The Court of Appeals ruled in Fabrizi v. 1095 Ave. of Americas, 22 N.Y.3d 658, 662-63 (2014) that the plaintiff in a “section 240(1) ‘falling object’ case” must “demonstrate that at the time the object fell, it either was being ‘hoisted or secured’” (citing Narducci v. Manhasset Bay Assoc., 96 N.Y.2d 259, 268 (2001)) or that the object “‘required securing for the purposes of the undertaking’” (citing Outar v. City of New York, 5 N.Y.3d 731, 732 (2005)).

The first alternative—that the object fell while being hoisted or secured—was and remains simple enough. But what, exactly, is an object that “required securing for the purposes of the undertaking”? For that matter, what exactly, is the pertinent “undertaking”?