(concurring in part and dissenting in part). I disagree with the majority’s disposition of Issue 1.1 fail to see in what material respect Bill Cody’s Ranch invoked the benefits and protections of Michigan law merely by having American Automobile Association (AAA) endorsement and negotiating with plaintiff’s father through the mails and by telephone.
MCL 600.175(1); MSA 27A.715(1) subjects any person who engages in "[t]he transaction of any business within the state” to the jurisdiction of our courts. By enacting this statute, the Legislature intended to extend the jurisdiction of our courts to the fullest extent permitted by the due process clause of the Fourteenth Amendment. Kriko v Allstate Ins Co, 137 Mich App 528; 357 NW2d 882 (1984).
Due process requires that in order to subject a nonresident defendant to a judgment in personam, the defendant must have certain minimum contacts with the forum state, such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. World-Wide Volkswagen Corp v Woodson, 444 US 286; *596100 S Ct 559; 62 L Ed 2d 490 (1980); International Shoe Co v Washington, 326 US 310, 316; 66 S Ct 154; 90 L Ed 2d 95 (1945). The unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with a forum state. "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting business activities within the forum State, thus invoking the benefits and protections of its laws”. Hanson v Denckla, 357 US 235, 253; 78 S Ct 1228; 2 L Ed 2d 1283 (1958). Jurisdiction may be invoked where a defendant engages in continuous and substantial activities within the forum state or where the suit arises out of an act or transaction having a substantial connection with the forum. See Helicopteros Nacionales de Colombia v Hall, — US —; 104 S Ct 1868; 80 L Ed 2d 404 (1984). However, the mere foreseeability that the conduct of a defendant would have some business effects in the forum state is not sufficient to support jurisdiction. Rather, a defendant’s connection with the state must be such that it "should reasonably anticipate being haled into court” there in the event of a dispute. World-Wide Volkswagen Corp v Woodson, supra.
In the instant case, Bill Cody’s Ranch is a Wyoming corporation which has no other place of business, has never registered with the Secretary of State to do business in Michigan, and has no employees in Michigan. The record before us discloses that Bill Cody’s Ranch advertised in a AAA Tour Book and paid to AAA, in its nationwide capacity, an "Official Appointment Service” fee. There is no evidence that Bill Cody’s Ranch ever particularly sought as customers Michigan residents rather than residents of any other state. Responding to an advertisement in a Tour Book *597which they received from an Automobile Club of Michigan employee, plaintiffs parents telephoned Bill Cody’s Ranch in Wyoming to make further inquiries and arrangements. Bill Cody’s Ranch followed up the conversation by mailing a brochure to plaintiff’s parents. There is no other evidence of any communications between plaintiff and Bill Cody’s Ranch until plaintiff and her family arrived at defendant’s Wyoming establishment. Following their vacation, the family received a direct mail advertisement from Bill Cody’s Ranch.
Tour Books are produced by AAA, and not the Automobile Club of Michigan, for distribution to AAA members across the country. According to the explanatory material in the Tour Book, AAA field representatives search nationwide for accommodations which meet the association’s requirements for recommendation to its membership. Accommodations which are found to be satisfactory are then listed in the Tour Book with a rating. Once selected by AAA for listing, an establishment becomes eligible for the association’s "Official Appointment Service”, which, for "a modest annual fee”, entitles it to display the AAA emblem on the premises and to use it in advertising. Additionally, any establishment selected by AAA for listing in a Tour Book may elect to purchase advertising space in the book. It is thus clear that inclusion in a Tour Book is at the will of AAA and not the featured establishment.
The majority predicates its holding on the following transactions: (1) Bill Cody’s Ranch’s advertisement in a publication distributed nationwide, (2) Bill Cody’s Ranch’s participation in AAA’s nationwide "Official Appointment Service”, (3) Bill Cody’s Ranch’s interstate telephone negotiations with plaintiff’s parents, followed up with the mailing of a brochure, and (4) Bill Cody’s Ranch’s *598posting to plaintiffs family of a direct mail advertisement over three months after plaintiffs injuries were sustained. In my view, the last transaction is irrelevant to this case. Moreover, advertising in national publications distributed within the forum state does not constitute a transaction of business within that state. See, e.g., Bolger v Dial-A-Style Leasing Corp, 159 Colo 44; 409 P2d 517 (1966). If the rule were to the contrary, advertisers in any nationally distributed publication would be subject to the jurisdiction of each of the states in which the publication is distributed. Insull v New York, World-Telegram Corp, 273 F2d 166 (CA 7, 1959). Such a contact is simply too tenuous upon which to found a claim of jurisdiction. See Erlanger Mills, Inc v Cohoes Fibre Mills, Inc, 239 F2d 502 (CA 4, 1956). By analogy, the same is true of AAA’s nationwide "Official Appointment Service” program.
Nor does the interstate posting of a brochure in response to plaintiff’s family’s phone call constitute an act by which defendant purposefully availed itself of the privilege of conducting business activities within Michigan, thus invoking the benefits of our laws. See, e.g, Agrashall, Inc v Bernard Sirotta Co, 344 F2d 583 (CA 2, 1965); Old Westbury Golf & Country Club, Inc v Mitchell, 44 Misc 2d 687; 254 NYS2d 679 (1964); Grobark v Addo Machine Co, 16 Ill 2d 426; 158 NE2d 73 (1959). Thus, I conclude that the transactions upon which the majority relies do not amount to a substantial connection with this state.
Additionally, in my opinion it is important to consider that plaintiff is contending Bill Cody’s Ranch employees, represented to be experts in working with novice riders, were negligent in their exercise of such expertise. A basic question for the trier of fact in this case will be whether the *599employees fell below the standard of care expected of Rocky Mountain horseback riding instructors. The subject is dude ranches and the community is Wyoming. A Wayne County jury lacks the knowledge and the experience to fairly consider the question. In this situation, I do not believe either plaintiff or Bill Cody’s Ranch will be afforded a fair trial in Wayne County.
In my view, the thread purporting to link Bill Cody’s Ranch to Michigan is too tenuous to support jurisdiction in this state. Jurisdiction over Bill Cody’s Ranch properly belongs to the courts of Wyoming. Accordingly, I would reverse the denial of Bill Cody’s motion for accelerated judgment.