Not so here. See, e.g., Chouinard v. Marigot Beach Club and Dive Resort, C.A. No. 20-10863-MPK, 2021 WL 2256318, at *12 n.23 (D. Mass. June 3, 2021) (Kelly, M.J.) (distinguishing such cases on that basis). Focusing on Goodyear's intentional acts that gave rise to the present dispute, they have occurred outside Massachusetts -- a fact that Alves does not dispute.