personam jurisdiction, in rem jurisdiction, and quasi in rem jurisdiction. Some sources refer to all three types of territorial jurisdiction as personal jurisdiction, since most actions against property (in rem jurisdiction) bear, in the end, upon the rights and obligations of persons. Others continue to recognize the traditional distinction between personal jurisdiction and jurisdiction over property, even after Shaffer v. Heitner (discussed below). In personam jurisdiction referred to jurisdiction over a particular person (or entity, such as a company). In personam jurisdiction, if held by a state court, permitted that court to rule upon any case over which it otherwise held jurisdiction. Under territorial jurisdiction, pure in personam jurisdiction could only be established by serving notice upon the individual while that individual was within the territory of the state. In rem jurisdiction referred to jurisdiction over a particular piece of property, most commonly real estate or land. Certain cases, notably government suits for unpaid property taxes, proceed not against an individual but against their property directly. Under territorial jurisdiction, in rem jurisdiction could be exercised by the courts of a state by seizing the property in question. Since an actual tract of land could not literally be brought into a courtroom as a person could, this was effected by giving notice upon the real property itself. In rem jurisdiction was thus supported by the assumption that the owner of that property, having a concrete economic interest in the property, had a duty to look after the affairs of their property, and would be notified of the pending case by such seizure. In rem jurisdiction was limited to deciding issues regarding the specific property in question. Quasi in rem jurisdiction involved the seizure of property held by the individual against whom the suit was brought, and attachment of that property to the case in question. This form of territorial jurisdiction developed from the rationale of in rem jurisdiction, namely that seizure of the property was reasonably calculated to inform an individual of the proceedings against them. Once a valid judgment was obtained against an individual, however, the plaintiff could pursue recovery against the assets of the defendant regardless of their location, as other states were obligated by the Full Faith and Credit Clause of the Constitution to recognize such a judgment (i.e. had ceded their power to refuse comity to fellow states of the Union). Violations by a rogue state could