12 HARVARD LAW REVIEW. there.^ It is not enough that officers or agents of the corporation are found and served with process within the State. They must be there in their capacity of representatives of the corporation in order that service upon them may be good service upon the corpo- ration. It is only because the agents represent it within the State, and to the extent to which they do represent it, that the corpora- tion is found there for the purpose of being served with process.^ The mere fact, therefore, that a corporation does some business in a State, and that the law makes provision for the service of process on the agents of a foreign corporation, will not make the corporation subject to be sued there upon causes of action having no relation to the business done within the State. Such was the opinion of the Supreme Court of Georgia, the Supreme Court of Vermont, and the Supreme Court of Alabama in cases in which the question was fairly presented for decision. In Bawknight v. Liverpool & London & Globe Insurance Co,,^ the court said : " We are not aware of any case which has decided that a foreign corporation may be sued m personam here on a foreign judgment, or on a contract or debt of any sort with which the Georgia agency has no connection, and it was held that an action could not be maintained in Georgia against an English corporation on a contract made outside of the State, and having no relation to the business done in Georgia, although the summons was served under the statute on an agent there." . . . " It would be strange if such were the law. A debt created in England by this English corporation could then be sued here ; a debt made in China might be sued on in personam here when the corporation is allowed to live only for certain purposes, instead of being sued at home where it lives for all purposes." In Sawyer v. North American Life Ins. Co.,^ the Supreme Court of Vermont held that it had no jurisdiction over a suit by a non- resident against a foreign corporation on a contract made abroad, although process was served on an agent under a statute providing for such service. In Central Railroad and Banking Co. v. Carr,^ suit was brought in Alabama against a railroad company incorporated only in 1 6 Thomp., Corp., §§ 7997, 8029; La Fayette Ins. Co. v. French, 18 IIow. 404; Smith V. Mut. Life Ins. Co., 14 Allen, 336; Nichols v. Green, 72 Iowa, 239.
- Mulhearn v. Press Publishing Co., 53 N. J. L. 150; 57 N. J. L. 388.
» 55 Ga. 194. * 46 Vt. 697. 6 76 Ala. 388 ; 52 Am. Rep. 339.
