Three cases from the Middle District of North Carolina have held that merely sending a cease-and-desist letter is insufficient to establish personal jurisdiction. See United Plastics Corp. v. Terra Tech., Inc., No. 1:06cv00629, 2007 U.S. Dist. LEXIS 10812, at *11-13 (M.D.N.C. Feb. 6, 2007) (finding that the out-of-state defendant did not avail itself of the laws of North Carolina when it sent a cease-and-desist letter and subsequent correspondence in an attempt to settle a patent dispute); Wood Int'l, Inc. v. McRoy, 436 F. Supp. 2d 744, 751 (M.D.N.C. 2006) (noting that defendant did not attempt to solicit business or enter into a business relationship in North Carolina and concluding that a cease-and-desist letter alone is not sufficient to support personal jurisdiction in a declaratory judgment action involving copyrighted material); Intec USA, LLC v. Engle, No. 1:05CV468, 2005 U.S. Dist. LEXIS 38490, at *15-16 (M.D.N.C. Sept. 8, 2005) (holding that no personal jurisdiction existed in breach of contract action because defendant's letter sent to Washington state, the location of plaintiff's law firm, did not clearly threaten litigation in North Carolina, the location of plaintiff). However, recent out-of-circuit court of appeals decisions have analyzed the issue in a variety of contexts and have uniformly held that cease-and-desist letters alone do not establish personal jurisdiction.