N.Y. C.P.L.R. § 302
Personal jurisdiction by acts of non-domiciliaries: the cases that interpreted this section
2,666 citing cases reviewed of 4,447 in the citation index: 2,170 interpreted the section (annotated below), 496 cited it only in passing. Cases filed after 2026-06-11 may not have been reviewed yet.
Have a situation under N.Y. C.P.L.R. § 302?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Claim arising from New York business
Section 302(a)(1) permits personal jurisdiction over a nondomiciliary who transacts business in New York, even if the person has never entered the state.
Shalik v. Coleman · filed 2013-11-20(a)(1)
Under CPLR 302 (a) (1), New York courts have personal jurisdiction over a nondomiciliary when that person transacts any business within New York State, regardless of whether that nondomiciliary has actually set foot in the State (see Executive Life Ltd. v Silverman, 68 AD3d 715, 716 [2009]).Read the full opinion on CourtListener →
CPLR 302(a)(1) permits jurisdiction based on one purposeful New York transaction substantially related to the claim; disputed facts about the defendant’s New York business contacts warrant a hearing.
MPG Associates, Inc. v. Roeske · filed 2013-12-04(a)(1)
Further, given the contradictions in the record as to whether the defendant solicited the plaintiffs New York customers and derived commissions from alleged sales to those customers (see SmartPros, Ltd. v Straub, 24 AD3d 653 [2005]; Vacuum Instrument Corp. v EPM Co., 8 AD3d 661 [2004]), a question of fact exists that warrants a hearing (see Vandermark v Jotomo Corp., 42 AD3d at 931; Corchia v Junik, 158 AD2d 574, 575 [1990]; see also Delgado v Velecela, 56 AD3d 515 [2008]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nondomiciliary whose conduct amounts to transacting business in New York.
Wohl v. Landmark Capital II, LLC · filed 2013-12-18(a)(1)
The defendants’ conduct was insufficient to confer personal jurisdiction over them in New York (see CPLR 302 [a]; Matter of Stengel v Black, 28 AD3d 401 [2006]; L. F. Rothschild, Unterberg, Towbin v McTamney, 89 AD2d 540 [1982], affd for reasons stated 59 NY2d 651 [1983]; cf. Fischbarg v Doucet, 9 NY3d 375, 380 [2007]; Deutsche Bank Sec., Inc. v Montana Bd. of Invs., 7 NY3d 65, 71 [2006], cert denied 549 US 1095 [2006]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nondomiciliary whose New York business transactions, including those through an agent, are substantially related to the claims.
Chevron Corp. v. Donziger · filed 2014-03-04(a)(1)
For all these reasons, the LAP Representatives’ claims in this action arise out of their extensive transaction of business in New York since 1993 and extending up to and beyond commencement of this lawsuit. Jurisdiction is proper under Section 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer personal jurisdiction based on New York business transactions when the claim did not arise from those transactions.
Morgan Keegan & Co. v. Rote · filed 2014-03-13(a)(1)
Furthermore, respondents’ travel to New York for the sole purpose of conducting the remaining hearing sessions from the Tennessee arbitration in the New York office of petitioner’s counsel was insufficient to establish personal jurisdiction, particularly where the cause of action at issue did not arise from those business transactions (CPLR 302 [a] [1]; see D&R Global Selections, S.L. v Bodega Olegario Falcón Piñeiro, 90 AD3d 403, 404 [1st Dept 2011]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary transacts business in New York and the claim arises from that transaction; negotiating or making a contract while physically present in New York generally qualifies.
USHA Holdings, LLC v. Franchise India Holdings Ltd. · filed 2014-03-27(a)(1)
According to New York law, a defendant’s physical presence in the state at the time of the negotiation, making, or execution of a contract generally justifies a finding of purposeful availment and allows a court to exercise personal jurisdiction under CPLR § 302(a)(1) in a breach of contract case such as this one.Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction based on negotiating a partnership agreement in New York when the record supports that the negotiations occurred there.
New Media Holding Co. v. Kagalovsky · filed 2014-04-29(a)(1)
This framework has not changed since this case was last before us on appeal. ... At any rate, despite defendants’ arguments to the contrary, the testimony in the record supports that conclusion; although Gusinski did not recall the details of the first meeting that he had with Kagalovsky, he did recall that later negotiations regarding the partnership took place in New York.Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction over a nondomiciliary law firm based on purposeful New York activities connected to the claim.
CELLINO & BARNES, P.C. v. MARTIN, LISTER & ALVAREZ, PLLC · filed 2014-05-02(a)(1)
We further conclude that defendant is subject to long-arm jurisdiction under CPLR 302 (a) (1), which provides that New York has jurisdiction over a nondomiciliary who “transacts any business within the state or contracts anywhere to supply goods or services in the state.”Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between a nondomiciliary’s New York business activity and the claim asserted.
Mejia-Haffner v. Killington, Ltd. · filed 2014-07-30(a)(1)
Based on the allegations in the complaint and the statements in the injured plaintiffs affidavit, there is no substantial relationship between Killington’s maintenance of a website through which a person in New York could purchase services and the alleged tort that occurred. ... Thus, Killington is not subject to long-arm jurisdiction under CPLR 302 (a) (1).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant’s New York business contacts give rise to the claim.
Schutte Bagclosures Inc. v. Kwik Lok Corp. · filed 2014-09-29(a)(1)
Taken together, Kwik Lok’s factually-supported allegations as to Schutte BV’s contacts with New York are sufficient to exercise jurisdiction over Schutte BV under § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful business activity in New York; the defendant’s contacts through email, websites, and telephone did not establish it.
Whitcraft v. Runyon · filed 2014-12-10(a)(1)
The nature and quality of the defendant’s alleged contacts with New York do not demonstrate that he purposefully transacted business within this state (see Daniel B. Katz & Assoc. Corp. v Midland Rushmore, LLC, 90 AD3d 977 [2011]; Kimco Exch. Place Corp. v Thomas Benz, Inc., 34 AD3d 433, 434 [2006]).Read the full opinion on CourtListener →
CPLR 302(a)(1) requires a substantial relationship between the defendant’s New York business transaction and the plaintiff’s claims.
CIANCIOLA, ESTHER L. v. A.O. SMITH WATER PRODUCTS CO. · filed 2013-11-08(a)(1)
Even assuming, arguendo, that defendant transacted business in New York, we conclude that plaintiff did not establish the requisite substantial relationship between defendant’s transaction of business and plaintiff’s claims against defendant (see Kruetter v McFadden Oil Corp., 71 NY2d 460, 467; Holness v Maritime Overseas Corp., 251 AD2d 220, 224).Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between the claim and the defendant’s New York business activity; an indirect connection is insufficient.
Reich v. Lopez · filed 2014-08-18(a)(1)
The “arising out of’ requirement for personal jurisdiction under § 302(a)(1) is not the same as merely being indirectly “related to” the transacted business.Read the full opinion on CourtListener →
CPLR 302(a)(1) requires a substantial relationship between the defendant’s New York business activity and the claim asserted.
Pichardo v. Zayas · filed 2014-11-12(a)(1)
Here, the relationship between the causes of action asserted in the complaint and the Zayases’ activities within New York were too insubstantial to warrant a New York court’s exercise of personal jurisdiction over them pursuant to CPLR 302 (a) (1).Read the full opinion on CourtListener →
Under CPLR 302(a)(1), the business transacted in New York must be substantially related to the claim for personal jurisdiction to exist.
Gottlieb v. Merrigan · filed 2014-07-03(a)(1)
Contrary to defendants’ argument, plaintiff has also, at the least, raised an issue of fact regarding whether his action for fees is substantially related to the negotiation of the workers’ compensation lien.Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction based on one purposeful New York transaction when the transaction has a substantial relationship to the claim, even if the defendant never enters the state.
Paradigm Marketing Consortium, Inc. v. Yale New Haven Hospital, Inc. · filed 2015-01-21(a)(1)
Proof of one transaction in New York is sufficient to invoke jurisdiction, even though the defendant never enters New York, as long as the defendant’s activities here were purposeful and there is a substantial relationship between the transaction and the claim asserted (see Kreutter v McFadden Oil Corp., 71 NY2d 460, 467 [1988]; see also MPG Assoc., Inc. v Roeske, 112 AD3d 590, 591 [2013]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant purposefully transacts business in New York and the claim has an articulable nexus to that transaction.
Wilson v. Dantas · filed 2015-04-14(a)(1)
We find that, because plaintiff's claims arise from defendants' transaction of business in New York, CPLR 302(a)(1) confers personal jurisdiction over defendants.Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction over an out-of-state defendant based on business transacted in New York when the defendant’s contacts satisfy the transacting-business test.
Vista Food Exchange, Inc. v. Champion Foodservice, LLC · filed 2015-08-18(a)(1)
Applying the same four factor test for determining whether an out-of-state defendant transacted business in New York under § 302(a)(1), jurisdiction over Champion also fails.Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful activity in New York that bears a substantial relationship to the claim.
Okeke v. Momah · filed 2015-10-07(a)(1)
Here, the respondents established, prima facie, that they did not conduct any purposeful activities in New York which bore a substantial relationship to the subject matter of this action, so as to avail themselves of the benefits and protections of this State’s laws.Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim based on licensing through a New York clearinghouse to arise from a work covered by that licensing arrangement.
Wallert v. Atlan · filed 2015-10-26(a)(1)
These cases, however, are inapposite, for a simple reason: The FAC does not allege that the Starlight composition, the song at issue in Wallert’s copyright infringement claims, was among those included in his alleged licensing contract with ASCAP (or another New York based clearinghouse).Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction when the claim has a substantial relationship to the defendant’s New York business transaction, even if that transaction did not cause the plaintiff’s injury.
Cohen v. BMW Investments L.P. · filed 2015-10-30(a)(1)
Although BMW’s transactions with Teplen and Roth in New York did not cause Cohen’s injury, they are a but for cause of this litigation. This provides a sufficient relationship between the claim and the defendant’s contacts with New York.Read the full opinion on CourtListener →
CPLR 302(a)(1) requires a prima facie showing that the defendant purposefully transacted business in New York to establish personal jurisdiction on that basis.
Shatara v. Ephraim · filed 2016-03-30(a)(1)
No evidence was presented that DiGiovanni purposefully availed herself of the privilege of conducting activities in New York. Accordingly, the court erred in determining that it was proper for it to exercise personal jurisdiction over DiGiovanni pursuant to CPLR 302 (a) (1).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer personal jurisdiction over defendants who did not transact business in New York.
Jacobs v. 201 Stephenson Corp. · filed 2016-04-06(a)(1)
Therefore, the defendants did not “transact business” in this State and were not subject to the “long arm” jurisdiction provision of CPLR 302 (a) (1).Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction over a nondomiciliary only when the claim has an articulable nexus or substantial relationship to its New York business activity.
Fernandez v. DaimlerChrysler, A.G. · filed 2016-10-12(a)(1)
Since the plaintiff failed to demonstrate, prima facie, that the causes of action asserted in the complaint arose from any of Daimler’s activities in New York, the Supreme Court was not authorized to exercise personal jurisdiction over Daimler pursuant to CPLR 302 (a) (1).Read the full opinion on CourtListener →
CPLR 302(a)(4) does not confer personal jurisdiction based on a nonresident’s New York property ownership when the claim does not arise from that ownership.
Hopstein v. Cohen · filed 2016-10-19(a)(4)
The fact that the appellant may have owned property in New York at some time does not establish jurisdiction under CPLR 302 where, as here, the plaintiffs’ negligence cause of action against the defendant did not arise out of such ownership of property, but rather, the operation of his vehicle in New Jersey (see CPLR 302 [a] [4]; see generally Johnson v Ward, 4 NY3d 516, 519 [2005]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary that sells tickets in New York and receives the proceeds, even when its trains operate outside the state.
Wong v. Southern Pennsylvania Transportation Authority · filed 2017-01-04(a)(1)
Clearly, by virtue of these sales and the realization of the profits, SEPTA is transacting business in New York. ... Accordingly, the business they transact here in New York brings SEPTA under the jurisdiction of our courts.Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction over a foreign defendant that transacts business in New York when the claim arises from that business.
Motors Liquidation Co. ex rel. Wilmington Trust Co. v. JPMorgan Chase Bank, N.A. (In re Motors Liquidation Co.) · filed 2017-02-16(a)(1)
For specific jurisdiction under CPLR § 302(a)(1), one prong of New York’s long arm statute, the Court may exercise jurisdiction over a foreign defendant who “transacts any business within the state” provided that the cause of action arises therefrom.Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between the defendant’s New York contacts and the plaintiff’s claims to support personal jurisdiction.
Latimore v. Fuller · filed 2015-04-14(a)(1)
Plaintiff neither established that New York courts may exercise jurisdiction over defendant Kim nor made a sufficient start to warrant jurisdictional discovery, since she failed to show that the few contacts Kim had with New York are substantially related to plaintiffs claims (see CPLR 302 [a] [1]; Kreutter v McFadden Oil Corp., 71 NY2d 460, 467 [1988]; Peterson v Spartan Indus., 33 NY2d 463, 467 [1974]).Read the full opinion on CourtListener →
Section 302(a)(1) and (4) require a connection between the claim and the defendant’s New York business activity or property ownership.
Matter of CDR Créances S.A.S. v. First Hotels & Resorts Invs., Inc. · filed 2016-06-21(a)(1), (a)(4)
CDR seeks to assert jurisdiction over First Hotels based on CPLR 302 (a) (1) and (4). However, under the circumstances presented here, that section of the CPLR does not confer personal jurisdiction over First Hotels.Read the full opinion on CourtListener →
CPLR 302 requires a substantial nexus between a nondomiciliary’s New York business activities and the claim arising from them.
D&R Global Selections, S.L. v. Bodega Olegario Falcon Pineiro · filed 2015-05-14
However, there is no substantial nexus between plaintiffs claim for unpaid commissions in connection with the sales of that wine, pursuant to an agreement made and performed wholly in Spain, and those promotional activities (see McGowan, 52 NY2d at 268).Read the full opinion on CourtListener →
Section 302(a) requires a connection between a defendant’s business transactions in New York and the claims asserted to establish personal jurisdiction.
Wang v. LSUC · filed 2016-03-10(a)
As determined by the lower court, plaintiff, who bears the burden of showing jurisdiction upon a motion to dismiss pursuant to CPLR 3211 (a) (8), failed to demonstrate that the defendants transacted significant business in New York, and to the extent that any business was transacted, plaintiff failed to demonstrate any connection to the claims asserted in this case (CPLR 302 [a]; O’Brien v Hackensack Univ. Med. Ctr., 305 AD2d 199, 200 [1st Dept 2003]; Paterno v Laser Spine Inst., 24 NY3d 370, 376 [2014]).Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between a nondomiciliary’s purposeful New York business activity and the claim; an unrelated employment relationship does not establish personal jurisdiction.
Chen v. Lu · filed 2016-11-09(a)(1)
Here, the sole purposeful activity cited by the plaintiffs in support of their argument that the defendant is subject to personal jurisdiction pursuant to CPLR 302 (a) (1) is the employment relationship between Crystal Window and the defendant. However, the alleged wrongdoing upon which the complaint primarily is based occurred during the defendant’s employment with Huai’an Crystal, a Chinese company, prior to any employment with Crystal Window.Read the full opinion on CourtListener →
Telephone and email communications with a New York office about a contemplated business association centered abroad do not, by themselves, constitute transacting business in New York under § 302(a)(1).
Ripplewood Advisors, LLC v. Callidus Capital SIA · filed 2017-06-22(a)(1)
The telephone and email communications between the Latvian defendants and plaintiff’s office in New York, concerning a contemplated association in the acquisition of a Latvian bank (with no presence in New York) undergoing privatization, do not suffice to constitute the transaction of business in New York.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nonresident who transacts business in New York when the claims have a substantial relationship to those activities.
Hall v. City of Buffalo · filed 2017-06-30(a)(1)
As the principal and sole shareholder of NHJB, which operated a bar in New York, Habib transacted business in New York within the meaning of CPLR 302 (a) (1) ... and we conclude that there is a substantial relationship between plaintiffs claims and Habib’s activities in New York (see generally Licci v Lebanese Can. Bank, SAL, 20 NY3d 327, 339 [2012]; Fischbarg v Doucet, 9 NY3d 375, 384 [2007]).Read the full opinion on CourtListener →
Section 302(a)(1) requires the claim to arise from business transacted in New York; a tangential relationship with a New York clearinghouse does not establish personal jurisdiction.
Artists Rights Enforcement Corp. v. Jones · filed 2017-07-18(a)(1)
Because AREC’s claim does not “arise from” any actions taken by EMI or BMI on behalf of Jones in New York, the Court is persuaded that it lacks personal jurisdiction over Jones.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claims have a sufficiently close connection to that business.
Flame-Spray Industries Inc. v. GTV Automotive GmbH · filed 2017-08-14(a)(1)
Here, plaintiffs claims, whether sounding in contract or tort, all arise from the business relationship between it and defendants. As such, the Court finds that there is a sufficiently close connection between the acts constituting the transacting of business under § 302(a)(1) and plaintiffs claims in this action to allow the exercise of personal jurisdiction over defendants.Read the full opinion on CourtListener →
Section 302(a)(1) supports personal jurisdiction where an employment agreement was substantially negotiated in New York and the employee regularly traveled there to perform duties under it.
Popescu, George-Alex v. Forexware, LLC · filed 2018-02-20(a)(1)
The motion court correctly determined that personal jurisdiction exists over defendant pursuant to CPLR 302(a)(1). The complaint, as supplemented by plaintiff's affidavit and the contracts at issue, alleges that defendant breached an employment agreement that was substantially negotiated in New York, where defendant's principal place of business was located, and that while plaintiff may have been based in Boston, he regularly traveled to New York in discharge of his duties pursuant to the employment agreement, including reporting to defendant's chair and controlling shareholder based in New York ( see Scheuer v Schwartz , 42 AD3d 314, 316 [1st Dept 2007]; Katz Agency v Heftel Broadcasting Corp. , 56 AD2d 758, 759 [1st Dept 1977]; Fischbarg v Doucet , 9 NY3d 375, 385 [2007]).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer personal jurisdiction when a nonresident's communications with New York parties are incidental to litigation outside the state.
Prout v. Anne C. Vladeck & Vladeck, Raskin & Clark, P.C. · filed 2018-09-25(a)(1)
His "connection to New York [wa]s entirely incidental, not purposeful," id. at *4, and it was therefore insufficient to support this Court's jurisdiction under 302 (a) (1).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over an individual who purposefully conducts business in New York on an employer’s behalf when that business is substantially related to the claims.
Newmont Mining Corp. v. Anglogold Ashanti Ltd. · filed 2018-09-30(a)(1)
Under the circumstances here, the Court concludes that Chancellor transacted business under § 302(a)(1) when he purposefully traveled to New York and, while in the state, provided legal advice to his employer, assisted with the negotiation and finalization of terms in an agreement that specifically invokes New York law, and attended the closing for that very transaction.Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim to arise from business transacted in New York; booking a hotel there is too remote from an alleged assault at the hotel abroad.
DeLorenzo v. Viceroy Hotel Group LLC · filed 2018-11-21(a)(1)
Under CPLR § 302(a)(1), a court may exercise personal jurisdiction over a defendant if (1) the defendant “transacts any business” in New York and (2) the plaintiff’s cause of action arises from such a transaction. ... But DeLorenzo’s claims arise not out of her hotel contract with the Ricketts Defendants but rather out of an alleged sexual assault in Anguilla.Read the full opinion on CourtListener →
Section 302(a)(1) requires evidence that the defendant purposefully transacted business in New York and that those transactions are connected to the claim.
Concotilli v. Brown · filed 2019-01-03(a)(1)
The court correctly found that it lacked personal jurisdiction over defendant pursuant to CPLR 302(a)(1). Plaintiff failed to provide any evidence that defendant purposefully transacts business within the state, as required by statute, or that there is a connection between defendant's transactions and the alleged defamatory statement at issue ( SPCA of Upstate NY, Inc. v American Working Collie , 18 NY3d 400, 404 [2012]; Copp v Ramirez , 62 AD3d 23, 28 [1st Dept 2009], lv denied 12 NY3d 711 [2009]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a claim arises from the defendant’s business contacts with New York, including an ongoing repair engagement and visits to the state.
New York Helicopter Charter, Inc. v. Borneman · filed 2019-01-17(a)(1)
Plaintiff made a sufficient showing under CPLR 302(a)(1) to establish that New York courts have jurisdiction over Keystone ( see Kreutter v McFadden Oil Corp. , 71 NY2d 460, 467 [1988]; Robins v Procure Treatment Ctrs., Inc. , 157 AD3d 606, 607 [1st Dept 2018]). The evidence reflects that the claim of negligence in Keystone's maintenance, installation, and turbine repair arises out of Keystone's contacts with New York ( see Helicopteros Nacionales de Colombia, S.A. v Hall , 466 US 408, 414 [1984]). Keystone chose to do business with a New York resident when it was hired to continuously repair the turbine at issue, and made visits to New York to observe the effect of the engine's failure and inspect the engine ( see D & R Global Selections, S.L. v Bodega Olegario Falcon Pineiro , 29 NY3d 292, 298-299 [2017]; Scheuer v Schwartz , 42 AD3d 314, 316 [1st Dept 2007]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claims arise directly from that business.
XpresSpa Holdings, LLC v. Cordial Endeavor Concessions of Atlanta, LLC · filed 2019-04-11(a)(1)
The allegations that Edwards transacted business in New York and that the claims arose directly out of that business are sufficient to support a finding of personal jurisdiction at this stage ( see CPLR 302[a][1]).Read the full opinion on CourtListener →
Section 302(a)(1) treats business solicitations, communications, and negotiations as transactions of business that can support personal jurisdiction.
Construction Directions, LLC v. Phoenix Building Corp. · filed 2019-05-21(a)(1)
The case law supports that such business solicitations, communications, and negotiations constitute “business transactions” and are sufficient to satisfy CPLR Section 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction when a defendant transacts business in New York and the claims have a sufficient connection to those transactions.
Hansen Realty Dev. Corp. v. Sapphire Realty Group, LLC · filed 2019-06-11(a)(1)
Jia is subject to this court's jurisdiction pursuant to our long arm statute (CPLR 302[a][1]). Jia's attendance at and participation in multiple business meetings in New York, one of which was held during the alleged unauthorized vacation, concerning the real estate development project, is sufficient to establish that he was transacting business in New York ( see Kreutter v McFadden Oil Corp. , 71 NY2d 460, 467, 470 [1988]; Home Box Off. v Baum , 172 AD2d 222, 223 [1st Dept 1991]). Moreover, there was a sufficient connection between Jia's business transactions in New York and the causes of action alleged in the complaint to confer jurisdiction over him pursuant to CPLR 302(a)(1) ( see generally Pramer S.C.A. v Abaplus Intl. [*2]Corp. , 76 AD3d 89, 95 [1st Dept 2010]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant purposefully transacts business in New York and the claim arises from that transaction.
Piccoli v. Cerra, Inc. · filed 2019-07-17(a)(1)
In opposition to the defendants' motion to dismiss for lack of personal jurisdiction, the plaintiffs made a prima facie showing that the defendants transacted business in New York and that the plaintiffs' cause of action for breach of contract arises from that transaction so as to establish that jurisdiction is proper under CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim to arise from New York business activity; transporting cargo through New York alone does not establish that connection.
Hartford Fire Insurance Co. v. Maersk Line · filed 2019-09-17(a)(1)
Physical transport through New York, standing alone, does not demonstrate that the claim “aris[es] from” a contract “to supply goods or services in the state . . . .” CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a New York business transaction that gives rise to the claim; an accessible website and unrelated recruiting efforts do not establish jurisdiction.
Camacho v. Emerson College · filed 2019-10-15(a)(1)
Camacho has failed to make a prima facie case that any transaction Emerson conducted in New York gave rise to his claims. Accordingly, this Court does not have personal jurisdiction under C.P.L.R. § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a plaintiff’s claim to arise from the defendant’s New York business transaction to support personal jurisdiction.
Camacho v. Northeastern University · filed 2019-10-15(a)(1)
Camacho has failed to make a prima facie case that any transaction Northeastern conducted in New York gave rise to his claims. Accordingly, this Court does not have personal jurisdiction under C.P.L.R. § 302(a)(1).Read the full opinion on CourtListener →
CPLR 302(a)(1) permits specific jurisdiction over a nonresident only when the claim arises from the nonresident's transaction of business in New York.
Fekah v. Baker Hughes Inc. · filed 2019-10-17(a)(1)
That statute provides for specific jurisdiction over nonresidents only to the extent the causes of action arise from the nonresident transacting business within the state. Even if defendant's recruitment of employees here, designating a registered agent here, and maintaining active registration to do business here, did constitute the transaction of business in this state, plaintiffs fail to show their claims arise from them.Read the full opinion on CourtListener →
Section 302(a)(1) requires a relationship between the New York business transaction and the claim, but does not require a causal link to the plaintiff’s injury.
Clean Coal Technologies, Inc. v. Leidos, Inc. · filed 2019-11-13(a)(1)
All that the “arising from” prong requires, according to Licci, is “a relatedness between the transaction and the legal claim such that the latter is not completely unmoored from the former.” Licci, 20 N.Y.3d at 339. “A causal link between the defendant’s New York business activity and a plaintiff’s injury” is not required. Licci ex rel. Licci v. Lebanese Canadian Bank, SAL, 737 F.3d 161, 168 (2d Cir. 2013).Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction when a defendant transacts business in New York and the claim has an articulable nexus to that business.
Katsoolis v. Cruz · filed 2019-11-15(a)(1)
Regarding the first prong, both Defendants Jackson and Brezer transacted business in New York: they purposefully installed Plaintiffs as the Liquid entities’ New York presence, and collaborated with Plaintiffs remotely to acquire financing and projects for the Liquid entities in the New York area. ... There is also an articulable nexus between Defendants Jackson and Brezer’s New York business activity and the hostile work environment claims.Read the full opinion on CourtListener →
Section 302(a)(1)’s nexus requirement is satisfied when alleged employment decisions concern a plaintiff employed in New York.
Williams v. PMA Companies, Inc. · filed 2019-11-25(a)(1)
Because Plaintiff was employed in New York at the time of these alleged actions, Plaintiff has articulated a sufficient nexus to satisfy CPLR § 302(a)(1)’s second requirement.Read the full opinion on CourtListener →
Section 302(a)(1) does not treat a New York law firm’s mailing address as transacting business in New York for personal jurisdiction.
Bentivoglio v. Event Cardio Group Inc. · filed 2019-11-27(a)(1)
Merely listing a New York law firm as a place that ECGI would accept mail does not support a finding that ECGI was “transacting business” in New York sufficient to serve as a basis for personal jurisdiction.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary purposefully uses a New York bank account for transactions from which the plaintiff's claim arises.
Skutnik v. Messina · filed 2019-12-04(a)(1)
Here, in opposition to the defendant's motion, the plaintiff made a prima facie showing that the defendant transacted business in New York and that the plaintiff's claims arose from those transactions, so as to establish jurisdiction pursuant to CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) and (a)(4) require a claim to arise from the defendant’s New York activities or property, respectively; unrelated sales or property do not establish jurisdiction.
Paciotti S.p.A. v. Dellamoda, Inc. · filed 2019-12-16(a)(1), (a)(4)
Jurisdiction under § 302(a)(1) attaches only if the cause of action “arises from” the defendant’s in-state activities. ... Again, the property relied on must serve as the basis for the plaintiff's cause of action. ... Therefore, jurisdiction does not attach under CPLR § 302(a)(4).Read the full opinion on CourtListener →
CPLR 302(a)(1) requires a defendant’s New York business activity to relate to the plaintiff’s claims; solicitation after the alleged injury does not establish that connection.
Robins v. Procure Treatment Ctrs., Inc. · filed 2020-01-02(a)(1)
Plaintiff did not meet her ultimate burden of establishing that Drs. Tsai and Chon, New Jersey doctors who treated her in New Jersey, projected themselves, on their own initiative, into [*2]New York to engage in a sustained and substantial transaction of business related to her claims, such that specific long-arm jurisdiction existed over them under CPLR 302(a)(1) ( see William v Beemiller Inc., 33 NY3d 523 [May 9, 2019]; Paterno v Laser Spine Inst. , 24 NY3d 370, 372 [2014]; O'Brien , 305 AD2d at 200-201). Plaintiff submitted evidence that they participated in radio interviews intended to solicit New York residents, but those interviews occurred after the alleged malpractice and therefore, do not relate to plaintiff's claims ( see Paterno , 24 NY3d at 379).Read the full opinion on CourtListener →
Section 302(a)(1) requires the defendant to have transacted business in New York and the claim to arise from that activity.
McConney v. Amtrak · filed 2020-01-28(a)(1)
Because the complaint does not include factual allegations sufficient to meet either prong of the Sole test, the court does not have specific personal jurisdiction over Amtrak under CPLR $ 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful business activity in New York; a contract with a New York corporation alone does not satisfy that requirement.
MTS Logistics, Inc. v. Innovative Commodities Group, LLC · filed 2020-02-26(a)(1)
MTS has not alleged that Innovative in any way purposefully availed itself of the laws of New York. That Innovative entered into a contract with MTS, a New York corporation, is not purposeful availment.Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between business transacted in New York and the claim; retaining New York counsel to defend an unrelated claim does not satisfy it.
Luctama v. Knickerbocker · filed 2020-03-30(a)(1)
That defendant retained a New York attorney to defend against plaintiffs’ claims does not amount to business transacted in New York that is substantially related to plaintiffs’ claims.Read the full opinion on CourtListener →
CPLR 302(a)(1) does not confer long-arm jurisdiction over out-of-state medical providers merely because a patient returns to New York and fills and takes prescribed medicine there.
Castro v. Pfizer, Inc. · filed 2020-05-20(a)(1)
The plaintiff contends that New York has long-arm jurisdiction over the NJ medical providers, on the ground that they supplied "services in th[is] state" (CPLR 302[a][1]). This contention lacks merit. The medical treatment in question occurred in New Jersey. The connection of the medical providers with New York is that they discharged a patient under their care to her home in New York, where she filled prescriptions allegedly provided by them, and took the medicine prescribed. The alleged conduct of the NJ medical providers did not constitute transacting business in this state ( see Paterno v Laser Spine Inst. , 24 NY3d 370, 375; Etra v Matta , 61 NY2d 455).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary transacts business in New York and those activities have an articulable nexus to the claims.
Matter of Renren Inc. Derivative Litig. v. XXX · filed 2020-05-20(a)(1)
Here, the plaintiffs have met their burden in making a prima facie showing that Renren transacted business in New York for the purposes of CPLR § 302 (a)(1) in connection with (1) the IPO on the NYSE, (2) the Separation, (3) the Private Placement, and (4) the Cash Dividend, and that such activities have an articulable nexus with the claims asserted in the Amended Complaint.Read the full opinion on CourtListener →
An alleged New York retail sale of a defendant’s product can establish purposeful availment under § 302(a)(1) at the pleading stage when the claim arises from that product.
New York Central Mutual Fire Insurance Company v. Icon Health & Fitness, Inc. · filed 2020-06-01(a)(1)
Assuming Plaintiff’s factual allegations are true, the treadmill made by Defendant that caused the damage to the Premises was sold at a Sears in New York in 2002, and that sale of the treadmill is sufficient to establish at the pleadings stage that Defendant purposely availed itself of the privilege of conducting activities within New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between the defendant’s New York business transaction and the claim; buying a ticket in New York does not establish jurisdiction over an injury elsewhere merely because the purchase led to the trip.
Simmons v. National Railroad Passenger Corporation · filed 2020-06-03(a)(1)
The alleged breach of the “contract of safe passage” occurred in Washington, D.C., and although the purchase of the train ticket in New York is causally related to that injury, the injury is not “substantially related to,” nor does it “arise from,” the purchase.Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction when a defendant purposefully transacts business in New York and the transaction bears a substantial relationship to the matter at issue.
Matter of James v. iFinex Inc. · filed 2020-07-09(a)(1)
Under CPLR 302(a)(1), New York's long-arm jurisdiction statute, "proof of one transaction in New York is sufficient to invoke jurisdiction, even though the defendant never enters New York, so long as the defendant's activities here were purposeful and there is a substantial relationship between the transaction and the claim asserted" (Deutsche Bank Sec., Inc. v Montana Bd. of Invs. , 7 NY3d 65, 71 [2006][internal quotation marks omitted], cert denied 549 US 1095 [2006]). ... Accordingly, petitioner has demonstrated that respondents' activities in New York were sufficiently related to the subjects of petitioner's investigation to satisfy specific personal jurisdiction for the purposes of GBL 354.Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction when claims arise from New York business contacts during which misappropriated information was used.
Pictometry International Corp. v. Air America Flight Center LLC · filed 2019-08-20(a)(1)
In other words, under the applicable laws, an employee’s misappropriation of a trade secret is not complete until the trade secret is wrongfully disclosed or used. Here, the use is alleged to have occurred during Sandhills’ performance of services for Pictometry. Under these circumstances, the Court finds a prima facie basis for specific jurisdiction pursuant to CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between a defendant’s purposeful New York activity and the asserted claim.
Best v. Guthrie Med. Group, P.C. · filed 2019-08-22(a)(1)
Regarding long-arm jurisdiction under CPLR 302 (a) (1), assuming, arguendo, that the individual defendants purposefully availed themselves of the privilege of conducting activity in New York, we conclude that there is no evidence that there was a " substantial relationship' " between that alleged activity and " the claim asserted' " by plaintiff ( Deutsche Bank Sec., Inc. , 7 NY3d at 71).Read the full opinion on CourtListener →
CPLR 302(a)(1) requires New York contacts to be substantially related to the dispute to support personal jurisdiction.
Trimarco v. Edwards · filed 2020-05-07(a)(1)
The court also properly found no jurisdiction under CPLR 302(a)(1). The alleged New York contacts were not substantially related to the loan agreement and dispute over payment at issue here to support the exercise of personal jurisdiction ( Coast to Coast Energy, Inc. v Gasarch , 149 AD3d 485, 486 [1st Dept 2017]).Read the full opinion on CourtListener →
Section 302(a)(1) requires an articulable nexus or substantial relationship between the claim and the defendant’s New York business activity.
Katsoolis v. Cruz · filed 2019-09-27(a)(1)
Section 302(a)(1) furthermore requires showing an “articulable nexus, or a substantial relationship, between the claim[s] asserted and the actions that occurred in New York.” Best Van Lines, 490 F.3d at 246. This nexus exists for all surviving claims.Read the full opinion on CourtListener →
Section 302 does not provide specific jurisdiction over a claim arising from an out-of-state accident when no injuries are alleged to relate to New York.
Carson v. Western Express, Inc. · filed 2019-11-14
Specific jurisdiction does not apply in this case, as the motor vehicle accident took place in Pennsylvania and Carson alleges no injuries related to the State of New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires a connection between the business transacted in the forum and the claim asserted.
Perrone v. Catamount Ski Resort, LLC · filed 2020-05-19(a)(1)
Plaintiff also fails to establish that specific jurisdiction would exist in the Southern District, because Plaintiff has not alleged that her “cause of action arises from . . . a business transaction [in this District],” Biro, 2012 WL 3262770, at *9 (citing Best Van Lines, Inc. v. Walker, 490 F.3d 239, 246 (2d Cir. 2007)), nor that the alleged tort occurred here.Read the full opinion on CourtListener →
Section 302(a)(1) authorizes personal jurisdiction over a defendant who transacts business in New York or contracts anywhere to supply goods or services in New York.
Blockchange Ventures I GP, LLC v. Blockchange, Inc. · filed 2021-01-29(a)(1)
Additionally, Plaintiff has not made a prima facie showing of jurisdiction under New York CPLR 302(a)(1). See Jazini v. Nissan Motor Co., 148 F.3d 181, 184 (2d Cir. 1998). Section 302(a)(1) authorizes jurisdiction over a defendant who “transacts business within the state or contracts anywhere to supply goods or services in the state.” ... Moreover, the mere accessibility of Defendant’s website and its use of cookies is insufficient to constitute transacting business in New York. ... I therefore lack personal jurisdiction over Defendant.Read the full opinion on CourtListener →
Section 302(a)(1) permits New York courts to exercise personal jurisdiction over a non-domiciliary who transacts business in New York when the claim arises from that transaction and jurisdiction comports with due process.
Matter of Renren, Inc. · filed 2021-03-18(a)(1)
The court properly determined that it had personal jurisdiction over defendant Renren, Inc., its subsidiary, and its directors and majority shareholders, since plaintiffs established that those defendants transacted business in New York for the purposes of CPLR 302(a)(1) in connection with the transactions at issue, and that jurisdiction comported with due process ( see Licci v Lebanese Can. Bank, SAL , 20 NY3d 327, 339-340 [2012]). Contrary to defendants' arguments, plaintiffs' causes of action arise from defendants' New York contacts, since plaintiffs demonstrated that, in light of all the circumstances, there is an articulable nexus or substantial relationship between the transactions and the claim asserted ( id. ).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business or contracts to supply goods or services in New York and the claim arises from that transaction.
Lowy v. Chalkable, LLC · filed 2020-08-12(a)(1)
In order to determine whether personal jurisdiction exists under CPLR 302(a)(1), the statute relied on by the plaintiffs, the court must determine (1) whether the defendant has purposefully availed itself of the privilege of conducting activities in New York by either transacting business or contracting to supply goods or services there, and (2) whether the claim asserted arises from that business transaction or from the contract to supply goods or services ( see D & R Global Selections, S.L. v Bodega Olegario Falcon Pineiro , 29 NY3d 292, 297; Qudsi v Larios , 173 AD3d 920, 922-923).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claim arises from that business.
Brown v. National Bank of Pakistan · filed 2021-01-13(a)(1)
The exercise of personal jurisdiction is also consistent with New York’s long arm statute, CPLR 302(a)(1) (personal jurisdiction is proper where (1) the defendant “ ‘transacted business within the state; and (2) the claim asserted ... arise[s] from that business activity’).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant’s New York activities are purposeful and substantially related to the claims asserted.
J.G. Jewelry Pte. Ltd. v. TJC Jewelry, Inc. · filed 2021-05-04(a)(1)
Similarly, Supreme Court properly found that personal jurisdiction over defendants exists ( see CPLR 302[a][1]), since the allegations in the amended complaint, as well as the affidavits submitted by defendants' principals, demonstrate that defendants' "activities here were purposeful and there [was] a substantial relationship between the transaction[s] and the claim[s] asserted" ( Fischbarg v Doucet , 9 NY3d 375, 380 [2007]; see C. Mahendra (NY) LLC v National Gold & Diamond Ctr., Inc. , 125 AD3d 454, 457-458 [1st Dept 2015]; D&R Global Selections, S.L. v Bodega Olegario FalcÓn PiÑeiro , 90 AD3d 403, 405 [1st Dept 2011]; Courtroom Tel. Network v Focus Media , 264 AD2d 351, 353 [1st Dept 1999]).Read the full opinion on CourtListener →
CPLR 302(a)(1) requires a non-domiciliary to purposefully transact business in New York; contacts concerning a one-time sale for use abroad did not satisfy that requirement here.
State of New York v. Vayu, Inc. · filed 2021-06-24(a)(1)
Nonetheless, in reviewing the parties' interactions as summarized above, we agree with Supreme Court that defendant did not "purposefully avail[] itself of 'the privilege of conducting activities within [New York],' by . . . transacting business in New York," thus invoking the benefits and protections of New York's laws ( D & R Global Selections, S.L. v Bodega Olegario Falcon Pineiro , 29 NY3d at 297, quoting Rushaid v Pictet & Cie , 28 NY3d at 323).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary whose New York business transactions give rise to the claims.
Henao v. Parts Authority, LLC · filed 2021-07-02(a)(1)
The TAC alleges facts that satisfy the transacting business provision of New York’s long-arm statute for exercising personal jurisdiction over Browne.Read the full opinion on CourtListener →
Section 302(a)(1)’s substantial nexus requirement can be satisfied by allegations linking injuries from falsely advertised goods to the defendant’s purported New York business transaction.
Davey v. PK BENELUX B.V. d/b/a/ LUCOVITAAL · filed 2021-08-06(a)(1)
These allegations are sufficient to allege a substantial nexus between plaintiff’s claims and defendant’s purported in-state transaction of business under CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim to arise from the defendant’s business transactions in New York.
Mensah v. Boeing Corporation · filed 2023-09-06(a)(1)
Mensah has not alleged any facts to suggest that his cause of action arises from any transactions made by Boeing in New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim to arise from the defendant’s New York business activity; maintaining correspondent accounts is insufficient when no transaction through them gave rise to the claim.
Moussaoui v. Bank of Beirut and The Arab Countries · filed 2023-09-14(a)(1)
Critically, moreover, the instant claims do not arise out of any specific transaction or business activity conducted by the defendants in New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires a nexus between the action and the defendant's New York business transaction.
Karam v. Karam · filed 2021-09-28(a)(1)
Defendant's various business interests and indirect ownership of real property in New York cannot serve as bases for jurisdiction under CPLR 302(a)(1) and (a)(4), since plaintiff failed to articulate the requisite nexus either between the divorce action and any in-state business transaction ( see generally Johnson v Ward , 4 NY3d 516, 519 [2005]) or between the action and defendant's ownership, possession, or use of New York real property ( see Marie v Altshuler , 30 AD3d at 271, 272 [1st Dept 2006]).Read the full opinion on CourtListener →
A claim must arise from business transacted in New York to establish long-arm jurisdiction under § 302(a)(1).
Ladder Capital Fin. LLC v. Portfolio Hotels, LLC · filed 2021-10-14(a)(1)
Nor does Owner allege in the complaint that its claim arose from the transaction of business in New York so as to establish long-arm jurisdiction (CPLR 302[a]; see D&R Global Selections, S.L. v Bodega Olegario Falcon Pineiro , 29 NY3d 292, 297 [2017]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary when a claim directly arises from that person's business transactions in New York.
City of Utica v. Mallette · filed 2021-12-23(a)(1)
Here, the court properly concluded that it had personal jurisdiction over defendant because the City's cause of action directly arose from her business transactions related to the project, including, but not limited to, her personal guarantee of the loans ( see CPLR 302 [a] [1]).Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful business activity in New York; a passive nationwide website and communications about a contract solicited by a New York plaintiff do not establish jurisdiction.
Fanelli v. Latman · filed 2022-02-09(a)(1)
Here, the totality of the circumstances does not provide the plaintiffs with a basis for imposing long-arm jurisdiction over either Latman or CRM pursuant to CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant's prolonged, purposeful business relationship with a New York entity gives rise to the claim.
Global Gaming Philippines, LLC v. Razon, Jr. · filed 2022-03-21(a)(1)
Such a prolonged relationship with a New York entity constitutes “a transaction of business in New York” per CPLR § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) does not treat allegedly defamatory internet content as a transaction of business in New York merely because New Yorkers are likely to read it.
Kingstown Capital Mgt. L.P. v. CPI Prop. Group, S.A. · filed 2022-05-05(a)(1)
However, placing allegedly defamatory content on the internet and making it accessible to the public does not constitute the transaction of business in New York, even when it is likely that the material will be read by New Yorkers ( see Symmetra Pty Ltd. v Human Facets, LLC , 2013 WL 2896876 at *9, 2013 US Dist LEXIS 83428, [SD NY June 13, 2013, No. 12-Civ-8857 (SAS)]).Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful business activity in New York to support personal jurisdiction.
Kingstown Capital Mgt. L.P. v. CPI Prop. Group, S.A. · filed 2022-05-05(a)(1)
Plaintiffs failed to establish personal jurisdiction over defendants under CPLR 302(a)(1), New York's long-arm statute, as they did not show that defendants engaged in purposeful activities in New York, conducted or transacted business in this state, or availed themselves of the benefits of New York law ( see SPCA of Upstate N.Y., Inc. v American Working Collie Assn. , 18 NY3d 400, 404 [2012]; Copp v Ramirez , 62 AD3d 23, 28 [1st Dept 2009], lv denied 12 NY3d 711 [2009]).Read the full opinion on CourtListener →
Maintaining a New York office for substantial marketing activity satisfies Section 302(a)(1)’s requirement that a nondomiciliary transact business in the state.
English v. Avon Prods., Inc. · filed 2022-06-02(a)(1)
However, Shulton's maintenance of its own New York office satisfies the first prong under CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires evidence that the defendant transacted business in New York and that the plaintiff's claim has a nexus to that activity.
Matter of New York City Asbestos Litig. · filed 2022-06-07(a)(1)
CPLR 302(a)(1) requires a two-pronged jurisdictional inquiry; the first inquiry is whether defendant conducted sufficient activities to have transacted business within the state; the second inquiry is whether plaintiff's claims arise from the transactions ( Al Rushaid v Pictet & Cie , 28 NY3d 316, 323 [2016]; Wilson v Dantas , 128 AD3d 176 [1st Dept 2015], affd 29 NY3d 1051, 1052 [2017]). ... Thus, there is no evidence that Crosby transacted sufficient business in the state or that plaintiffs' claims have any nexus to activity Crosby conducted in New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires a showing that out-of-state defendants transacted business in New York to establish personal jurisdiction.
Taxi Medallion Loan Trust III v. Brown Eyes Cab Corp. · filed 2022-06-14(a)(1)
Plaintiffs made a showing that the out-of-state defendants were transacting business within the state, as is necessary to establish personal jurisdiction under CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits long-arm jurisdiction when a defendant purposefully transacts business in New York and those activities are substantially related to the plaintiff’s claims.
4069 Rosen Assoc., LLC v. Tournamentone Corp. · filed 2022-06-14(a)(1)
The court properly found that the nature and quality of defendant's contacts in New York were sufficient to support long-arm jurisdiction under the "transacts . . . business" provision of CPLR 302(a)(1), because defendant's New York activities were purposeful and substantially related to plaintiffs' claims to recover on 11 notes and debentures signed by defendant ( see C. Mahendra [NY], LLC v National Gold & Diamond Ctr., Inc. , 125 AD3d 454, 457 [1st Dept 2015]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nonresident who negotiated a business deal in New York when the lawsuit stems from that deal.
Perl v. Siegelbaum · filed 2023-08-02(a)(1)
Putting aside that he consented to jurisdiction and waived objection to it when he executed the Partnership Agreement as Delphi's initial limited partner as discussed above (which consent and waiver ends the analysis), a court may exercise personal jurisdiction over a non-resident defendant who transacts business within the state if the defendant or commits a tortious act which causes injury to a person or property within the state (CPLR 302[a][1], [3]). ... What matters is that the business deal that he negotiated was negotiated by him in New York and that this lawsuit between the parties stems from the fallout of those New York based agreements which require suit in New York. As such he is subject to jurisdiction and can not claim that New York is an inconvenient forum.Read the full opinion on CourtListener →
Section 302(a)(1) requires purposeful business activity in New York and a claim arising from those contacts; disputed facts about the contacts can preclude summary judgment on personal jurisdiction.
Global Gaming Philippines, LLC v. Razon, Jr. · filed 2023-09-12(a)(1)
These disputes of fact preclude summary judgment in favor of either Plaintiff or the Debtor Defendants on the issue of personal jurisdiction under New York’s long-arm statute.Read the full opinion on CourtListener →
Section 302(a)(1) requires an articulable nexus or substantial relationship between a nondomiciliary’s New York activities and the claim.
Vaval v. Stanco, LLC · filed 2023-09-20(a)(1)
To satisfy the second prong, there must be an "articulable nexus" or a "substantial relationship" between a defendant's New York activities and the cause of action asserted ( Lowy v Chalkable, LLC , 186 AD3d at 592 [internal quotation marks omitted]; see Fernandez v DaimlerChrysler, A.G. , 143 AD3d 765, 767).Read the full opinion on CourtListener →
Section 302(a)(1) requires business transacted in New York and a claim arising from that activity; communications with a New York party alone do not establish jurisdiction.
Kaplan Group Investments, LLC v. A.S.A.P. Logistics LTD · filed 2023-09-25(a)(1)
Based on Plaintiffs’ allegations, it appears that the most relevant provision is C.P.L.R. § 302(a)(1), which requires a showing that “(1) [t]he defendant must have transacted business within the state; and (2) the claim asserted must arise from that business activity.” Sole Resort, S.A. de C.V. v. Allure Resorts Mgmt., LLC, 450 F.3d 100, 103 (2d Cir. 2006). Plaintiffs have not pleaded those elements, however, as they make no allegations in their complaint about the Snooz Defendants’ business in New York.Read the full opinion on CourtListener →
Under Section 302(a)(1)’s transaction-of-business ground, a plaintiff must allege that the defendant transacted business in New York.
Broidy v. Global Risk Advisors LLC · filed 2023-09-26(a)(1)
With respect to Section 302(a)(1), Plaintiffs make no allegations that Courtney Chalker “transact[ed] business” of any kind in New York.Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction when a non-domiciliary purposefully accesses confidential documents on a New York server and the claim arises from that conduct.
Applied Research Investments, LLC v. Lin · filed 2023-09-27(a)(1)
It does not matter that Lin was not physically in New York, because by pleading that Lin downloaded Plaintiff’s confidential documents from New York servers, Plaintiff has pled Lin engaged in purposeful activity with the forum state. ... Lin’s conduct of downloading confidential documents from Plaintiff’s New York server, both while and after he was Plaintiff’s employee, is the exact conduct that Plaintiff bases its claims upon.Read the full opinion on CourtListener →
Section 302(a)(1) requires specific facts about a defendant’s New York business contacts; conclusory allegations of regular business activity do not establish jurisdiction.
Long Side Ventures LLC v. Hempacco Co., Inc. · filed 2023-09-29(a)(1)
Plaintiffs have not provided facts to support the contention that Defendants have regularly conducted business within New York because the Complaint does not describe Defendants’ purported contacts with any specificity. As such, it is improper for the Court to exercise jurisdiction on the basis of § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer personal jurisdiction over a foreign bank when the plaintiff’s claims do not arise from transactions through its New York correspondent accounts.
Kreit v. Byblos Bank S.A.L. · filed 2023-10-22(a)(1)
Without any indicia that Plaintiff’s legal claims are based on transfers effectuated by Defendant’s correspondent accounts, the Court cannot exercise personal jurisdiction over Defendant under New York C.P.L.R. § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer specific jurisdiction based on a lease agreement when the plaintiff’s claim does not arise from a breach related to that agreement.
Medina v. Jet Aviation Holdings USA, Inc. · filed 2023-11-14(a)(1)
The allegations relating to JA Teterboro are insufficient to warrant personal jurisdiction over it pursuant to CPLR 302(a)(1). Plaintiff's claim arises from his striking his head on a parked airplane in the New Jersey hangar JA Teterboro leased to Third Point. Plaintiff's claim does not arise from any breach related to the lease agreement between JA Teterboro and Third Point to bestow specific jurisdiction on JA Teterboro, a foreign defendant ( see Pichardo v Zayas , 122 AD3d 699, 701-702 [2d Dept 2014], lv denied 26 NY3d 905 [2015]; see generally Rushaid v Pictet & Cie , 28 NY3d 316, 323 [2016]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary who transacts business in New York when the claim arises from that conduct.
Proano v. Melrose Home Improvement Corp. · filed 2023-11-17(a)(1)
Plaintiffs do not allege Mr. Gualpa’s citizenship; however, they allege that he transacted business within New York as the owner and manager of Melrose, which is the conduct that gave rise to Plaintiffs’ claims against him. (See Compl. ¶¶ 17–19, 22-23.) Thus, the Court may exercise specific personal jurisdiction over him. See N.Y. C.P.L.R. § 302(a)(1); Ford, 141 S. Ct. at 1025.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary who transacts business in New York when the claims arise from that conduct.
Zabrodin v. Silk 222, Inc. · filed 2023-11-20(a)(1)
Plaintiffs do not allege Kurbanov’s citizenship; however, they allege that he transacted business within New York as the owner and manager of Silk Restaurant, which is the conduct that gave rise to Plaintiffs’ claims against him. (See Compl. ¶¶ 18–22, 24, 48.) Thus, the Court may exercise specific personal jurisdiction over him. See N.Y. C.P.L.R. § 302(a)(1); Ford, 141 S. Ct. at 1025.Read the full opinion on CourtListener →
CPLR 302(a)(1) permits specific jurisdiction when a defendant transacts business in New York and the plaintiff's claim arises from that transaction.
KPP III CCT LLC v. Douglas Dev. Corp. · filed 2023-12-05(a)(1)
Plaintiff also failed to demonstrate specific jurisdiction over Douglas and JCC through the actions of Matthew Jemal. New York courts may exercise specific jurisdiction pursuant to CPLR 302 where (i) the defendant conducted sufficient activities to have transacted business within the state and (ii) the plaintiff's claims arise from the transactions (English v Avon Prods., Inc., 206 AD3d 404, 406 [1st Dept 2022]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nondomiciliary who transacts business in New York when the claim arises from that activity.
Bullion Shark, LLC v. Flip a Coin Bullion LLC · filed 2023-12-06(a)(1)
The Court has personal jurisdiction over Corporate Defendant Flip A Coin and Individual Defendants Matthew and Jacob Forman and Christina Cappello because they have minimum contacts with New York. ... Jurisdiction under Section 302(a)(1) requires showing that “(1) [t]he defendant . . . transacted business within the state” and that “(2) the claim asserted . . . arise[s] from that business activity.”Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claims arise from those transactions; an interactive storefront offering allegedly infringing goods to New York consumers can satisfy those requirements.
The Pinkfong Company Inc. v. TTC · filed 2023-12-07(a)(1)
WHEREAS, the Court has personal jurisdiction because the Served Defendants are subject to personal jurisdiction under CPLR § 302(a)(1),and exercising personal jurisdiction over the Served Defendants comports with the Due Process Clause of the U.S. Constitution.Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between the defendant’s New York business transactions and the plaintiff’s claims; a merely coincidental connection is insufficient.
Gulf Harbour Investments Corporation v. CIT Bank, N.A. · filed 2023-12-22(a)(1)
Construing the pleadings and affidavits in the light most favorable to Gulf Harbour and resolving all doubts in its favor, the connection between CIT Bank’s New York business activities and Gulf Harbour’s causes of actions is too attenuated to confer jurisdiction under section 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction over funds that transact business in New York through their stock exchange listing and use of New York brokers when the shareholder claims relate to those contacts.
Saba Capital Master Fund, LTD. v. ClearBridge Energy Midstream Opportunity Fund Inc. · filed 2024-01-04(a)(1)
New York’s long-arm statute allows claims against a defendant who “transacts any business within the state.” N.Y. C.P.L.R. § 302(a). The Adams and Tortoise Funds’ transactions of business in New York –- including listing on the New York Stock Exchange and relying on New York brokers to manage their portfolios and execute transactions –- are “act[s] by which” they “purposefully avail[]” themselves “of the privilege of conducting activities within the forum State.” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017, 1024 (2021).Read the full opinion on CourtListener →
Section 302(a)(1) permits jurisdiction when a defendant purposefully transacts business in New York and the plaintiff’s claims have an articulable nexus to that transaction.
Smart Shoppers NYC LLC v. Tylers Coffee LLC · filed 2024-01-10(a)(1)
As such, the business transaction requirement under § 302(a)(1) is met here.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary purposefully conducts business through New York and the claim arises from that activity.
Belen v. Herman · filed 2024-01-17(a)(1)
First, the FAC plausibly alleges that Oakworth purposefully availed itself of New York through its fund transfers to Citibank NYC. ... As pled, Oakworth facilitated the covert transfer of Herman’s assets through New York to Liechtenstein, implementing Herman’s wrongful avoidance of Plaintiffs’ New York judgment against him, establishing an “articulable nexus” to New York.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a nondomiciliary’s purposeful New York activity has a substantial relationship to the claim.
PC-16 Doe v. Hill Regional Career High Sch. · filed 2024-01-18(a)(1)
We find the field trip at issue, to Carnegie Hall for the School choir performance, constituted "purposeful activity," in New York, namely, an "act by which [d]efendant purposefully avails itself of the privilege of conducting activities" here. We further find plaintiff adequately alleged facts to show a "substantial relationship between the transaction and the claim asserted" ( Paterno v Laser Spine Inst ., 24 NY3d 370, 376 [2014] [internal quotation marks omitted]), having alleged, "at minimum, a relatedness between the transaction and the legal claim such that the latter is not completely unmoored from the former" ( Matter of New York Asbestos Litig. , 212 AD3d 584, 586 [1st Dept 2023] [internal quotation marks omitted]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a nonresident negotiates a business transaction in New York and the claims arise from that transaction.
Italian Exhibition Group USA, Inc. v. Bartolozzi · filed 2024-01-25(a)(1)
First, Paik transacted business in the state. ... Second, IEG’s claims arise from these negotiations.Read the full opinion on CourtListener →
Section 302(a)(1) subjects an out-of-state attorney to personal jurisdiction for transacting business in New York when the attorney purposefully enters the state to perform services there.
Leili v. Romanello · filed 2024-01-30(a)(1)
For an out-of-state attorney to be subject to personal jurisdiction under CPLR 302(a)(1) for transacting business within the state, he or she must project "[themselves] into New York to perform services and purposefully [avail themselves] of the privileges and benefits of performing such services in the state" ( Liberatore v Calvino , 293 AD2d 217, 220 [1st Dept 2002]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction based on one purposeful New York business transaction substantially related to the claim, even if the defendant never enters the state.
Lippes v. Toddy · filed 2024-02-02(a)(1)
Jurisdiction can attach on the basis of one transaction, even if the defendant never enters the state, " 'so long as the defendant's activities here were purposeful and there is a substantial relationship between the transaction and the claim asserted' " ( Fischbarg v Doucet , 9 NY3d 375, 380 [2007], quoting Deutsche Bank Sec., Inc. v Montana Bd. of Invs ., 7 NY3d 65, 71 [2006], cert denied 549 US 1095 [2006]).Read the full opinion on CourtListener →
CPLR 302(a)(1) requires purposeful business activity in New York with a substantial relationship to the claim; sporadic emails and a few meetings that lack that connection do not establish jurisdiction.
Black v. Phoenix Cayman Ltd. · filed 2024-02-15(a)(1)
Plaintiffs did not show that the sporadic emails between Visweswaran and his colleagues, who were based in New York, and his few meetings in New York before plaintiffs invested in the partnership, constituted a transaction of business with plaintiffs in New York or were substantially related to the claims of fraud in the inducement of plaintiffs' investment and subsequent alleged waste and mismanagement of partnership assets ( see Quad Capital Portfolio A LLC v AbbVie Inc., 201 AD3d 449, 449-450 [1st Dept 2022]; CDR Creances S.A.S. v First Hotels & Resorts Invs., Inc. , 140 AD3d 558, 562 [1st Dept 2016]).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary that transacts business in New York when the claim arises from that business.
Eco-Fuels LLC v. Sarker · filed 2024-02-26(a)(1)
The cause of action for the instant case is breach of the same contract, and as such, the Court finds that Defendants transacted business within New York and are subject to the Court’s personal jurisdiction.Read the full opinion on CourtListener →
Section 302(a)(1) requires an articulable nexus between the defendant’s New York business transactions and the claims asserted.
Italian Exhibition Group USA, Inc. v. Bartolozzi · filed 2023-11-06(a)(1)
As for the long-arm statute, the claims against Paik must “aris[e] from” her New York “trans- act[ions].” N.Y. C.P.L.R. § 302(a)(1). In other words, there must be “some articulable nexus be- tween the business transacted and the cause of action sued upon.” McGowan v. Smith, 52 N.Y.2d 268, 272 (N.Y. 1981); see also Agency Rent A Car Sys., Inc. v. Grand Rent A Car Corp., 98 F.3d 25, 31 (2d Cir. 1996) (“substantial nexus”). The complaint alleges that Paik “routinely c[a]me into New York” on business and controlled the company’s New York bank account. Am. Compl. ¶¶ 44, 135. But again, it doesn’t allege a connection between those potential contacts and the claims here.Read the full opinion on CourtListener →
Section 302(a)(1) requires a connection between the defendant’s New York business transaction and the claims for specific jurisdiction.
Equipav S.A. Pavimentacao, Engenharia e Comercio Ltda. v. Bertin · filed 2024-01-18(a)(1)
Even assuming that Bertin’s use of a correspondent banking account in New York is sufficient to demonstrate the “transaction of business” in this state, however, Equipav has not proffered facts showing any connection between a New York bank account and the claims at issue in the arbitration proceeding, and thus Petitioner’s allegations do not provide a basis for the exercise of specific jurisdiction.Read the full opinion on CourtListener →
Section 302(a)(1)’s nexus requirement is satisfied when a website sells to New York customers but allegedly denies a blind New York customer the ability to buy through that website.
Campbell v. Gallery Model Homes, Inc. · filed 2024-03-12(a)(1)
Specifically, “by selling products on [the] Website to New York customers, but only to those customers who are not legally blind and can navigate the Website,” Gallery’s “business transaction[s]” have a “substantial relationship” to Campbell’s claim.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when business transacted in New York has an articulable nexus to the claim.
Newman Capital LLC v. Private Capital Group, Inc. · filed 2024-03-28(a)(1)
These meetings were related to the contracts at issue in this lawsuit; therefore, there is “some articulable nexus between the business transacted and the cause of action sued upon.” Sole Resort, S.A. de C.V. v. Allure Resorts Mgmt., LLC, 450 F.3d 100, 103 (2d Cir. 2006) (internal quotation marks omitted). Accordingly, jurisdiction over the Individual Defendants is proper pursuant to N.Y. CPLR § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a non-domiciliary who transacts business in New York when the claim arises from that transaction.
Mandour v. Rafalsky · filed 2024-04-01(a)(1)
Because Fredrick and Richard were the "primary actors with respect to the transactions at issue" (Matter of Renren, Inc., 192 AD3d 539, 539 [1st Dept 2021]), plaintiffs sufficiently allege that Fredrick and Richard transacted business in New York. Further, plaintiffs' claims arise from the Shareholders Agreement and Fredrick and Richard's transaction of business as directors and shareholders of RC.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant’s New York business transactions have an articulable nexus or substantial relationship to the claims asserted.
Oasis Invs. II Master Fund Ltd. v. Mo · filed 2024-05-02(a)(1)
Here, there was much more and like Renren, the Transaction involved a significant number of critical New York contacts such that jurisdiction is proper under CPLR § 302(a)(1) because there is an articulable nexus or substantial relationship between the transactions and the claim asserted.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and that business has an articulable nexus to the claim.
Newman Capital LLC v. Private Capital Group, Inc. · filed 2024-05-10(a)(1)
Accordingly, jurisdiction over the Individual Defendants is proper pursuant to N.Y. CPLR § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a New York business transaction and a substantial relationship between that transaction and the claim; booking a hotel stay in New York does not establish jurisdiction over a negligence claim arising from an injury at the hotel abroad.
Christie v. Hyatt Hotels Corp. · filed 2024-05-23(a)(1)
Plaintiffs fail to establish personal jurisdiction under § 302(a)(1), which requires that: “(1) [t]he defendant must have transacted business within the state; and (2) the claim asserted must arise from that business activity,” Sole Resort, S.A. de C.V. v. Allure Resorts Mgmt., LLC, 450 F.3d 100, 103 (2d Cir. 2006), meaning that “there [is] an articulable nexus or substantial relationship between the asserted claim and the defendant’s contacts.”Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction when a defendant's purposeful New York transaction has a substantial relationship to the claim.
JMRNNY Doe v. Opus Dei · filed 2024-06-10(a)(1)
Beyond general jurisdiction, there is also a basis for specific jurisdiction here. To be sure, it is alleged that McCloskey was transferred from New York to Oakcrest-a purposeful act that invoked the privileges and benefits of New York State. There exists an unequivocal nexus between the transfer ofMcCloskey, who is alleged to have committed tortious acts within New York, and Plaintiffs subsequent injuries, which occurred at Oakcrest following McCloskey's transfer.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claim arises from that business activity.
Cabrera v. RLB USA Safety and Hardware Inc. · filed 2024-06-14(a)(1)
Jurisdiction under Section 302(a)(1) requires showing that “(1) [t]he defendant . . . transacted business within the state” and that “(2) the claim asserted . . . arise[s] from that business activity.”Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business in New York and the claim arises from that business.
Spin Master, Ltd. v. Aomore-US · filed 2024-06-17(a)(1)
Under New York’s long-arm provision, N.Y. CPLR § 302(a)(1), a defendant is subject to personal jurisdiction in this Court “if (1) the defendant transacted business within the state; and (2) the claim asserted arises from that business activity.” Licci ex rel. Licci v. Lebanese Canadian Bank, SAL, 732 F. 3d 161, 166 (2d Cir. 2013). ... There can be no serious doubt that Plaintiff’s patent infringement claims arise directly from these New York transactions.Read the full opinion on CourtListener →
CPLR 302(a)(1) does not establish personal jurisdiction merely because a nondomiciliary sent a Venmo payment request to a plaintiff in New York.
Acosta v. Vann · filed 2024-06-17(a)(1)
In opposition to the motion, the plaintiff contends that Vann transacted business within the State of New York by sending a Venmo transaction request to the plaintiff when the plaintiff was in New York. ... Here, the plaintiff has not made a prima facie showing that personal jurisdiction over Vann exists under CPLR 301, as alleged in the complaint ( see Transcan Sys., Inc. v Seldat Distrib., Inc. , 209 AD3d at 912), or CPLR 302(a)(1), as alleged in opposition to the motion ( see Fanelli v Latman , 202 AD3d at 761).Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction over a non-domiciliary who transacts business in New York when the claim arises from that business activity.
Barton v. Zhang · filed 2024-06-27(a)(1)
Petitioner asserts that the Court has specific jurisdiction over Zhang under N.Y. C.P.L.R. § 302(a)(1). ... Petitioner has established that the Court has personal jurisdiction over Zhang under New York law. Petitioner has submitted an affidavit and evidence that establishes that Zhang transacted business in New York. ... Petitioner’s claim, which turns on breach of those contractual obligations, has a substantial relationship to New York, satisfying the “arising under” prong.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction over a nondomiciliary whose New York business transactions give rise to the plaintiff’s claims.
Cooper v. Fire & Ice Trucking, Corp. · filed 2024-07-09(a)(1)
Plaintiff does not allege Defendant Owens’ citizenship; however, they allege that she transacted business within New York as the owner and manager of Fire & Ice, which is the conduct that gave rise to Plaintiff’s claims against her. (See Compl. at ¶¶ 14–16, 24-25.) Thus, the Court may exercise specific personal jurisdiction over her. See CPLR § 302(a)(1); Ford, 592 U.S. at 359.Read the full opinion on CourtListener →
Section 302(a)(1) does not support jurisdictional discovery based solely on an inventor being named on patents filed in Virginia by New York lawyers.
Louisiana Health Service & Indemnity Company v. Celgene Corporation · filed 2024-07-09(a)(1)
The fact that Zeldis was listed as the inventor on patents belonging to Celgene— headquartered in New Jersey—and filed in Virginia, by a New York based law firm, without more is “simply too tenuous of a connection to New York.”Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary transacts business in New York and the claim arises from that business activity.
Cohen v. eSupplements, LLC · filed 2024-08-20(a)(1)
Jurisdiction under Section 302(a)(1) requires showing that “(1) the defendant must have transacted business within the state” and that “(2) the claim asserted must arise from that business activity.” ... Here, the Complaint alleges that Nutricost sold the Product in New York, where Cohen purchased it, and it is clear that Cohen’s claims for fraud, deception, misrepresentation, and breach of warranty arise out of that purchase.Read the full opinion on CourtListener →
Section 302(a)(1) permits specific jurisdiction over an individual who transacts business in New York when the claim arises from that transaction.
Chavez v. Roosevelt Tropical, Corp. · filed 2024-08-21(a)(1)
New York has specific jurisdiction over individuals who “transact[] any business within the state” so long as “the cause of action arises from that transaction.”Read the full opinion on CourtListener →
Section 302(a)(1) permits long-arm jurisdiction based on business transacted in New York through membership interests in New York entities.
People v. Abraham Operations Assoc. LLC · filed 2024-08-23(a)(1)
Contrary to respondents' contentions, jurisdiction over Hellman, Kaufman, Greenberg, Blumenfeld, and Jonathan Hagler is appropriate under CPLR 302 (a) (1). The petition adequately establishes that these respondents transact business in New York. Long-arm jurisdiction may be asserted over these respondents by virtue of their membership interests in certain respondent entities.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant’s business operations in New York give rise to the plaintiff’s injuries.
BTL Industries, Inc. v. Bioskin Laser LLC · filed 2024-03-22(a)(1)
Personal jurisdiction is proper as Defendants’ business operations in New York State give rise to Plaintiff’s injuries. See CPLR 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1)’s arising-from requirement is satisfied when a seller’s transactions with New York customers substantially relate to a blind shopper’s claim that website barriers prevented a purchase.
Velazquez v. Don Roberto Jewelers, Inc. · filed 2024-03-27(a)(1)
Don Roberto’s transactions thus have a substantial relationship to Velazquez’s claim.Read the full opinion on CourtListener →
Section 302(a)(1) requires a connection between the claim and the defendant’s New York business transactions; unrelated transactions with other customers do not suffice.
Style Stitch, Inc. v. The Avyan Group, LLC · filed 2024-08-07(a)(1)
Where Plaintiff falls short, however, is its lack of factual allegations supporting the position that its claims in this case—which relate to the breach of contract between India-based Plaintiff and New Jersey-based Defendant—“arose from” any of the unrelated business transactions Defendant may have had with non-party retailers in New York.Read the full opinion on CourtListener →
Section 302(a)(1) requires an articulable nexus between the New York transaction and the claim; separate, unrelated out-of-state agreements do not establish that nexus.
Powerflex Solar, LLC v. Solar PV Pros, LLC · filed 2024-08-01(a)(1)
Therefore, the issue distills to whether there is an articulable nexus between the New York agreements and the Rhode Island and California agreements. We find that there is not.Read the full opinion on CourtListener →
Section 302(a)(1) can treat a diocese’s purposeful religious activities in New York as transacting business for personal jurisdiction.
MM-1-DOE v. Catholic Diocese of Peoria · filed 2024-09-17(a)(1)
The facts in this matter are analogous to those in PC-16 Doe. Here, as alleged, Defendants authorized and promoted a trip to New York - a purposeful act - thereby invoking this State's privileges and benefits. ... The evangelization of Plaintiff and others, encouragement of plaintiff/minor's vocation and the study of the catholic faith were the business of the diocese conducted in New York during the pilgrimage.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a defendant transacts business or contracts to supply goods in New York and the claims arise from those activities.
Cengage Learning, Inc. v. Does 1 - 50 · filed 2024-09-24(a)(1)
Alternatively, the Court has personal jurisdiction over Defendants pursuant to N.Y. C.P.L.R. § 302(a)(1). Plaintiffs have shown that Defendants transact business and/or contract to supply goods in New York, including distributing infringing works to Plaintiffs and others in New York via the Sites, and Plaintiffs’ claims arise from those activities.Read the full opinion on CourtListener →
CPLR 302(a)(1) permits personal jurisdiction when a defendant purposefully engages in activity in New York and the claim has a substantial relationship to that activity.
V.Z. v. Roman Catholic Diocese of Burlington · filed 2024-09-26(a)(1)
Accepting as true the facts alleged ( see Rushaid v Pictet & Cie , 28 NY3d 316, 327 [2016]), plaintiff has made a prima facie showing that Diocese of Burlington is subject to personal jurisdiction under CPLR 302(a)(1) ( see PC-16 Doe v Hill Regional Career High School , 223 AD3d 518, 519 [1st Dept 2024]). ... Therefore, plaintiff adequately alleges that Diocese of Burlington engaged in "purposeful activity" in New York, and that there is a "substantial relationship between the transaction and the claim asserted" ( id. ).Read the full opinion on CourtListener →
Section 302(a)(1) does not confer jurisdiction based on telephone negotiations over a contract without a New York choice-of-law term when the assets have no connection to New York.
Shift Markets Group, Inc. v. Alkemi AI Inc.. · filed 2024-09-27(a)(1)
Courts applying § 302(a)(1) routinely find that telephonic negotiations involving non-domiciliary defendants under contracts not containing New York choice of law terms for assets which have no relation to the forum state are insufficient. ... This Court comes to the same conclusion here as Plaintiff has not sufficiently pleaded any connection between the assets at issue here and the forum state.Read the full opinion on CourtListener →
Section 302(a)(1) requires actual business activity in New York; a desire to acquire New York clients alone is insufficient.
Seiden v. Baker Tilly H.K. Ltd. · filed 2024-10-08(a)(1)
But even assuming that CNEP was a New York corporation – which is by no means clear from the record – the mere fact that BTHK desired to acquire clients located in New York is not, by itself, enough to demonstrate that it actually transacted business in New York with CNEP.Read the full opinion on CourtListener →
Section 302(a)(1)'s transaction-of-business requirement can be satisfied by even a minute number of New York transactions.
Batista v. PhotonLight.com, Inc. · filed 2024-10-15(a)(1)
However, even a minute number of transactions, as is the case here, is sufficient to satisfy the first prong of the analysis under CPLR 302 (a) (1) ( see Kreutter , 71 NY2d at 467).Read the full opinion on CourtListener →
Section 302(a)(1) requires a claim to arise from purposeful activity in New York; sales of consumer reports there do not establish jurisdiction over a failure-to-correct claim arising from conduct elsewhere.
Alvarez v. Experian Information Solutions, Inc. · filed 2024-12-06(a)(1)
Moreover, even if Experian transacted business in New York by selling creditors consumer reports, “Plaintiff [Khalil’s] FCRA claim for failure to investigate and remove disputed information [from the reports] does not appear to ‘arise from’ Experian’s [sale of the reports] or any other purposeful activity in New York; rather, arises out of [Experian’s] failure to correct the erroneous reporting disputed by Plaintiff” – which apparently, based on the PAC’s allegations – was committed outside of New York. ... Accordingly, because Prospective Plaintiff Khalil has “failed to show even one purposeful and relevant ‘activity’ or ‘occurrence that took place in’ New York[,]” the Court finds that it lacks personal jurisdiction over Experian with respect to Khalil’s claims.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary purposefully transacts business in New York and the claim has an articulable nexus to that business.
Spin Master Ltd. v. www.spinmastershop.com · filed 2024-12-09(a)(1)
WHEREAS, the Served Defendant is subject to personal jurisdiction, as the New York long-arm statute provides a statutory basis for jurisdiction through its “transacting business” provision.Read the full opinion on CourtListener →
Section 302(a)(1) does not treat an email threatening litigation and demanding settlement, without more, as transacting business in New York merely because the recipient is there.
Twin Beauty LLC v. NR Interactive LLC · filed 2024-12-14(a)(1)
An email to a New York recipient stating defendant’s intent to protect his copyright through litigation and demanding a settlement to forestall litigation—though perhaps a hardball tactic—does not constitute “transacting business” within the meaning of N.Y. C.P.L.R. § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) requires a substantial relationship between the defendant’s New York business transaction and the claim.
Wilmar Sugar Pte. Ltd. v. Chiaradia · filed 2025-01-08(a)(1)
The issue that Plaintiff has here is that, even assuming that their allegations regarding Chiaradia’s connections to New York are true, they have not established a substantial relationship between utilizing a commodities market that resolves disputes in New York and the alleged statements made to unidentified third parties (presumably in Singapore) about a Singaporean company. Their claims for defamation and negligence simply do not arise out of Chiaradia’s alleged connections to New York.Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction when a non-domiciliary's purposeful New York business activities are substantially related to the claims.
City of New York v. Exxon Mobil Corp. · filed 2025-01-14(a)(1)
The Court finds that Defendants' contacts with and activities in NYC were purposeful and are substantially related to the underlying claims of deceptive practices in NYC. Accordingly, the Court finds that the Complaint contains sufficient allegations to establish personal jurisdiction in New York over the Defendants pursuant to CPLR § 302(a)(1).Read the full opinion on CourtListener →
Section 302(a)(1) permits personal jurisdiction based on regular, work-related communications with a person in New York when those communications give rise to the claims.
Kovacs v. AudioEye, Inc. · filed 2025-01-31(a)(1)
The Court finds that the allegations of regular, work-related communications with Plaintiff, who alleges he was located in New York, from which the causes of action arise are sufficient as a matter of law to confer personal jurisdiction over Defendant Bettis pursuant to CPLR § 302(a)(1).Read the full opinion on CourtListener →
Notes 751–900 of 2,170, oldest cases first.
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