In the 1915 case Russo-Chinese Bank v. National Bank of Commerce of Seattle, Washington, the U.S. Supreme Court was tasked with determining whether a Russian bank could sue an American bank for refusing to honor its letters of credit after it had been nationalized by the Russian government during a revolution. The court ruled in favor of the American bank, stating that because Russia did not recognize or enforce judgments from U.S courts at that time due to political turmoil and lack of diplomatic relations between two countries, it would be unfair and impractical to allow a Russian entity to take advantage of U.S legal system while denying reciprocal rights to American entities in Russia. This decision established important precedent regarding international law and reciprocity principle in US jurisprudence.

In the dissenting opinion for Russo-Chinese Bank v. National Bank of Commerce of Seattle, Washington, it was argued that the majority's decision to allow a foreign corporation (Russo-Chinese Bank) to sue in U.S. courts without having an established place of business or agent within the country contradicted previous rulings and principles. The dissent emphasized that allowing such actions could potentially open up U.S. courts to a floodgate of litigation from foreign corporations with no real ties or commitments to American jurisdiction, which would be detrimental for domestic businesses and legal system as well as international relations. Furthermore, it was pointed out that this ruling seemed inconsistent with other decisions where non-resident individuals were not allowed similar privileges unless they had property within the state where they intended to sue.