Phillips v. Prairie Eye Ctr., 530 F.3d 22 (1st Cir. 2008). · Go Syfert
Phillips v. Prairie Eye Ctr., 530 F.3d 22 (1st Cir. 2008). Cases Citing This Book View Copy Cite
Quick Summary

A defendant's mere awareness of a plaintiff's forum residence is insufficient to establish purposeful availment for specific personal jurisdiction.

An ophthalmologist residing in Massachusetts sued an Illinois medical practice for breach of fiduciary duty and contract after an employment negotiation failed. The plaintiff alleged that the defendant's emails to him in Massachusetts established specific personal jurisdiction. The court must determine whether the plaintiff has proffered evidence sufficient to support findings of all facts essential to personal jurisdiction. Although the defendant knew the plaintiff's location, the court held that mere awareness of a plaintiff's residence does not constitute purposeful availment. Because the defendant did not target the forum state and could not reasonably anticipate being haled into court there, the court affirmed the dismissal for lack of personal jurisdiction.

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cited 8× by 8 distinct cases, 2009–2023 · 2 courts↑ Rising · …reasonably anticipate being haled into court at p. 28 ✓ Topic ↗
cited 7× by 7 distinct cases, 2018–2023 · …rely on unsupported allegations in its pleadings. ⚠ not in text Topic ↗
557 citation events (557 in the last 25 years) across 22 distinct courts.
Strongest positive: John D. Hartz v. Brandon E. Lenart (med, 2026-02-10)
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discussed Cited as authority (verbatim quote) John D. Hartz v. Brandon E. Lenart
D. Me. · 2026 · signal: see also · quote attribution · 1 verbatim quote · confidence high
because the district court did not hold an evidentiary hearing but credited the plaintiff's evidentiary submissions, we construe the court's ruling as employing the prima facie method.
discussed Cited as authority (verbatim quote) John D. Hartz v. Brandon E. Lenart
W.D. Ky. · 2026 · signal: see also · quote attribution · 1 verbatim quote · confidence high
because the district court did not hold an evidentiary hearing but credited the plaintiff's evidentiary submissions, we construe the court's ruling as employing the prima facie method.
discussed Cited as authority (verbatim quote) PARKER v. BARCLAYS BANK DELAWARE
E.D. Pa. · 2025 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
we have held, however, in a variety of contexts, that the defendant's awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.
discussed Cited as authority (verbatim quote) Estados Unidos Mexicanos v. Smith & Wesson Brands, Inc.
D. Mass. · 2024 · signal: see · quote attribution · 1 verbatim quote · confidence high
there must be more than just an attenuated connection between the contacts and the claim . . . .
examined Cited as authority (verbatim quote) Lewis v. Hill (2×) also: Cited as authority (rule)
D. Mass. · 2023 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
it stretches too far to say that defendant, by mailing a contract with full terms to massachusetts for signature and following up with three e-mails concerning the logistics of signing the contract, should have known that it was rendering itself liable to suit in massachusetts.
examined Cited as authority (verbatim quote) Reynolds v. Angelloti (2×) also: Cited as authority (rule)
D. Mass. · 2021 · quote attribution · 1 verbatim quote · confidence high
it stretches too far to say that prairie eye, by mailing a contract with full terms to massachusetts for signature and following up with three e-mails concerning the logistics of signing the contract, should have known that it was rendering itself liable to suit in massachusetts.
examined Cited as authority (verbatim quote) Azima DLI, LLC v. I-Care Reliability Inc. (2×) also: Cited as authority (rule)
D. Mass. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
there must be more than just an attenuated connection between the contacts and the claim; the defendant's in-state conduct must form an important, or at least material, element of proof in the plaintiff's case.
discussed Cited as authority (verbatim quote) De Leon v. Ocean Motion Watersports
D.N.H. · 2016 · signal: see also · quote attribution · 1 verbatim quote · confidence high
in order to make a prima facie showing of jurisdiction, 'the plaintiff ordinarily cannot rest upon the pleadings but is obliged to adduce evidence of specific facts.
discussed Cited as authority (verbatim quote) I-D Foods v David Deaver Brown
D.N.H. · 2014 · signal: see · quote attribution · 1 verbatim quote · confidence high
the inquiry is whether the plaintiff has proffered evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction
cited Cited as authority (rule) Joel Fuller v. Carrera & Partners, Inc. and Nick Carrera
D. Mass. · 2026 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (citing Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
cited Cited as authority (rule) Thomas Ryan, et al. v. The Newark Group, Inc., et al.; Thomas Ryan, et al. v. EIDP, Inc., et al.
D. Mass. · 2025 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008).
cited Cited as authority (rule) Magdi Rashid v. Qatar Airways Group Q.C.S.C.
D. Mass. · 2025 · confidence medium
Co., 709 F.3d 72, 79 (1st Cir. 2013) (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Burton Boone, III, and Diamond Boone v. Six Unit, LLC, Michael Lizotte, Erica Lizotte, and James & Stolt, LLC, d/b/a Summit Real Estate
D.N.H. · 2025 · confidence medium
While defendants did know that plaintiffs were located in New Hampshire after receiving their offer on the Property, the Court of Appeals for the First Circuit has held “in a variety of contexts, that the defendant's awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008).
cited Cited as authority (rule) Bateman v. Nissan Motor Co., Ltd.
D. Mass. · 2025 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008).
cited Cited as authority (rule) Putnam v. EPR Properties
D. Mass. · 2025 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008).
discussed Cited as authority (rule) Thorstenson v. Unknown Parties
D. Ariz. · 2025 · confidence medium
PETITION FOR WRIT OF MANDAMUS 18 As mentioned, the crux of the Petition is that the State Court improperly entered an 19 Order, and that this Court should direct the State Court to strike that Order from its record. 20 (Doc. 1 at 4.) Because the Court lacks jurisdiction to do so, the Petition is dismissed. 21 “Federal courts are courts of limited jurisdiction.” United States v. Marks, 530 F.3d 22 799, 810 (9th Cir. 2008).
discussed Cited as authority (rule) Contempo Card Company, Inc. v. Myndset Alchemy, LLC
D.R.I. · 2025 · confidence medium
The Court’s inquiry under this standard is whether Contempo (which has the burden of persuasion on this issue) “has proffered evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction.” (quoting , 530 F.3d 22, 26 (1st Cir. 2008)).
cited Cited as authority (rule) Aquidneck Trucking, LLC v. Lightspeed Trucking, LLC
D. Mass. · 2025 · confidence medium
“The plaintiff must demonstrate that each of these three requirements is satisfied.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008).
discussed Cited as authority (rule) Value Based Consultants, LLC v. Ring MD USA, Inc.
D.P.R. · 2025 · confidence medium
See Phillips Exeter, 196 F.3d at 290 (“the mere existence of a contractual relationship between an out-of-state defendant and an in-state plaintiff does not suffice, in and of itself, to establish jurisdiction in the plaintiff's home state.”); see also Inamar Inv., Inc., 737 F.Supp. at 14 (“[I]t has been repeatedly observed that merely contracting with a resident of the forum state is insufficient to subject the nonresident to the forum’s jurisdiction.”); Phillips v. Prairie Eye Ctr., 530 F.3d 22, 29 (1st Cir. 2008) (concluding that there was no purposeful availment after the defenda…
discussed Cited as authority (rule) HANSEN v. HOMESITE INSURANCE COMPANY OF THE MIDWEST
D. Me. · 2025 · confidence medium
The contacts must be deliberate, and not based on the unilateral actions of another party.” Id. (emphasis in original) (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (internal citations omitted).
cited Cited as authority (rule) Aquidneck Trucking, LLC v. Lightspeed Trucking, LLC
D. Mass. · 2025 · confidence medium
“The plaintiff must demonstrate that each of these three requirements is satisfied.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008).
discussed Cited as authority (rule) Vauban International Bank Corporation v. EZBanc Corp
D.P.R. · 2025 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008) (quoting Daynard v. Ness, Motley, Loadholt, Richardson & Poole, P.A., 290 F.3d 42, 51 (1st Cir. 2002)).
discussed Cited as authority (rule) BioFort Corp v. Savir-Baruch
D.P.R. · 2025 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008) (quoting Daynard v. Ness, Motley, example, quash plaintiffs’ service of process, but the central jurisdictional flaw would remain.
discussed Cited as authority (rule) Bain v. McGriff Insurance Services, LLC
M.D. Fla. · 2025 · confidence medium
“Thus, here, we look to whether the defendant's activity in the forum state was instrumental either in the formation of the contract or its breach.” Id. at 27 (cleaned up). 5 A. Due Process Clause “The inquiry into specific jurisdiction1 lends itself to a tripartite analysis.” Phillips Exeter Acad. v. Howard Phillips Fund, 196 F.3d 284, 288 (1st Cir. 1999).
cited Cited as authority (rule) Sunergy Solutions LLC v. Underriner
D. Mass. · 2025 · confidence medium
“The plaintiff must demonstrate that each of these three requirements is satisfied.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008).
discussed Cited as authority (rule) Bain v. McGriff Insurance Services, LLC
M.D. Fla. · 2025 · confidence medium
“Thus, here, we look to whether the defendant's activity in the forum state was instrumental either in the formation of the contract or its breach.” Id. at 27 (cleaned up). 5 A. Due Process Clause “The inquiry into specific jurisdiction1 lends itself to a tripartite analysis.” Phillips Exeter Acad. v. Howard Phillips Fund, 196 F.3d 284, 288 (1st Cir. 1999).
discussed Cited as authority (rule) STATEWIDE TOWING INC v. METRO TOW TRUCKS LTD
D. Me. · 2024 · confidence medium
To meet this burden on the papers, without an evidentiary hearing, the plaintiff must “proffer[ ] evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008).
discussed Cited as authority (rule) Isijola v. US Telecommunications, Inc
D. Mass. · 2024 · confidence medium
Copia, 812 F.3d at 4 (“First, the claim[s] underlying the litigation must directly arise out of, or relate to, a defendant’s forum-state activities.” (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008)).
discussed Cited as authority (rule) Keane v. Expeditors International of Washington, Inc. (2×)
D. Mass. · 2024 · confidence medium
“Under the prima facie standard, the inquiry is whether the plaintiff has proffered evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008).
discussed Cited as authority (rule) McCarty v. Doe
D. Mass. · 2024 · confidence medium
At most, Tuegel’s statements are evidence that she knew that plaintiff was a resident of Massachusetts, and “[a] defendant’s awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008).8 In any event, Calder does not permit the exercise of personal jurisdiction on all out-of- state tortfeasors whose actions lead to in-state injury.
discussed Cited as authority (rule) THREE GIRLS FISHING LLC v. PAN AMERICAN POWER CORP
D. Me. · 2024 · confidence medium
Purposeful Availment Specific jurisdiction exists where the defendant “purposefully availed itself of the privilege of conducting activities in the forum state, thereby invoking the benefits and protections of that state’s laws and making the defendant’s involuntary presence before the state’s courts foreseeable.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (internal quotation marks omitted); see also Ford Motor Co. v. Mont.
discussed Cited as authority (rule) Huang v. Liu (2×) also: Cited "see"
D. Mass. · 2024 · confidence medium
Under the prima facie standard, the plaintiff must proffer “evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction.” A Corp., 812 F.3d at 58 (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)). “[P]laintiffs may not rely on unsupported allegations in their pleadings,” and are instead “obliged to adduce evidence of specific facts” supporting jurisdiction.
discussed Cited as authority (rule) Egan v. X-Mode Social, Inc.
D. Mass. · 2024 · confidence medium
Phillips v. Prairie Eye Ctr., 530 F.3d 22, 30 (1st Cir. 2008) (holding that the “burden on the defendant is disproportionate” if it were subject to suit in Massachusetts where its “principal place of business is in Illinois, and it has no ongoing connection in Massachusetts”).
discussed Cited as authority (rule) Advent Technologies, Inc. v. Kaye
D. Mass. · 2024 · confidence medium
“Voluntariness requires that the defendant’s contacts with the forum state ‘proximately result from actions by the defendant himself.’” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (quoting Burger King Corp. v. 3 Advent Inc. also states that Defendants were paid through a Massachusetts bank account and “reached into” Massachusetts to resign, id. ¶ 28, but those assertions are unsupported.
discussed Cited as authority (rule) Komarovskiy v. Celsius Network LLC
D. Mass. · 2024 · confidence medium
While the Court need not reach the standing issue today, the Court wishes to discuss this and other topics at the next status conference. v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008) (citation omitted).
cited Cited as authority (rule) Naicom Corporation v. Dish Network Corporation
D.P.R. · 2024 · confidence medium
Co., 709 F.3d 72, 79 (1st Cir. 2013) (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Rancourt v. Meredith Corporation (2×) also: Cited "see"
D. Mass. · 2024 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (citing Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Jorge v. Adler
D. Mass. · 2024 · confidence medium
However, the law is clear that “the ‘Defendant's awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.” Power, 648 F. Supp. 3d at 332 (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008)).
cited Cited as authority (rule) Yunnan Duobang Network Technology Co Ltd v. Amazon.com Services LLC
W.D. Wash. · 2023 · confidence medium
Int’l Union, Loc. 1877, AFL CIO, 530 F.3d 22 817, 823 (9th Cir. 2008).
discussed Cited as authority (rule) Rich v. Meta Platforms, Inc (2×)
D. Mass. · 2023 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Sheldon v. DT Swiss AG
D. Mass. · 2023 · confidence medium
“Voluntariness requires that the defendant's contacts with the forum state ‘proximately result from actions by the defendant himself.’” Phillips v. Prairie Eye Center, 530 F.3d 22, 28 (1st Cir. 2008) (quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985).
discussed Cited as authority (rule) Beck, M.D. v. Bronstein, M.D. (2×) also: Cited "see"
D. Mass. · 2023 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (citing Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Ascend Learning, LLC v. Bryan (2×) also: Cited "see"
D. Mass. · 2023 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (citing Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
cited Cited as authority (rule) Ascend Capital LLC v. Moolex, LLC
D. Mass. · 2023 · confidence medium
Copia Commc’ns, LLC v. AMResorts, L.P., 812 F.3d 1, 4 (1st Cir. 2016) (quoting Phillips v. Prairie Eye Ctr., 530 F.3d 22, 27 (1st Cir. 2008)) (internal alteration omitted).
discussed Cited as authority (rule) RelAxe FLSE LLC v. P JBL Village Shoppes LLC
D.N.H. · 2023 · confidence medium
“Voluntariness requires that the defendant’s contacts with the forum state ‘proximately result from actions by the defendant . . . .’” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (quoting Burger King, 471 U.S. at 475 ).
discussed Cited as authority (rule) RelAxe FLSE, LLC v. JBL Village Shoppes, LLC
D.N.H. · 2023 · confidence medium
“Voluntariness requires that the defendant’s contacts with the forum state ‘proximately result from actions by the defendant . . . .’” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (quoting Burger King, 471 U.S. at 475 ).
discussed Cited as authority (rule) Doane v. Benefytt Technologies, Inc. (2×)
D. Mass. · 2023 · confidence medium
Plumbing, Inc., 812 F.3d 54, 58 (1st Cir. 2016) (citing Phillips v. Prairie Eye Ctr., 530 F.3d 22, 26 (1st Cir. 2008)).
discussed Cited as authority (rule) Korngold v. DRB Systems, LLC
D. Mass. · 2023 · confidence medium
The First Circuit has stated that “the defendant’s in-state conduct must form an important, or at least material, element of proof in the plaintiff’s case.” Phillips v. Prairie Eye Ctr. 530 F.3d 22, 27 (1st Cir. 2008) (quoting Harlow v. Child.’s Hosp., 432 F.3d 50, 61 (1st Cir. 2005)).
discussed Cited as authority (rule) Pitts v. San Juan College
D.N.M. · 2023 · confidence medium
“The defendant’s awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (finding that knowing a plaintiff resided in the forum, mailing a contract there, and following up on the receipt of the contract via e-mail was insufficient to find purposeful jurisdiction).
discussed Cited as authority (rule) Pitts v. San Juan College
D. Mass. · 2023 · confidence medium
“The defendant’s awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant.” Phillips v. Prairie Eye Ctr., 530 F.3d 22, 28 (1st Cir. 2008) (finding that knowing a plaintiff resided in the forum, mailing a contract there, and following up on the receipt of the contract via e-mail was insufficient to find purposeful jurisdiction).
Retrieving the full opinion text from the archive…
Christopher PHILLIPS, Plaintiff, Appellant,
v.
PRAIRIE EYE CENTER, Defendant, Appellee
07-2469.
Court of Appeals for the First Circuit.
Jun 12, 2008.
530 F.3d 22
2008 U.S. App. LEXIS 12530
2008 WL 2375177
Pamela A. Smith with whom Law Office of Pamela A. Smith was on brief for appellant., Marissa I. Delinks with- whom CharCretia V. Di Bartolo, William P. Hardy, and Hinshaw & Culbertson LLP were on brief for appellee.
Lynch, Merritt, Howard.
Cited by 253 opinions  |  Published
LYNCH, Circuit Judge.

This dispute arises from an employment negotiation gone awry. Christopher Phillips, an ophthalmologist who lived at the time in Massachusetts, interviewed in Illinois for a job with Prairie Eye Center, a full service ophthalmology practice. After both parties signed an employment contract for Phillips to go work for Prairie Eye in Illinois, the relationship between the two deteriorated. Phillips never went to work for Prairie Eye.

He filed suit against Prairie Eye in Massachusetts state court asserting personal jurisdiction over the defendant pursuant to the Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3. After Prairie Eye removed the case to federal court, the district court found that Prairie Eye lacked the requisite minimum contacts with Massachusetts and dismissed the case. We agree and affirm the dismissal.

I.

We accept the allegations in the complaint as true and construe the facts in the light most favorable to the plaintiff, as we are reviewing a dismissal for lack of personal jurisdiction. Daynard v. Ness, Motley, Loadholt, Richardson & Poole, P.A., 290 F.3d 42, 51 (1st Cir.2002). The facts relevant to determining personal jurisdiction are not in dispute.

[*25] Phillips resided in Massachusetts until 2007. In June 2006, Phillips, who was seeking a new job, posted his résumé on the job placement section of the American Academy of Ophthalmology website. Soon thereafter, he received an e-mail invitation for an interview from Sandra Yeh, the owner and president of Prairie Eye Center, located in Springfield, Illinois.

On August 11, 2006, Phillips flew to Springfield to interview with Yeh and other doctors at Prairie Eye. Afterwards, Prairie Eye sent an unsigned employment contract via first class mail to Phillips in Massachusetts. ' The contract specifically detailed the terms of employment, including duration, compensation, and duties. The parties dispute how much negotiation of the contract occurred while Phillips was in Illinois, but plaintiff does not contest that the unsigned contract he received contained enough material terms that it could be accepted.

On August 20, Yeh sent Phillips an email, which Phillips received in Massachusetts, asking whether Phillips had received the employment contract and asking him if there was anything she could do to help his decisionmaking process. This is the first of Yeh’s three e-mail contacts with Massachusetts that Phillips put in the record. [1] A few hours later, Phillips sent Yeh an e-mail, which Yeh received in Illinois, noting that “[njearly everything [in the contract] looks great, but I [have] just a couple of minor requests to ask of you.” Yeh, via an e-mail later that day (and the second of the proffered e-mail contacts), agreed in principle to Phillips’s proposed changes and asked him to modify the contract with his changes and mail the contract back to Yeh. Phillips then typed his changes into an addendum, signed the contract and addendum, and the following day, mailed the signed contract and addendum to Yeh in Illinois.

A couple of weeks later, on September 10, Yeh e-mailed Phillips again, in the third and last of the proffered e-mail contacts. Yeh noted that she had made a change to the addendum (specifically with regards to the timing of the partnership offer), and needed Phillips to initial the change and send it back to her. Two days later, Phillips e-mailed Yeh saying, “I will initial the contract and get the original right out to you.” He then e-mailed a scanned copy of the initialed contract back to Yeh.

A copy of the contract, executed by both parties, is in the record. The contract, however, was never performed. Soon after the Phillips e-mailed the contract back to Yeh, the relationship between the two fell apart, and Phillips never went to work for Yeh at Prairie Eye Center. How and why the relationship soured is not relevant to the jurisdictional question presented to us.

About a month later, on October 20, 2006, Phillips filed suit against Prairie Eye Center in state court in Massachusetts asserting breach of fiduciary duty and breach of the implied covenant of good faith and fair dealing and seeking a declaratory judgment that the contract was null and void. The defendant removed the action to federal court and filed a motion to dismiss for lack of personal jurisdiction. After allowing extensive briefing and hold[*26] ing a motion hearing, .the district court dismissed the case for lack of personal jurisdiction by a docket notation.

While this case was on appeal, the defendant, Prairie Eye Center, filed a breach of contract action against Phillips in U.S. District Court for the Central District of Illinois seeking damages and declaratory relief. Phillips, who has since moved to the state of Washington, moved for a stay of that proceeding because of the pending appeal in this case. The federal district court in Illinois denied the stay, and Phillips has asserted the claims he makes here as counterclaims in that case.

II.

A. Standard of Review and Burden of Proof

We review de novo a district court’s decision to dismiss for lack of personal jurisdiction. Adelson v. Hananel, 510 F.3d 43, 48 (1st Cir.2007).

The district court “may choose from among several methods for determining whether the plaintiff has met [its] burden.” Id. (quoting Daynard, 290 F.3d at 50-51) (internal quotation marks omitted). Because the district court did not hold an evidentiary hearing but credited the plaintiffs evidentiary submissions, we construe the court’s ruling as employing the prima facie method. [2] This is “the least taxing of these standards from a plaintiffs standpoint.” Rodriguez v. Fullerton Tires Corp., 115 F.3d 81, 83-84 (1st Cir.1997).

Under the prima facie standard, the inquiry is whether the plaintiff has proffered evidence which, if credited, is sufficient to support findings of all facts essential to personal jurisdiction. Daynard, 290 F.3d at 51. In order to make a prima facie showing of jurisdiction, “the plaintiff ordinarily cannot rest upon the pleadings but is obliged to adduce evidence of specific facts.” Foster-Miller, Inc. v. Babcock & Wilcox Canada, 46 F.3d 138, 145 (1st Cir.1995). The court “must accept the plaintiffs (properly documented) evidentiary proffers as true for the purpose of determining the adequacy of the prima facie jurisdictional showing,” Daynard, 290 F.3d at 51 (quoting Foster-Miller, 46 F.3d at 145) (internal quotation marks omitted), and “construe them in the light most congenial to the plaintiffs jurisdictional claim,” id. (quoting Mass. Sch. of Law at Andover, Inc. v. Am. Bar Ass’n, 142 F.3d 26, 34 (1st Cir.1998)) (internal quotation mark omitted).

B. Jurisdictional Analysis

There is no claim here of general jurisdiction. See Harlow v. Children’s Hosp., 432 F.3d 50, 57 (1st Cir.2005) (describing the difference between general jurisdiction, which requires that the defendant have continuous and systematic contacts with the state, and specific jurisdiction, where the claim must be related to the defendant’s contacts). Phillips bases his claim of specific personal jurisdiction over Prairie Eye on the Massachusetts long-arm statute. We proceed directly to the constitutional analysis, “because the Supreme Judicial Court of Massachusetts has interpreted the state’s long-arm statute ‘as an assertion of jurisdiction over the person to the limits allowed by the Constitution of the United States.’ ” Daynard, 290 F.3d at 52 (quoting “Automatic” Sprinkler Corp. of Am. v. Seneca Foods Corp., 361 Mass. 441, 280 N.E.2d 423, 424 (1972)).

[*27] The Due Process Clause requires that “in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.’ ” Int’l Shoe Co. v. Washington, 326 U.S. 310, 319, 66 S.Ct. 154, 90 L.Ed. 95 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463, 61 S.Ct. 339, 85 L.Ed. 278 (1940)). For specific jurisdiction, the constitutional analysis is divided into three categories: relatedness, purposeful availment, and reasonableness.

First, the claim underlying the litigation must directly arise out of, or relate to, the defendant’s forum-state activities. Second, the defendant’s in-state contacts must represent a purposeful availment of the privilege of conducting activities in the forum state, thereby invoking the benefits and protections of that state’s laws and making the defendant’s involuntary presence before the state’s courts foreseeable. Third, the exercise of jurisdiction must, in light of the Gestalt factors, be reasonable.

Adelson, 510 F.3d at 49 (quoting Daynard, 290 F.3d at 60). The plaintiff must demonstrate that each of these three requirements is satisfied.

1. Relatedness

“The evidence produced to support specific jurisdiction must show that the cause of action either arises directly out of, or is related to, the defendant’s forum-based contacts.” Harlow, 432 F.3d at 60-61 (1st Cir.2005); see also Adelson, 510 F.3d at 49. There must be more than just an attenuated connection between the contacts and the claim; “the defendant’s in-state conduct must form an ‘important, or [at least] material, element of proof in the plaintiffs case.” Harlow, 432 F.3d at 61 (quoting United Elec., Radio & Mach. Workers v. 163 Pleasant St. Corp., 960 F.2d 1080, 1089 (1st Cir.1992)) (internal quotation marks omitted).

Phillips brings both a contract claim, breach of the implied covenant of good faith and fair dealing, and a tort claim, breach of fiduciary duty. Although the standard for relatedness for a tort claim is typically different from that of a contract claim, Jet Wine & Spirits, Inc. v. Bacardi & Co., 298 F.3d 1, 10 (1st Cir.2002), here the two claims are sufficiently connected that the difference is of no concern. Phillips’s claim for breach of fiduciary duty concerns the formation of his employment contract. See, e.g., id. (noting that when “the tort is intentional interference with a contractual ... relationship, the two inquiries begin to resemble each other”). Thus, here, we look to whether “the defendant’s activity in the forum state was ‘instrumental either in the formation of the contract or its breach.’ ” Adelson, 510 F.3d at 49 (quoting Phillips Exeter Acad. v. Howard Phillips Fund, Inc., 196 F.3d 284, 289 (1st Cir.1999)).

Phillips’s case does not contain the typical factors which have led us to conclude there is sufficient relatedness. This is unlike cases where the specific terms of an employment contract were “formalized and entered into” in the forum state, and where the employee was subject to “substantial control and ongoing connection to [the forum state] in the performance of this contract.” Id. Here, Phillips provided no evidence that any negotiations took place in Massachusetts. In fact, the unsigned employment contract sent to Phillips shortly after his interview in Illinois is both definite and detailed, and it precedes the three e-mails from Yeh to Phillips. Still, Phillips’s claim does arise out of his contractual relationship with Prairie Eye Center and, accepting his allegations as true, Yeh’s communications to Phillips,[*28] which he received in Massachusetts, were in bad faith. See Daynard, 290 F.3d at 61. That said, we will assume arguendo that the plaintiff established sufficient relatedness.

2. Purposeful Availment

Phillips must also show that Prairie Eye purposefully availed itself of “the privilege of conducting activities in the forum state, thereby invoking the benefits and protections of that state’s laws and making the defendant’s involuntary presence before the state’s courts foreseeable.” Id. (quoting Foster-Miller, 46 F.3d at 144) (internal quotation mark omitted). As the formulation suggests, purposeful availment involves both voluntariness and foreseeability. Id.; see also Adelson, 510 F.3d at 50. Voluntariness requires that the defendant’s contacts with the forum state “proximately result from actions by the defendant himself.” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985). The contacts must be deliberate, and “not based on the unilateral actions of another party.” Adelson, 510 F.3d at 50 (citing Burger King, 471 U.S. at 475, 105 S.Ct. 2174). Foreseeability requires that the contacts also must be of a nature that the defendant could “reasonably anticipate being haled into court there.” Id. (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980)) (internal quotation marks omitted).

Prairie Eye’s contacts with Massachusetts are plainly voluntary. [3] Prairie Eye knew that Phillips said he was a resident of Massachusetts and mailed the unsigned employment contract to Phillips in Massachusetts. Prairie Eye does not contest that it knew Phillips was in Massachusetts when Yeh wrote the e-mails.

Phillips relies on these facts to argue that because he accepted the contract in Massachusetts, Prairie Eye should have foreseen that it could be haled into court in Massachusetts. We have held, however, in a variety of contexts, that the defendant’s awareness of the location of the plaintiff is not, on its own, enough to create personal jurisdiction over a defendant. When a patient argued that jurisdiction in Maine over a Massachusetts hospital was proper because the defendant knew plaintiff resided in Maine, we noted: “Jurisdiction cannot be created by and does not travel with the plaintiff patient wherever she goes.” Harlow, 432 F.3d at 63; see also Sawtelle v. Farrell, 70 F.3d 1381, 1392 (1st Cir.1995) (finding no purposeful availment when “the [defendants’] only connection with [the forum state] was the [plaintiffs’] residence there”). When a plaintiff tire manufacturer argued that a defendant rim manufacturer was subject to personal jurisdiction in Puerto Rico, we noted that even if the defendant had specific knowledge that the stream of commerce would move its tire rims into Puerto Rico, “awareness alone would not be enough to constitute the purposeful availment which is necessary for a showing of[*29] minimum contacts.” Rodriguez, 115 F.3d at 85 (citing Asahi Metal Indus. Co. v. Superior Ct., 480 U.S. 102, 112, 107 S.Ct. 1026, 94 L.Ed.2d 92 (1987) (plurality opinion)).

There is little besides awareness here. It stretches too far to say that Prairie Eye, by mailing a contract with full terms to Massachusetts for signature and following up with three e-mails concerning the logistics of signing the contract, should have known that it was rendering itself hable to suit in Massachusetts. The Massachusetts Supreme Judicial Court recently found personal jurisdiction over nonresident plaintiffs did not comport with due process where the only contacts consisted of a purchase of an insurance policy from a Massachusetts insurer and the mailing of premium payments to Massachusetts. Moelis v. Berkshire Life Ins. Co., 451 Mass. 483, 887 N.E.2d 214, 2008 WL 2122417, at *3 (2008); see also N.H. Ins. Guar. Ass’n v. Markem Corp., 424 Mass. 344, 676 N.E.2d 809, 812 (1997) (no personal jurisdiction over policyholder defendants where insurance contracts were drafted in New Hampshire, insured activity did not occur in Massachusetts, and only relevant contacts were plaintiffs mailing of policy from Massachusetts to defendant, defendant’s mailing of payment to insurer in Massachusetts, and defendant’s submission of claims to Massachusetts); “Automatic” Sprinkler Corp., 280 N.E.2d at 425 (no personal jurisdiction over New York defendant that signed purchase order to buy goods from Massachusetts seller, mailed purchase order to Massachusetts, received invoice from Massachusetts, and sent check to Massachusetts).

The contract was for Phillips to be employed in Illinois, and never for him to be employed in Massachusetts. See, e.g., Harlow, 432 F.3d at 63 (“In the case of personal services focus must be on the place where the services are rendered, since this is the place of the receiver’s ... need.” (quoting Wright v. Yackley, 459 F.2d 287, 289 (9th Cir.1972)) (block quotation)).

Defendant did not initiate the contact with plaintiff in Massachusetts; rather, it was the other way around. Phillips posted his résumé on a national website, and was actively seeking employment outside of Massachusetts. Yeh never entered Massachusetts herself: it was the plaintiff who physically went to Illinois to be interviewed and to discuss a job.

A purpose of the foreseeability requirement is that “personal jurisdiction over nonresidents ... is a quid for a quo that consists of the state’s extending protection or other services to the nonresident.” Sawtelle, 70 F.3d at 1392 (quoting Coté v. Wadel, 796 F.2d 981, 984 (7th Cir.1986)) (alteration omitted) (internal quotation marks omitted); see also Moelis, 451 Mass. 483, 887 N.E.2d 214, 219 (noting that jurisdiction is more appropriate “where nonresidents more intentionally take advantage of favorable State policies”). There is no indication nor even an allegation that Prairie Eye availed itself of any of the protections of Massachusetts law or any other services provided by the state. See Phillips Exeter Acad., 196 F.3d at 292. Hence, Prairie Eye’s contacts with Massachusetts do not constitute sufficiently purposeful availment to allow for the exercise of jurisdiction.

3. Reasonableness

In addition, the Gestalt factors weigh strongly against the exercise of jurisdiction here. The Gestalt factors measure reasonableness: even “if such [requisite] contacts exist,” the court’s exercise of jurisdiction “must comport with ‘fair play and substantial justice.’ ” U.S.S. Yachts, Inc. v. Ocean Yachts, Inc., 894 F.2d 9, 11[*30] (1st Cir.1990) (quoting Burger King, 471 U.S. at 476, 105 S.Ct. 2174).

We think it would be unfair to subject Prairie Eye to suit in Massachusetts. First, the burden on the defendant is disproportionate. The defendant’s principal place of business is in Illinois, and it has no ongoing connection to Massachusetts. As the defendant informed the district court, it plans to call multiple Illinois witnesses in support of its case, all of whom are outside of the jurisdiction of Massachusetts courts.

Second, while we normally give deference to the plaintiffs choice of forum, see Adelson, 510 F.3d at 52, as the plaintiff no longer lives in Massachusetts, it is hard to see why it would be less burdensome for him to appear in Illinois than in Massachusetts, save that he has retained a Massachusetts lawyer. In addition, efficient administration of justice can easily be accomplished in Illinois, where the plaintiff has already asserted his claims as counterclaims in the civil action that is currently proceeding against him. See Daynard, 290 F.3d at 62-63.

Accordingly, exercising personal jurisdiction over Prairie Eye in Massachusetts would “offend traditional notions of fair play and substantial justice.” Int'l Shoe, 326 U.S. at 316, 66 S.Ct. 154 (quoting Milliken, 311 U.S. at 463, 61 S.Ct. 339) (internal quotation marks omitted).

The judgment of the district court is affirmed.

1

. We describe the case in terms of the plaintiffs submissions because the plaintiff bears the burden of establishing jurisdiction. Adelson v. Hananel, 510 F.3d 43, 48 (1st Cir.2007). In its Motion To Dismiss for Lack of Personal Jurisdiction, Prairie Eye attached seven additional e-mails from Yeh to Phillips, most of them dealing with the scheduling of Phillips's August 11 interview. Even if we were to consider the defendant’s submissions, they do not create sufficient contacts to satisfy jurisdictional due process requirements.

2

. The other two methods, the preponderance method and the likelihood method, usually require an evidentiary hearing. See Foster-Miller, Inc. v. Babcock & Wilcox Canada, 46 F.3d 138, 146 (1st Cir.1995).

3

. At oral argument, we raised the question as to whether the voluntariness inquiry should be different for an e-mail contact than for a landline telephone, postal, or face-to-face contact. For the latter types of contacts, voluntariness is clear as the originator of the communication must know its destination before initiating the communication. For example, someone mailing a letter must write a physical address, which exists in some jurisdiction, on the envelope. With an e-mail, however, the originator sends a message to an e-mail address, which does not signal the physical location of the recipient. Generally, the recipient can open the e-mail anywhere in the world. In this case, voluntariness may be ambiguous because the originator of the communication may not know in which jurisdiction the communication will be received. This case does not turn on these issues, though.