CORPORATIONS - FOREIGN CORPORATIONS - SERVICE OF PROCESS BASED UPON SOLICITATION

The question of just when a foreign corporation is amenable to process for an in personam action has long troubled the courts. To one who is seeking a clear and applicable formula, the cases in this field offer but little aid because of the confusion created by the multitude of decisions upon the problem. The decisions of the United States Supreme Court itself are of no great assistance in deriving such a formula. Many attempts have been made by legal writers to define a working rule for this problem as a whole.

However, the present writer will endeavor only to point out certain factors which have influenced decisions in the cases where a foreign corporation was merely soliciting business within the state.