In the case of Donald, Secretary of State of Wisconsin v. Philadelphia & Reading Coal & Iron Company (1915), the U.S Supreme Court ruled in favor of the defendant, a Pennsylvania corporation that mined and sold coal but did not operate within Wisconsin's borders. The state had attempted to impose an annual license fee on corporations doing business within its jurisdiction, including those incorporated elsewhere. However, it was determined that merely shipping goods into a state for sale does not constitute "doing business" there if no offices or employees are maintained in-state and all transactions are finalized out-of-state. Therefore, such activity is not subject to taxation by said state under the Due Process Clause of the Fourteenth Amendment which prohibits states from depriving any person or entity “of life, liberty or property without due process law.” This ruling clarified interstate commerce regulations and helped define what constitutes 'doing business' within a particular jurisdiction.

In the dissenting opinion for Donald, Secretary of State of Wisconsin v. Philadelphia & Reading Coal & Iron Company, Justice Holmes argued that the majority's decision to uphold a state law requiring foreign corporations to consent to being sued in local courts as a condition of doing business within its borders was an overreach. He contended that such laws were not only unconstitutional but also fundamentally unfair because they forced companies into an untenable position: either give up their right to due process or forfeit their ability to conduct business in certain states. Furthermore, he believed this ruling would set a dangerous precedent by allowing states too much power over interstate commerce and corporate rights.