traditional notions of fair play and substantial justice.” Intl Shoe Co. v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945); see also World-Wide Volkswagen Corp. v. Wood- son, 444 U.S. 286, 292, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). The minimum con- tacts requirement is also known as “fair warning,” such that