In Kosydar v. National Cash Register Co. (1974) 417 U.S. 62, the court approved the bright line rule stated in Coe, reiterating that mere intent to export will not suffice, and holding the process of exportation does not begin "until the article at issue begins its physical entry into the stream of exportation." (Id. at p. 71.) The court upheld the policy behind Coe's reasoning: "It may be said that insistence upon an actual movement into the stream of export in the case at hand represents an overly wooden or mechanistic application of the Coe doctrine (Coe v. Town of Errol, (1886) 116 U.S. 517). This is an instance, however, where we believe that simplicity has its virtues. The Court recognized long ago that even if it is not an easy matter to set down a rule determining the moment in time when articles obtain the protection of the Import-Export Clause, 'it is highly important, both to the shipper and to the State, that it should be clearly defined so as to avoid all ambiguity or question.' " (Kosydar, at p. 71.)