In Shaffer v. Heitner, 433 U.S. 186, 197, 97 S. Ct. 2569, 53 L. Ed. 2d 683 (1977), the Court reconsidered Pennoyer's bright-line rule that the mere presence of property in a state provides the basis for in rem jurisdiction. Id. The plaintiff in Shaffer, a nonresident of Delaware, filed a shareholder's derivative suit in Delaware against a Delaware corporation, its subsidiary, and present and former officers and directors, nonresidents of Delaware, arising from events that occurred in Oregon. Id. at 189-91. To bring the individuals within the Delaware court's jurisdiction, the plaintiff successfully seized their company stock and other company holdings, which were considered to be in Delaware. Id. at 190-93. The Supreme Court rejected the notion that the Delaware court could obtain quasi in rem jurisdiction merely by seizing the individuals' company holdings. The Court recognized that the assertion of jurisdiction over property effectively constituted jurisdiction over the interests of parties in that property. Id. at 207. Consequently, the Court concluded that to determine whether exercising jurisdiction over such interests is appropriate, a court must apply the minimum-contacts standard set forth in International Shoe. Id. at 212. In doing so, the Court recognized that a state court will generally have jurisdiction to adjudicate claims concerning property located within its state. Id. at 207-08. Significantly, for purposes of this appeal, the Court noted that when a party seeks to seize intangible property, such as the company holdings at issue in that case or the debt at issue in Harris, "the presence of the . . . property alone would not support the State's jurisdiction." Id. at 209. Rather, other ties must exist to satisfy the minimum-contacts standard. Id. Because such ties did not exist in Shaffer, the Court held that Delaware did not have quasi in rem jurisdiction over the individuals. Id. at 213, 216-17.