With Regard to Establishing Minimal Contacts to Establish Jurisdiction Regarding

With regard to establishing minimal contacts to establish jurisdiction regarding out-of-state companies that advertise and sell products over the Internet,which of the following is not a true statement?

A) the U.S. Supreme Court has not yet directly ruled on the issue
B) the Zippo Standard, established in Zippo Manufacturing Company v. Zippo Dot Com, Inc., is not legally binding precedent
C) at least six federal circuit courts have adopted the Zippo Standard as the legal framework to assess minimum contacts
D) the Zippo standard sets a rigid test to establish minimum contacts by requiring that at least a minimum of 5% of the state's population visit the company's web site