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