Issue: Does California have jurisdiction over International Life just from the fact they sold one policy in CA but maintain no office, agent employees or other business there?

Rule: When any company does business (purposeful activity – show this by showing it was continuous and systematic) in another state from which they are based, they are automatically legally accountable in that state.

Holding: Because the contract was delivered in CA and premiums were paid from there this is sufficient to establish minimum contacts with the state as presented by International Shoe.

Rationale: It cannot be denied that CA has a manifest interest in providing effective means of redress to its residents when insurers refuse to pay claims. As long as there is one contact in the state this is sufficient to establish a "minimum contact." Also the court looked at fairness to see if it demands exercise of jurisdiction.

Policy/Notes: if activities were continuous and systematic this is evidence that activities were enough for jurisdiction

follow up case: Perkins v. Benguet Consolidated Mining Co., 342 U.S. 437 (1952). D was a Philippine based mining company in which operations were halted because of Japanese occupation. The president of the company relocated and established an office in Ohio. Contact was extensive. P’s suit arose in Philippines. P filed suit in Ohio.

Q: Was this office enough to establish minimum contact in the state? Was there general jurisdiction in Ohio to sue the company in Ohio?

H: Yes, continuous and systematic activities were performed in Ohio which brings it under Ohio jurisdiction. Use the quacks like a duck analogy. If it walks, looks and quacks like a duck it probably is a duck. No test was given as to how to see these cases in the future.