In May, we published an article in this journal entitled "Alaska Supreme Court Invalidates Exclusive Jurisdiction Provision,"1 concerning the Alaska Supreme Court’s decision in Toni 1 Trust v. Wacker (Toni 1 Trust).2 That decision held that Section 34.40.110(k) of the Alaska Trust Act, which purported to grant Alaska courts exclusive jurisdiction over fraudulent transfer actions against Alaska self-settled spendthrift trusts, was an ineffective exercise of the Alaska legislature’s authority and couldn’t control the jurisdictional question that it sought to control. The Toni 1 Trust decision confirmed an earlier decision of the Montana courts to the effect that a transfer of Montana real estate to an Alaska self-settled spendthrift trust during the pendency of a lawsuit was, of course, a fraudulent transfer.