Pneuma-Flo Systems, Inc. v. Universal MacHinery Corp.

MEMORANDUM OPINION AND ORDER

HAIGHT, District Judge:

The due process era in jurisdiction, ushered in by International Shoe Co. v. Washington, 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95 (1945) and continued apace by decisions such as Shaffer v. Heitner, 433 U.S. 186, 97 S.Ct. 2569, 53 L.Ed.2d 683 (1977), has undoubtedly brought about a more equitable distribution of hardships arising when a local plaintiff seeks redress against a foreign defendant. This revolution, achieved through the repudiation of simple physical presence as the sine qua non of amenability to suit and substituting the forum…