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It used to seem so easy. After Professors Arthur von Mehren and Donald Trautman wrote their celebrated article, we came to accept that there were two kinds of jurisdiction, general and specific. If the defendant entered into the state and committed a tort, this gave rise to specific jurisdiction in that state's courts. If the defendant merely conducted unrelated business in the forum, jurisdiction was necessarily "general." In the latter case, jurisdiction was harder to establish
because the quantum of unrelated contacts sufficient to establish general jurisdiction was greater than the quantum required for jurisdiction. Supreme Court cases seemed to reflect this dichotomy between general and specific jurisdiction fairly nicely.

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