Milwaukee Concrete Studios, Limited v. Fjeld Manufacturing Company, Incorporated, and Janice Krueger

Determining where an individual “may be found” ordinarily poses no difficulties: That locution is normally understood in its literal sense of the individual’s physical presence. Indeed, for a long time the one-to-one correlation between the concept of being “found” in a place and being physically present there marked the outer limit of a court’s — and hence of an opposing litigant’s — ability to *452exercise power over an individual defendant (Pennoyer v. Neff, 95 U.S. 714, 24 L.Ed. 565 (1877)). In those days it would have been unheard of to question the concept that tagging an individual with a…