1. After Perkins, discussed in Goodyear, lower courts remained uncertain as to when contacts with the forum were so “continuous and systematic” and “sufficiently substantial”

as to support jurisdiction on a cause of action that did not arise out of defendant’s in-state activity. At least one appeals court warned that devising “useful general standards” in this area would be “almost impossible,” adding that “an examination of the multitude of decided cases can give little assistance.” Aquascutum of London, Inc. v. S.S. AmericanChampion, 426 F.2d 205, 211 (2d Cir. 1970).

Does Goodyear clarify when general jurisdiction may be exercised? The opinion states that general jurisdiction exists in the place where “the corporation is fairly regarded as at home,” using the place of incorporation and the principal place of business as examples of a corporation’s “home.” Does a corporate home require a physical presence in the state? Is it significant that Goodyear USA did not challenge North Carolina’s exercise of jurisdiction over it, even though the company is not incorporated in that state and does not have a principal place of business there?