On February 15, 2024, the First Department issued a decision in Black v. Phoenix Cayman Ltd., 2024 NY Slip Op. 00797, holding that a few e-mails and meetings in New York were insufficient to create personal jurisdiction in New York, explaining:
Plaintiffs assert that the court has specific jurisdiction over defendant Visweswaran, a resident of the United Kingdom, pursuant to CPLR 302(a)(1), based on his transaction of business in New York. Pursuant to CPLR 302(a)(1), a New York court may exercise personal jurisdiction over a nondomiciliary if he has purposefully transacted business within the state, and there is a substantial relationship between the transaction and the claim asserted. The court properly found that, after engaging in jurisdictional discovery, plaintiffs were unable to meet their burden of demonstrating long-arm jurisdiction over Visweswaran. Jurisdiction cannot be based on the fact that Visweswaran was a director of New York corporate and partnership entities involved. 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.
(Internal quotations and citations omitted).