Jazini ex rel. Jazini v. Nissan Motor Co.
148 F.3d 181 (2d Cir. 1998) Cited 717 times 2 Legal AnalysesHolding that "conclusory non-fact-specific jurisdictional allegations" and "legal conclusion couched as a factual allegation" do not meet the burden of a prima facie showing of jurisdiction
Volkswagenwerk Aktiengesellschaft v. Beech
751 F.2d 117 (2d Cir. 1984) Cited 305 times 2 Legal AnalysesFinding sufficient allegations of fact under each of the four factors to demonstrate that the American subsidiary was a mere department of its foreign corporation
Aerotel Ltd. v. Sprint Corp.
100 F. Supp. 2d 189 (S.D.N.Y. 2000) Cited 126 timesHolding that, with respect to claims that a patent is invalid and unenforceable, the locus of operative facts factor is "not geographically dependent"
In re Ski Train Fire in Kaprun, Austria
230 F. Supp. 2d 403 (S.D.N.Y. 2002) Cited 57 timesHolding that overlapping boards is typical of a parent-subsidiary relationship, and does not weigh in favor of a department finding
J.L.B. Equities, Inc. v. Ocwen Financial Corp.
131 F. Supp. 2d 544 (S.D.N.Y. 2001) Cited 55 timesHolding all the factors aside from common ownership "counsel against the exercise of personal jurisdiction" where "the plaintiff cannot, and does not, adequately demonstrate that the [subsidiary] is dependent upon [the parent corporation] for funds. To the contrary, the facts alleged suggest that the [subsidiary] generates the bulk of [the parent corporation]'s income"
Children's Network, LLC v. Pixfusion LLC
722 F. Supp. 2d 404 (S.D.N.Y. 2010) Cited 31 times 1 Legal AnalysesFinding that plaintiff's suit was not anticipatory because defendant's intent to sue was "far from clear," as the cease and desist letter failed to include specific deadlines or identify a possible forum for subsequent legal action, and indicated a desire to "negotiate a business resolution"
Pergo, Inc. v. Alloc, Inc.
262 F. Supp. 2d 122 (S.D.N.Y. 2003) Cited 38 timesFinding that, because there was no nexus to New York, evidence of defendants' sales in New York was "insufficient"
Linde v. Arab Bank, PLC
262 F.R.D. 136 (E.D.N.Y. 2009) Cited 25 times 1 Legal AnalysesFinding lack of control in the context of a domestic subsidiary and a foreign parent company
Bellomo v. Pennsylvania Life Co.
488 F. Supp. 744 (S.D.N.Y. 1980) Cited 57 timesHolding foreign insurance company was "super-corporation" engaged in underwriting and selling insurance policies through its subsidiaries
Jerge v. Potter
99-CV-0312E(F) (W.D.N.Y. Aug. 11, 2000) Cited 18 timesFinding financial dependence factor not satisfied where initial investment derived from parent but subsidiary had financially independent operations and received no day-to-day financing
Section 301 - Jurisdiction over persons, property or status
N.Y. CPLR 301 Cited 1,602 timesCodifying caselaw that incorporates "doing business" standard