On December 29, 2023, Justice Cohen of the New York County Commercial Division issued a decision in Reveam, Inc. v. Taylor Frères Capital Mkts., LLC, 2023 NY Slip Op. 34555(U), holding that sending correspondence to New York was an insufficient basis for asserting personal jurisdiction in New York, explaining:
Finally, Taylor Freres’ argument that CPLR 302(a)(3)(ii) is satisfied because Rice received and directed numerous pieces of correspondence to Taylor Freres (including the 2013 Agreement and the 2014 Agreement) at its Rockefeller Plaza office in New York is unavailing. Exercising personal jurisdiction in such circumstances would not satisfy the well-established principles of due process, which require that defendants could reasonably foresee facing suit in the forum. Rice’s limited contacts with New York are too attenuated to satisfy due process requirements.
(Internal citations omitted).