Read the following excerpt from a US court opinion:
```
318, 66 S.Ct. 154; see Helicopteros Nacionales, 466 U.S. at 414, 104 S.Ct. 1868 (“Even when the cause of action does not arise out of or relate to the foreign corporation’s activities in the forum State, due process is not offended by a State’s subjecting the corporation to its in personam jurisdiction when there are sufficient contacts between the State and the foreign corporation.”). ¶ 15 International Shoe and the cases immediately following it addressed only in personam jurisdiction. Thus, the sole constitutional issue when a state sought to exercise either in rem or quasi in rem jurisdiction continued to be the one posed by Pennoyer: Was the relevant property within the jurisdiction of the state? See, e.g., Hanson v. Denckla, 357 U.S. 235, 246, 78 S.Ct. 1228, 2 L.Ed.2d 1283 (1958) . The hoary doe trine of Harris v. Balk, 198
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that the basis of in rem jurisdiction is the presence of the subject property within the territorial jurisdiction of the forum state
B. holding that where prior state court had in rem jurisdiction district court could maintain in personam jurisdiction and simply deny requests for conflicting in rem relief because district court is fully capable of preventing inappropriate conversion of the suit to a proceeding truly in rem
C. holding that an action quasi in rem requires a seizure of property within the jurisdiction of the court or its equivalent
D. holding that in a quasi in rem action a district court does not have jurisdiction over the res when that property is not physically within the same state as the court
E. holding that a party cannot waive in rem jurisdiction under florida law and a court proceeding pursuant to in rem jurisdiction must actually possess in rem jurisdiction over the property that is the subject of the matter
Reply with [A, B, C, D, E] only.