The Third Circuit Court of Appeals has held that the pre-incorporation acts of a promoter, when coupled with post-incorporation ratification, may suffice to justify the exercise of in personam jurisdiction over a foreign corporation in the state of pre-incorporation activities.
Rees v. Mosaic Technologies, Inc. 742 F.2d 765 (3d Cir. 1984).
Edward G. Rice,
In Personam Jurisdiction - Minimum Contacts - Ratifications - Promoters Contracts,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol24/iss1/8