Extension of "quasi in rem" jurisdiction led to extreme results that threatened the justification for the jurisdiction. Bearing in mind that territorial jurisdiction existed in a pre-industrial society where transportation across the country was difficult, long, and potentially treacherous, and consider the hypothetical wherein Alice owes Bob money, and Bob owes Carmel, a resident of New York, money. Carmel seeks to recover on Bob's debt to Carmel, however cannot do so because Bob avoids Carmel by travelling to California. Alice, however, happens to travel through New York. Carmel serves notice upon Alice, and attaches Alice's debt to Bob (considered to be property within the state) to the proceeding. Alice can no more certainly provide notice to Bob in California than Carmel could provide, and the transient and involuntary exposure of Bob to being hauled into court in New York by this attachment seems to erode the original rationale of "quasi in rem" jurisdiction.