The Page Company v. MacDonald case in 1922 revolved around a copyright dispute between the two parties. The Page Company, an American publisher, had exclusive rights to publish and sell certain books by Lucy Maud Montgomery in the United States. However, they discovered that MacDonald was selling copies of these books imported from Canada where he held his own publishing rights. The U.S Supreme Court ruled in favor of The Page Company stating that even though MacDonald had legal rights to publish the works in Canada, he violated U.S copyright laws by importing and selling them without permission from the holder of U.S copyrights i.e., The Page Company.

In the dissenting opinion for The Page Company v. MacDonald case, Justice Holmes disagreed with the majority's ruling that a Canadian citizen could be sued in Massachusetts without being physically present there. He argued that this violated traditional legal principles of jurisdiction and due process rights under the Fourteenth Amendment. Holmes believed that just because someone sends their product into another state or country doesn't mean they should automatically be subject to its laws and courts; rather, he felt it was necessary for individuals to have some form of meaningful contact or presence within a jurisdiction before they can be held accountable by its legal system. This perspective emphasizes respect for individual rights and sovereignty over commercial convenience.