Response or Comment
It is often assumed that courts can acquire jurisdiction only by personal service to give jurisdiction in personam, or by a seizure to give jurisdiction in rem; but it is not so. The assumption is induced no doubt by the fact that in the ordinary common law actions jurisdiction is acquired in that way. Mr. Justice Field very distinctly pointed out in the case of Pennoyer v. Neff (1877), 95 U. S. 714, that it was not the fact that the land was not seized that rendered the judgment void. It was the fact that the land was not the res in litigation in the prior case that made the judgment void.
Rood, John R. "Acquiring Jurisdiction without Personal Service, Seizure of Aid of Statute." Mich. L. Rev. 16 (1918): 184-7.