[The conspiracy theory of jurisdiction] is based on two principles: (1) that the acts of one co-conspirator are attributable to all coconspirators, McLaughlin v. Copeland, 435 F.Supp. 513, 530 (D.Md.1977) (“McLaughlin”); and (2) that the constitutional requirement of minimum contacts between non-resident defendants and the forum can be met if there is a substantial connection between the forum and a conspiracy entered into by such defendants. Vermont Castings, Inc. v. Evans Products Co., 510 F.Supp. 940, 944 (D.Vt.1981). The conspiracy theory of jurisdiction as developed*857 in the cases, holds that when several individuals (1) conspire to do something (2) that they could reasonably expect to have consequences in a particular forum, if one co-conspirator (3) who is subject to personal jurisdiction in the forum (4) commits overt acts in furtherance of the conspiracy, those acts are attributable to the other co-conspirators, who thus become subject to personal jurisdiction even if they have no other contacts with the forum……..
However, in several cases in which the conspirator who committed the overt acts was a resident of the forum, courts have required only that “substantial acts” in furtherance of the conspiracy be committed in the forum…. While these courts did not address the point explicitly, the only reasonable interpretation of this standard is that the acts committed in furtherance of the conspiracy must be of a type that, if committed by the non-resident co-conspirators themselves, … would have provided a basis for subjecting the non-residents to personal jurisdiction under the forum’s long-arm statute. If the overt acts do not meet this standard, it would be patently unfair to subject those non-residents to personal jurisdiction via the conspiracy theory, under which the non-residents’ contacts with the forum are less direct.
All this suggests a need for a simplified articulation of the conspiracy theory of jurisdiction. Under that doctrine, when
(1) two or more individuals conspire to do something
(2) that they could reasonably expect to lead to consequences in a particular forum, if
(3) one co-conspirator commits overt acts in furtherance of the conspiracy, and
(4) those acts are of a type which, if committed by a nonresident, would subject the non-resident to personal jurisdiction under the long-arm statute of the forum state,
then those overt acts are attributable to the other co-conspirators, who thus become subject to personal jurisdiction in the forum, even if they have no direct contacts with the forum. Cawley v. Bloch, 544 F.Supp. 133, 134-35 (D.Md.1982) (citations and footnotes omitted), quoted in Chenault v. Walker, No. W1998-00769-COA-RM-CV, slip op. at 14-15 (Tenn.Ct.App. Feb. 9, 2000).
Manufacturers Consolidation Service, Inc. v. Rodell 42 S.W.3d 846, 856 -857 (Tenn.Ct.App.,2000)