Personal Jurisdiction Over an Out-Of-State Defendant Would Likely Not Occur

Personal jurisdiction over an out-of-state defendant would likely not occur in which of the following situations?

A) The defendant maintains an office in the forum state.
B) The defendant, at a minimum, has employees that enter the forum state to conduct business.
C) The e-mail is an integral part of an ongoing business relationship even if no offices or personnel are within the forum state.
D) Despite the exchange of e-mails, there is no ongoing business relationship between the parties.