A court has jurisdiction in rem over any res of which it has physical control. But does physical control of a document carry with it the control of the chose in action which it represents? This involves an inquiry as to what extent the chose in action is embodied in the document, to what extent the certificate is itself the res or property. Answers to this question have varied with the type of document and even with the type of suit in which the problem has arisen.
CONFLICT OF LAWS-JURISDICTION IN REM OF DOCUMENTED CLAIMS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol32/iss4/5