What is the test for general jurisdiction in a personal injury action brought by a defendant who allegedly engaged in illegal activities in the forum?

Where the defendant's activities in the forum state are not so pervasive as to justify the exercise of general jurisdiction, then jurisdiction depends upon the quality and nature of the defendant's activities in the forum in relation to the particular cause of action. (Cornelison v. Chaney, supra, 16 Cal.3d 143, 148, 127 Cal.Rptr. 352, 545 P.2d 264.)

"In such a situation, the cause of action must arise out of an act done or transaction consummated in the forum, or defendant must perform some other act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws. Thus, as the relationship of the defendant with the state seeking to exercise jurisdiction over him grows more tenuous, the scope of jurisdiction also retracts, and fairness is assured by limiting the circumstances under which the plaintiff can compel him to appear and defend. The crucial inquiry concerns the character of the defendant's activity in the forum, whether the cause of action arises out of or has a substantial connection with that activity, and upon the balancing of the convenience of the parties and the interests of the state in assuming jurisdiction." (Cornelison v. Chaney, supra, 16 Cal.3d 143, 148, 127 Cal.Rptr. 352, 545 P.2d 264 fn. omitted.)