1. Burnham.) Some states do not recognize the doctrine and, at best, it is a greater longshot than a motion to transfer. 117 "'Modern transportation and communications have made it much less burdensome for a party sued to defend himself' in a State outside his place of residence;U. ILL. L. REV,1990
2. relative ease of travel might be used against the plaintiff, who, except in some personal injury cases, can travel as easily as the defendant. The plaintiff in Kulko, for example, must travel to New York to press her claim. See Lea Brilmayer, How Contacts Count: Due Process Limitations on State Court Jurisdiction;U;SUP. CT. REV,1980