I guess there is a significant risk of the result being found in the States' favor so that they don't directly challenge the law. IANAL, but it seems like the

I guess there is a significant risk of the result being found in the States' favor so that they don't directly challenge the law. IANAL, but it seems like the Supreme Court would very likely rule in their favor though. Quill v N Dakota is a very similar ruling and when looking through the notes I found this: "As we noted in Heublein, Inc. v. South Carolina Tax Comm'n, 409 U.S. 275, 280 (1972), in enacting § 381, "Congress attempted to allay the apprehension of businessmen that `mere solicitation' would subject them to state taxation. . . . Section 381 was designed to define clearly a lower limit for the exercise of [the State's power to tax]. Clarity that would remove uncertainty was Congress' primary goal.""