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14 Shoe. The State of Washington sued a corporate defendant in state court for claims based on its in-state activities even though the defendant had not registered to do business in Washington and had not agreed to be present and accept service of process there. 326 U. S., at 312–313. Despite this, the Court held that the suit against the company comported with due process. In doing so, the Court reasoned that the Fourteenth Amendment “permit[s]” suits against a corporate defendant that has not agreed to be “presen[t] within the territorial jurisdiction of a court,” so long as “the quality and nature of the [company’s] activity” in the State “make it reasonable and just” to maintain suit there. Id., at 316, 319–320. Put simply, even without agreeing to be present, the out-of-state corporation was still amenable to suit in Washington consistent with “ ‘fair play and substantial justice’ ”—terms the Court borrowed from Justice Holmes, the author of Pennsylvania Fire. International Shoe, 326 U. S., at 316 (citing McDonald v. Mabee, 243 U. S. 90, 91–92 (1917)).

In reality, then, all International Shoe did was stake out an additional road to jurisdiction over out-of-state corporations. Pennsylvania Fire held that an out-of-state corporation that has consented to in-state suits in order to do business in the forum is susceptible to suit there. International Shoe held that an out-of-state corporation that has not consented to in-state suits may also be susceptible to claims in the forum State based on “the quality and nature of [its] activity” in the forum. 326 U. S., at 319. Consistent with all this, our precedents applying International Shoe have long spoken of the decision as asking whether a state court may exercise jurisdiction over a corporate defendant “ ‘that has not consented to suit in the forum.’ ” Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U. S. 915, 927–928 (2011) (emphasis added); see also Daimler AG v. Bauman, 571 U. S. 117, 129 (2014). Our precedents have recognized, too, that “express or implied consent” can continue to