has jurisdiction consistent with the Due Process Clause to enter orders relating to the property. See ¶ 11, supra. Any reason for continued adherence to the Harris fiction as a basis for the exercise of in rem jurisdiction has disappeared. ¶ 34 Rather, when the plaintiff proceeds in rem, “the solution must be sought in the general principles governing jurisdiction over persons and property rather than in an attempt to assign a fictional situs to intangibles.” Atkinson v. Superior Court, 49 Cal.2d 338, 316 P.2d 960, 964 (1957) (Traynor, J.). Courts must focus on reality, not fiction. Under such an analysis, an intangible not embodied in a document is undoubtedly subject to the jui'isdiction of the court where its owner is domiciled. Gravano, 204 Ariz. at 117 ¶ 45, 60 P.3d at 257 (<HOLDING>) (citing Kelly v. Bastedo, 70 Ariz. 371, 377,
recognizing limited partnership interest as intangible personal property holding that for a suit to be brought in the venue in which the contract was to be performed the contract must expressly state where the performance of the contract was to occur holding that gravanos rights under a book contract which are intangible property could be seized in arizona because gravano was a resident here holding that nonsignatories to a contract have no rights under the contract and thus no standing to assert claims under the contract recognizing that property not subject to physical seizure such as mutual fund shares are intangible property