Use this rule to obtain personal jurisdiction over a defendant in any case arising out of the ownership, use, or possession of real property, or other tangible assets, or “things of value” situated in Oregon. Be aware, however, that “[t]he bare fact of real estate holdings, without more, cannot serve as the basis for establishing personal jurisdiction in an action that neither arises out of, nor relates to, defendant’s property ownership.” Sutherland v. Brennan, 131 Or App 25, 30, 883 P.2d 1318 (1994), aff’d 321 Or 520 (1995). A “thing of value” can include a defendant’s contractual obligations to pay or distribute money in Oregon. See, Dreher v. Smithson, 162 Or App 645, 650, 986 P2d 721 (1999), rev den, 329 Or. 589 (2000) (citations omitted; interpreting ORCP 4E).