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We do not feel that due process of law should be construed to mean that non-resident traders shall be at liberty to seek our markets and to avoid our courts. While we are properly prohibited from seizing a defendant who has not submitted itself in some manner to our jurisdiction, we should not be compelled to banish a citizen plaintiff to an alien jurisdiction that he has never submitted himself to in order that he may pursue a cause of action arising here.
Jamestown, NY Lawyer Robert H. Jackson. New York Law Review, 1927.