On November 18, 2025, the First Department issued a decision in Lash v. TDR Capital LLP, 2025 NY Slip Op. 06282, dismissing an action on forum non conveniens grounds because of sparse New York connections, explaining:
The motion court should have dismissed this action pursuant to the doctrine of forum non conveniens. Although 4 of the 12 plaintiffs are New York residents, the rest are residents of other states, both defendants are foreign entities; and virtually all relevant events occurred in Luxembourg or the United Kingdom — notwithstanding that defendants were represented by New York-based attorneys, that some very limited amount of negotiations took place in New York, or that defendants used New York financial institutions for one transaction. Luxembourg is an adequate alternative forum with a substantial interest in adjudicating this dispute involving Luxembourg companies. Moreover, Luxembourg law governs six out of plaintiff’s nine causes of action and the import of the relevant Luxembourg law is heavily contested.
(Internal citations omitted).