"The true ground of the doctrine in felony is this: if a felony be compounded of two distinct acts, one of which takes place in one county and the other in another county, the concurrence of both being necessary to constitute the felony, the party may not be triable in either, because, ex hypothesi, there is no felony committed in either."
January 1, 1970
https://en.wikiquote.org/wiki/Criminal_justice