This column addresses recent noteworthy decisions of the U.S. District Court for the Northern District of New York. Recently, District Judge Mae D’Agostino addressed some of the procedural peculiarities of personal jurisdiction and Senior District Judge Lawrence E. Kahn revisited the particularity required to allege a relevant market for antitrust claims.

‘Salamone’

In Salamone v. Douglas Marine, 19-CV-01213 (MAD/DJS), 2022 WL 111774 (N.D.N.Y. Jan. 12, 2022), the plaintiff sought to recover damages associated with the failed sale of a racing boat and engines. At an early pre-motion conference, defendant Douglas Marine disputed that it had taken any actions in New York as part of the transaction to support the exercise of long-arm personal jurisdiction. The court recommended that the parties try to resolve their factual disputes, through discovery if necessary, and for Douglas Marine to move to dismiss if they could not.

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