You have to voluntarily commit the contact. No. Tripping was accidental and the motion which caused the defendant to fall and make contact with the plaintiff was not voluntary. Direct contact is something making contact with one’s body. Indirect contact would be contact within the defined protective zone (doctrine of extended personality). Yes because while smoke is a less obvious form of touching, it is still considered touching in torts. An example from our book to consider is if M were to fill Q’s house with odorless/ colorless/deadly gas, Q suffers harmful contact by inhaling the poisonous gas. Another example to consider is the provision titled “Purposeful Infliction of Bodily Harm” which yields examples of contact that is considered battery but not in its stereotypical form, like being punched in the face. Plenty of case law seems to support that blowing smoke in the plaintiff’s face is considered making contact.