In a case of apparent first impression, a Staten Island, N.Y., judge has ruled that a single eBay transaction between a New York buyer and an out-of-state seller is insufficient to establish personal jurisdiction in a breach of contract action.

One sale, “without more, does not constitute sufficient purposeful availment to satisfy the minimum contacts necessary to justify summoning across state lines, to a New York court, the seller of an allegedly non-conforming good,” Richmond County Civil Court Judge Philip S. Straniere held in Sayeedi v. Walser, 10610/06.

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