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Related Contracts and Personal Jurisdiction, 101 Harvard Law Review 1444 (1988)


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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