2. Traditional analysis distinguishes three types of jurisdiction. In a proceeding in personam, the court exercises its power to render a judgment for or against a person by virtue of his presence within the state’s territory or his citizenship there. In a proceeding in rem, the court exercises its power to determine the status of property located within its territory, and the determination of the court is binding with respect to all possible interest holders in that property. In a proceeding quasi in rem, the court renders a judgment for or against a person, but recovery is limited to the value of property that is within the jurisdiction and thus subject to the court’s authority. The dispute that gives rise to an action quasi in rem may be related to the property or unrelated to it. In an action quasi in rem, the property may be used to satisfy any judgment assessed in the action. Which of these bases of jurisdiction were at issue in Pennoyer?