erturned prior holdings to
the effect that mere solicitation of patronage does not constitute doing
of business in a State sufficient to subject a foreign corporation to
the jurisdiction thereof,[719] but also rejected the "presence" test as
begging "the question to be decided. * * * The terms 'present' or
'presence,'" according to Chief Justice Stone, "are used merely to
symbolize those activities of the corporation's agent within the State
which courts will deem to be sufficient to satisfy the demands of due
process. * * * Those demands may be met by such contacts of the
corporation with the State of the forum as make it reasonable, in the
context of our federal system * * *, to require the corporation to
defend the particular suit which is brought there; [and] * * * that the
maintenance of the suit does not offend 'traditional notices of fair
play and substantial justice' * * * An 'estimate of the inconveniences'
which would result to the corporation from a trial away from its 'home'
or principal place of business is relevant in this connection."[720] As
to the scope of application to be accorded this "fair play and
substantial justice" doctrine, the Court, at least verbally, conceded
that "* * * so far as * * * [corporate] obligations arise out of or are
connected with activities within the State, a procedure which requires
the corporation to respond to a suit brought to enforce them can, in
most instances, hardly be said to be undue."[721] Read literally, these
statements coupled with the terms of the new doctrine may conceivably
lead to a reversal of former decisions which: (1) nullified the exercise
of jurisdiction by the forum State over actions arising outside said
State and brought by a resident plaintiff against a foreign corporation
doing business therein without having been legally admitted and without
having consented to service of process on a resident agent; and (2)
exempted a foreign corporation, which has been licensed by the forum
State to do business therein and has consented to the appointment of a
local agent to accept process, from suit on an action not arising in the
forum State and not related to activities pursued therein.

By an extended application of the logic of the last mentioned case, a
majority of the Court, in Travelers Health Assn. _v._ Virginia[722]
ruled that, notwithstanding that it solicited business in Virginia
solely through recommendations of existing members and was represented