JURISDICTION-BASIS AND RANGE OF PROCESS-RECENT DEVELOPMENTS

Since Pennoyer v. Neff, holding that mere notice was an insufficient basis for in personam jurisdiction, it has generally been held that an in personam judgment requires service, as distinguished from notice, on a defendant present or domiciled within the jurisdiction. With the increased tempo of interstate activities, however, it has become expedient to relax the concept of physical power as being the basis of jurisdiction, which prompted the Pennoyer decision. Presence has assumed a more elaborate meaning, while service has become more closely equated with adequate notice. Illustrative of this development is the recent decision of Traveler\u27s Health Assn. v. Virginia, where peculiar problems were presented relating to a state\u27s ability to regulate activity carried on substantially beyond its borders, but seriously affecting those within its jurisdiction