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14 agent, so that the company could then be constructively “present” for in-state service. Mutual Reserve Fund Life Assn. v. Phelps, 190 U. S. 147, 158–159 (1903); see St. Clair, 106 U. S., at 356.

As Justice Scalia explained, such extensions of “consent and presence were purely fictional” and can no longer stand after International Shoe. Burnham, 495 U. S., at 618; see also, e.g., Shaffer v. Heitner, 433 U. S. 186, 202–203 (1977) (International Shoe abandoned “both the fictions of implied consent to service on the part of a foreign corporation and of corporate presence”); McGee v. International Life Ins. Co., 355 U. S. 220, 222 (1957) (International Shoe “abandoned ‘consent,’ ‘doing business,’ and ‘presence’ as the standard for measuring the extent of state judicial power over [foreign] corporations”); International Shoe, 326 U. S., at 318. The very point of International Shoe was to “cast … aside” the legal fictions built on the old territorial approach to personal jurisdiction and replace them with its contacts-based test. Burnham, 495 U. S., at 618 (opinion of Scalia, J.); id., at 630 (Brennan, J., concurring in judgment) (International Shoe abandoned the previous “ ‘patchwork of legal and factual fictions’ ”). In Burnham, we upheld tag jurisdiction because it is not one of those fictions—it is presence. By contrast, Pennsylvania’s registration statute is based on deemed consent. And this kind of legally implied consent is one of the very fictions that our decision in International Shoe swept away. See 326 U. S., at 318; Ford Motor, 592 U. S., at ___ (, concurring in judgment) (slip op., at 8).

Neither nor the plurality seriously contests this history. Nor does either deny that Mallory’s theory would gut Daimler. Instead, they insist that we already decided this question in a pre-International Shoe precedent: