Koh, a California resident, won a judgment in California of $240,000 against Inno-Pacific Holdings, Ltd., a Singapore company, but Inno-Pacific did not pay the judgment. Koh discovered that the company had an interest in land in Washington State, so he filed suit in Washington to seize the property to satisfy his judgment. The trial court in Washington dismissed the suit, because it lacked personal jurisdiction over Inno-Pacific. Koh appealed. On what basis could the Washington court have jurisdiction?

Koh, a California resident, won a judgment in California of $240,000 against Inno-Pacific Holdings, Ltd., a Singapore company, but Inno-Pacific did not pay the judgment. Koh discovered that the company had an interest in land in Washington State, so he filed suit in Washington to seize the property to satisfy his judgment. The trial court in Washington dismissed the suit, because it lacked personal jurisdiction over Inno-Pacific. Koh appealed. On what basis could the Washington court have jurisdiction?