McGee v. International Life Insurance Co., 355 U.S. 220, 2 L. Ed. 2d 223, 78 S. Ct. 199 (1957), involved the mailing of a reinsurance certificate to a California resident, Franklin, by a Texas insurance company. See 355 U.S. at 221. The certificate was an offer by the Texas company to insure Franklin in accordance with an insurance contract Franklin held with an Arizona insurance company whose insurance obligations had been assumed by the Texas company. See id. Franklin accepted the offer and from then until his death mailed premiums from California to Texas. See McGee, 355 U.S. at 221-22. California jurisdiction was proper because the contract itself had a substantial connection with that state and California had "a manifest interest in providing effective means of redress for its residents when their insurers refuse to pay claims." Id. at 223.