Personal jurisdiction sits at the core of civil procedure. It is defined as judicial power over a person or property. This power arises from both constitutional and statutory law. Midway through the twentieth century, the Supreme Court attempted to set forth a comprehensive theory of personal jurisdiction under which all assertions of personal jurisdiction could be subsumed for constitutional scrutiny. In International Shoe Co. v. Washington, the Court arrived at the following formulation: “[D]ue process requires only that in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.’”