business within its borders, it may condition entry upon acceptance by
the corporation of service of process upon its agents or upon a person
to be designated by the corporation or, failing such designation, upon a
State officer designated by law.[715] Service on a State officer,
however, is no more effective than service upon an agent in the employ
of a foreign corporation when, as has already been noted, such
corporation is not subject to the jurisdiction of the State; that is,
has not engaged in activities sufficient to render it "present" within
the State, or is subjected to a cause of action unrelated to such
activities and originating beyond the forum State. Thus, a foreign
insurance company which, after revocation of its entry license,
continued to collect premiums on policies formerly issued to citizens of
the forum State was in fact continuing to do business in that State
sufficiently to render service on it through the insurance commissioner
adequate to bind it as defendant in a suit by a citizen of said State on
a policy therein issued to him.[716] Furthermore, a foreign corporation
which, after leaving a State and subsequently dissolving, failed to obey
a statutory requirement of that State that it maintain therein a
resident agent until the period of limitations shall have run, or, in
default thereof, that it consent to service on it through the Secretary
of State, could not complain of any denial of due process because that
statute did not oblige the Secretary of State to notify it of the
pendency of an action. The burden was on the corporation to make such
arrangement for notice as was thought desirable.[717]

To what extent these aforementioned holdings have been undermined by the
recent opinion in International Shoe Co. _v._ Washington[718] cannot yet
be determined. In the latter case, a foreign corporation, which had not
been issued a license to do business in Washington, but which
systematically and continuously employed a force of salesmen, residents
thereof, to canvass for orders therein, was held suable in Washington
for unpaid unemployment compensation contributions in respect to such
salesmen. Service of the notice of assessment personally upon one of its
local sales solicitors plus the forwarding of a copy thereof by
registered mail to the corporation's principal office in Missouri was
deemed sufficient to apprize the corporation of the proceeding.

To reach this conclusion the Court not only ov