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As a dedication to Walter V. Schaefer, a preeminent state court
judge, this article is addressed to state court justice. The problem it
addresses is the question of state court jurisdiction in cases that have
out-of-state elements, the problem classically associated in American
law with the decision in Pennoyer v. Neff Its purpose is to suggest
how that problem might be looked at in the future. In advancing that
suggestion, existing law is taken as a point of departure in the quest for
doctrine better suited to the exigencies of modem litigation. What is
sought is an organizing idea toward which decisional law should tend
with definite but unhurried purpose.

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