If a plaintiff cannot get a court to exercise in personam jurisdiction over a defendant, the court still might exercise personal jurisdiction on a theory of in rem or quasi in rem jurisdiction. Both in rem and quasi in rem allow a court to exercise personal jurisdiction on the basis of the defendant’s property being in the forum state. 

I. In Rem Jurisdiction

A judgment in rem binds the entire world as to the future disposition of that property, but not the individual parties to the suit;...