Note 705 — AMENDMENT 14 (continued 3)

In a very few cases, "continuous operations within a State were thought to be so substantial and of such a nature as to justify suits against [a foreign corporation] on causes of action arising from dealings entirely distinct from those" operations.—See St. Louis S.W.R. Co. v. Alexander, 227 U.S. 218 (1913); Missouri, K. & T.R. Co. v. Reynolds, 255 U.S. 565 (1921).