of International Shoe applies only in cases where there is no presence in the forum state. For example, if A committed a tort in State X. He is sued by B and B serves him with process just before he leaves State X before the flight took off, the service would be valid and State X would have jurisdiction over A. If A did not comply with the final judgement passed by the courts of State X, B could enforce that judgement in the state where A resides under the full faith and credit clause of the US Constitution. There was one case where a defendant was served while the airplane was in the air over the forum State, and the federal district court held that this was valid service, since at law the territory of a state includes the airspace above the State. Relationship to venue Venue and personal jurisdiction are closely related for practical purposes. A lawyer should usually perform joint analysis of personal jurisdiction and venue issues. Personal jurisdiction is largely a constitutional requirement, though also shaped by state long-arm statutes and Rule 4 of the Federal Rules of Civil Procedure, while venue is purely statutory. It is possible for either venue or personal jurisdiction to preclude a court from hearing a case. Consider these examples: Personal jurisdiction is the limiting factor. In World-Wide Volkswagen Corp. v. Woodson, the plaintiffs sued, in an Oklahoma state court, an automobile dealership based in New York for damages from an explosion that occurred on June 11, 1977, as the plaintiffs drove the car through Oklahoma. Had the plaintiffs sued in U.S. federal court sited in Oklahoma, personal jurisdiction against the dealership would have been unavailable, as the dealership did not have minimum contacts with the forum state. Venue, however, would have been proper under , the general federal venue statute, because Oklahoma was a state in which a substantial part of the events or omissions giving rise to the claim occurred. However, the United States Supreme Court found that the defendants (World-Wide Volkswagen Corp.) did not have the minimum contacts with Oklahoma necessary to create personal jurisdiction there. [World-Wide Volkswagen was one of the "defendants"; the case cited is WWV Corp (original defendant) v. Woodson (the Oklahoma state judge) ] Venue is the limiting factor. Suppose Dale resides in California. Peter from Nevada wants to sue Dale for battery which