What should be done if a defendant has never been to the state where the lawsuit is filed?

If a defendant has never been to the state where the lawsuit is filed, moving to dismiss for lack of personal jurisdiction is the appropriate course of action because personal jurisdiction refers to a court's authority over a party involved in a legal proceeding. For a court to have personal jurisdiction, typically, the defendant must have sufficient contacts with the state in which the court is located. This can include physical presence, residence, business operations, or other significant interactions within the state.

In this situation, since the defendant has never set foot in the state, there is likely no sufficient connection to establish personal jurisdiction. If the court lacks personal jurisdiction, it cannot compel the defendant to appear or to defend against the action. Therefore, it's essential for the defendant to raise this issue by filing a motion to dismiss, which will prompt the court to examine whether it indeed has the requisite jurisdiction to hear the case involving the defendant.

The other options would not appropriately address the lack of personal jurisdiction. Proceeding with the trial as planned would be inappropriate since it would assume the court has authority, which it may not. Requesting to transfer the case does not rectify the jurisdiction issue if the case is moved to another venue with the same problem. Filing a counterclaim, while it could be