4. What role ought the historic distinctions of in personam, quasi in rem, and in rem jurisdiction play in assessing the adequacy of notice to defendant? Mullanestates that attachment of a chattel or real estate, together with publication, may provide adequate notice, under the theory that property owners usually are aware of and concerned about the status of their property. Is this consistent with Justice Jackson’s insistence that jurisdiction labels, such as in personam and in rem, should not be considered significant?