International Shoe Co v Washington

FACTS:
Int'l, a Delaware corp, engaged in manufacture and sale of shoes, has its principal business in Missouri. Int'l maintains
places of business in several states such as Washington. Int'l has no office, no contracts, and no stock in Washington. Int'l hired 11-
13 salesmen in Washington (on commission; show samples and solicit orders, subject to Missouri approval), supervised by
managers in Missouri. Int'l argued that Washington has no jd over the present in personam suit to collect tax.
ISSUE:
W/N Washington has jd.
HELD:
YES. First, the systematic solicitation of orders plus some additional activities (permanent display rooms, salesmen's
residence, merchandise regularly shipped) is sufficient to constitute doing business within the state. Such "minimum contacts" are
differentiated from casual presence and single/isolated activities. Second, the presence of a corp (personality is a fiction) is
manifested only by activities carried out by authorized persons.
*In US, concept of judicial jd shifted from territorial power to minimum contact and fairness (b/w defendant and forum;
regardless of non-resident status).