3. In RUSH v. SAVCHUK, 444 U.S. 320, 100 S.Ct. 571, 62 L.Ed.2d 516 (1980), the Supreme Court settled the question of whether an insurance obligation can be attached to effect quasi in rem jurisdiction. In finding such an attachment unconstitutional, the Court separated the contacts of the defendant with the forum from those of the insurer with the forum. Having done so, the Court held that sufficient contacts between defendant and the forum did not exist and that the Due Process Clause forbade the assertion of jurisdiction.