. & Co. _v._ Curtis Brown Co., 260 U.S. 516, 517
(1923).

[711] Goldey _v._ Morning News, 156 U.S. 518 (1895).

[712] Conley _v._ Mathieson Alkali Works, 190 U.S. 406 (1903).

[713] Riverside Mills _v._ Menefee, 237 U.S. 189, 195 (1915).

[714] Mutual Life Insurance Co. _v._ Spratley, 172 U.S. 602 (1899).

[715] St. Clair _v._ Cox, 106 U.S. 350, 356 (1882). _See_ St. Louis
S.W.R. Co. _v._ Alexander, 227 U.S. 218 (1913).

[716] Mutual Reserve &c. Assn. _v._ Phelps, 190 U.S. 147, 156 (1903).

[717] Washington _v._ Superior Court, 289 U.S. 361, 365 (1933).

[718] 326 U.S. 310, 317-320 (1945).

[719] This departure was recognized by Justice Rutledge in a subsequent
opinion in Nippert _v._ Richmond, 327 U.S. 416, 422 (1946).

The principle that solicitation of business alone is inadequate to
confer jurisdiction for purposes of subjecting a foreign corporation to
a suit _in personam_ was established in Green _v._ Chicago, B. & Q.R.
Co., 205 U.S. 530 (1907); but was somewhat qualified by the later
holding in International Harvester Co. _v._ Kentucky, 234 U.S. 579
(1914) to the effect that when solicitation was connected with other
activities (in the latter case, the local agents collected from the
customers), a foreign corporation was then doing business within the
forum State. Inasmuch as the International Shoe Company, in addition to
having its agents solicit orders, also permitted them to rent quarters
for the display of merchandise, the observation has been made that the
Court, by applying the qualification of the International Harvester
Case, could have decided International Shoe Co. _v._ Washington, 326
U.S. 310 (1945) as it did without abandoning the "presence" doctrine.

[720] 326 U.S. 310, 316-317.

[721] Ibid. 319.

[722] 339 U.S. 643 (1950).

[723] Ibid. 647-649.--Concerning the holding in Minnesota Ass'n. _v._
Benn, 261 U.S. 140 (1923), that a similar Minnesota mail order insurance
company could not be viewed as doing business in Montana where the
claimant-plaintiff lived, and that the circumstances under which its
Montana contracts, executed and to be performed in Minnesota, were
consummated could not support in implication that the foreign insurer
had consented to be sued in Montana, the majority asserted that the
"narrow grounds relied on by the Court in the Benn Case cannot be deemed
controlling."

Declaring that what is necessary to sustain a suit by a policyholder in
Virginia against a forei