OPINION
GOLDBERG, Justice.
This case came before the Supreme Court on October 6, 2009. The defendants, Dell, Inc. f/k/a Dell Computer Corp., Dell Catalog Sales L.P., Dell Marketing L.P., Qualxserv, LLC, and Banctec, Inc. (Dell or collectively defendants) and the intervenor, David M. Sullivan, tax administrator for the State of Rhode Island, sought common-law certiorari to review the denial of a motion to dismiss this case for lack of subject-matter jurisdiction...
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