The U.S. Supreme Court case Codlin v. Kohlhausen in 1900 revolved around a dispute over the ownership of certain shares of stock in the American Tobacco Company. The plaintiff, Codlin, claimed that he had purchased these shares from defendant Kohlhausen and sought to have them transferred into his name on the company's books. However, Kohlhausen refused to do so arguing that no such sale took place and maintained possession of the certificates representing said stocks. The court ruled in favor of Codlin based on evidence presented which included letters between both parties acknowledging an agreement for purchase as well as payment receipts for said stocks by Codlin. The court held that even though physical possession was with Kohlhausen, beneficial ownership belonged to Codlin due to their contractual agreement and subsequent payments made by him towards it. Therefore, it ordered transferal of those shares into Codlin’s name despite objections raised about irregularities or frauds committed during this transaction process by other shareholders who were not party to this lawsuit.

The dissenting opinion in the case of Codlin v. Kohlhausen argued that the majority's decision was based on a misinterpretation of New York state law, which they believed did not allow for an action to be brought against a foreign corporation unless it had been doing business within the state at the time when cause for such action arose. They contended that there was no evidence presented showing that this condition had been met and therefore, according to their interpretation of New York law, jurisdiction could not have been established over defendant Kohlhausen & Co., a German company. The dissenters also disagreed with how broadly 'doing business' was defined by the majority; they felt this definition should be more narrowly construed as requiring some form of continuous and systematic activity within New York State rather than just occasional transactions or activities.