Summary

Portrait of William O. Douglas William O. Douglas Travelers Health Association v…

A state is helpless when the out-of-state company operates beyond the borders, establishes no office in the state, and has no agents, salesmen, or solicitors to obtain business for it within the state. Then it is beyond the reach of process. In the present case, however, that is only the formal arrangement. The actual arrangement shows a method of soliciting business within Virginia as active, continuous, and methodical as it would be if regular agents or solicitors were employed.
Source: Wikisource

Portrait of William O. Douglas William O. Douglas Travelers Health Association v…

This device for soliciting business in Virginia may be unconventional and unorthodox; but it operates functionally precisely as though appellants had formally designated the Virginia members as their agents. Through these people appellants have realistically entered the state, looking for and obtaining business. Whether such solicitation is isolated or continuous, it is activity which Virginia can regulate.
Source: Wikisource

Portrait of William O. Douglas William O. Douglas Travelers Health Association v…

Practically all of appellants' business in Virginia originates with and is the result of the activities of its Virginia members. The recommendation of a member relieves an applicant of the duty of furnishing any reference. Though the old members are not designated as 'agents,' it 'clearly appears,' as stated by the Supreme Court of Appeals, 'that the association relies almost excusively on these activities of its Virginia members to bring about an expansion of its Virginia business.' Travelers Health Ass'n v.
Source: Wikisource

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