The current doctrine of "minimal contacts" had already been around for 45 years in 1990. https://en.m.wikipedia.org/wiki/International_Shoe_Co._v._Washington h

The current doctrine of "minimal contacts" had already been around for 45 years in 1990. https://en.m.wikipedia.org/wiki/International_Shoe_Co._v._Washington https://en.m.wikipedia.org/wiki/International_Shoe_Co._v._Wa... Yes, I think Comgress should be presumed to have known about it.