First Natl. Bank of Omaha v. Spirit Med. Transport, 2017 Ohio 1468

First National Bank of Omaha (First National) sued Spirit Medical Transport (Spirit) in Ohio for unpaid credit-card debt of about $52,553.
Spirit answered and asserted First National was not licensed to do business in Ohio and therefore barred from suing.
Evidence at bench trial: Spirit obtained the card through Old National Bank in Union City, Ohio; First National employee testified Old National acts as First National’s agent and solicits business and uses First National’s credit-card applications.
First National conceded it was an unlicensed foreign corporation in Ohio and argued it was exempt from Ohio’s foreign-corporation licensing statute either because it engaged solely in interstate commerce or because it was a national bank.
The trial court found First National transacted business in Ohio, failed to prove any exemption, and dismissed the complaint; First National appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether First National was required to obtain an Ohio foreign-corporation license before suing under R.C. Ch. 1703	First National: not transacting business in Ohio; exempt as engaged solely in interstate commerce and/or as a national bank	Spirit: First National transacts business in Ohio through Old National Bank as its agent; no license = barred from suing	Court affirmed dismissal: First National transacts business in Ohio via Ohio agent, not solely interstate commerce; national-bank exemption not shown; unlicensed foreign corp cannot maintain suit

Cincinnati Metro. Hous. Auth. v. Edwards, 174 Ohio App.3d 174 (2007) (use of common/dictionary meaning when statute doesn’t define a term)
Dot Systems, Inc. v. Adams Robinson Ent., Inc., 67 Ohio App.3d 475 (1990) (foreign corporation is not engaged solely in interstate commerce where it enters the state through agents and transacts a substantial, noncasual portion of its business)