by the New York court, where the plaintiff sued on the judgment in a court outside of the State of New York?


40
In terms of fairness to the plaintiff, Seider involves by definition a plaintiff who is able to foresee that he may be injured in a foreign jurisdiction and compelled to litigate there.  In Watson, however, the plaintiff's activity was local, and it was certainly much less foreseeable to her that she might be forced to go to Massachusetts or Illinois in order to recover for her local injuries.


41
A balancing of considerations of fairness to the parties, of litigational convenience, and of the interests of the state (which is to say the interest of its citizens) (1) in compensating the injured party, both for his own sakeresident of New York in New York state to which the Alaskan had gone, and quite another to make him do so for an accident which occurred in Alaska when the New Yorker elected to go to Alaska and use its highways.


42
The present case in its application deals only with a New York plaintiff, following the Seider procedure and its impact on a defendant in any of the other forty-nine states which happened to be the accident state.  If its constitutionality is upheld, it is quite likely that all fifty states will be compelled to enact like measures.  As a result each party will commence suit as quickly as possible in an endeavor to have the litigation in the state where he resides.  It would