Which kind of property could not be subject to in rem jurisdiction?

Name: Which kind of property could not be subject to in rem jurisdiction?
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Question

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In rem jurisdiction refers to the power a court may exercise over property located within its jurisdiction, regardless of the owner's location. Real estate, automobiles, stocks or bonds issued by a company, and furniture can all be subject to in rem jurisdiction because they are types of property that can be located within a court's jurisdiction.

Which Kind of Property Could Not Be Subject to in Rem