e. Defined in terms no less
abstract than its alleged successor and capable therefore of acquiring
meaning only in cases of specific application, the "presence" doctrine
was stated by Justice Brandeis as follows: "In the absence of consent, a
foreign corporation is amenable to process to enforce a personal
liability only if it is doing business within the State in such manner
and to such extent as to warrant the inference that it is present
there".[704] In a variety of cases the Court has considered the measure
of "presence" sufficient to confer jurisdiction and a representative
sample of the classes thereof is set forth below.

With rare exceptions,[705] even continuous activity of some sort by a
foreign corporation within a State did not in the past suffice to render
it amenable to suits therein unrelated to that activity. Without the
protection of such a rule, it was maintained, foreign corporations would
be exposed to the manifest hardship and inconvenience of defending in
any State in which they happen to be carrying on business suits for
torts wherever committed and claims on contracts wherever made. Thus, an
Indiana insurance corporation, engaging, without formal admission, in
the business of selling life insurance in Pennsylvania, was held not to
be subject in the latter State to a suit filed by a Pennsylvania
resident upon an insurance policy executed and delivered in
Indiana.[706] Similarly, a Virginia railway corporation, doing business
in New Orleans, was declared not to be within the jurisdiction of
Louisiana for the purposes of a negligence action instituted against it
by a Louisiana citizen and based upon injuries suffered in Alabama.[707]
Also, an Iowa railway company soliciting freight and passenger business
in Philadelphia through a local agent was viewed as exempt therein from
suit brought by a Pennsylvania resident to recover damages for personal
injuries sustained on one of the carrier's trains in Colorado.[708] On
the other hand, when a Missouri statute, accepted by a foreign insurance
company and requiring it to designate the State superintendent of
insurance as its agent for service of process, was construed by Missouri
courts to apply to suits on contracts executed outside Missouri, with
the result that the company had to defend in Missouri a suit on a policy
issued in Colorado and covering property therein, the Court was unable
to discern any denial of due process. The company was deemed to have