conduct of any trade or commerce and who suffers any loss of money or property, real or personal, as a result of the use or employment by another person who engages in any trade or commerce of an unfair method of competition or an unfair or deceptive act or practice ... may ... bring an action in the superior court _” (emphasis added). .Thus, in order to state a chapter 93A claim, Lyle was required to demonstrate a loss of money or property. Yet it alleged no such loss. Instead, it asserted a breach of contract by virtue of Ash-worth’s failure to provide timely notice of[*115] termination as required by the Agreement. In addition, Lyle alleged that Ashworth violated chapter 93A by engaging in the deceptive act of backdating the notice of termination. As to the latter allegation, however, Lyle claimed no injury apart from that caused by the alleged breach of contract. Consequently, Lyle failed to allege a “loss of money or property ... as a result of [Ash-worth’s] use or employment ... of [a] ... deceptive act ... [,]” as required by chapter 93A, section 11. Finally, a breach-of-contract claim, without more, cannot be converted into a tort claim. See Redgrave v. Boston Symphony Orchestra, Inc., 557 F.Supp. 230, 238 (D.Mass.1983).

Affirmed.

1

. We review de novo. Nowak v. Tak How Invs., Ltd., 94 F.3d 708, 712 (1st Cir.1996), cert. denied, -U.S.-( 117 S.Ct. 1333, 137 L.Ed.2d 493 (1997). Since the district court resolved the jurisdictional issue without an evidentiary hearing, "we draw the facts from the pleadings and the parties' supplementary filings, including affidavits, taking facts affirmatively alleged by plaintiff as true and construing disputed facts in the light most hospitable to plaintiff[,]” but without crediting "conclusory allegations or draw[ing] farfetched inferences,” Ticketmaster-New York, Inc. v. Alioto, 26 F.3d 201, 203 (1st Cir.1994).

2

. The contention that Ashworth transacted business in Massachusetts by mailing its termination notice to Lyle in Massachusetts is flawed as well, since Ashworth cannot have solicited business by terminating the business relationship. Nor was the Agreement executed by Ashworth in Massachusetts, see Carlson Corp. v. University of Vermont, 380 Mass. 102, 402 N.E.2d 483, 485 (1980) (defendant transacted business in Massachusetts, where it signed the contract), but in California where it had been forwarded after having been executed by Lyle in Massachusetts, supra p. 112.