Heading: Gray v. American Radiator & Standard Sanitary Corp., 22 Ill. 2d 432, 176 N.E.2d 761 (1961) p58.

Facts: - Suit brought against Titan Valve Manufacturing for the negligent construction of a water valve which caused the water heater in which it was used to explode and injure the plaintiff.

Procedure: Gray appeals from a judgement of the circuit court of Cook County dismissing her action for damages. Since a constitutional question is involved it is appealed directly to this court.

Issue: Is a statute within the due process of the law that provides that summons may be served upon any party outside the state and that such service has the force and effect of personal service within Illinois? Secondly, was a "tortious act" committed in Illinois?

Rule: Even though a company may not sell products directly to a specific state, when those products are used within a state, the manufacturer is responsible for the safety of the product, and thus must answer to any actions brought against it within that state.

Holding: A tortious act was committed within Illinois and the state statute allowing for the summons outside of the state does not violate due process of law.

Rationale: 1. It is well established that in law, the place of wrong is where the last event takes place which is necessary to render the actor liable. Negligence in manufacturing cannot be separated from the resulting injury.

2. To establish jurisdiction there must be certain minimum contacts with the state (International Shoe). Although these valves were not sold directly to residents in Illinois, there is no contesting the fact that the valves are widely used in Illinois on water heaters. This results in reasonable use and consumption within the state. Therefore it benefits from the laws of the state and benefited from the protection the law gives to the marketing of hot water heaters.