In this article, we examine Reveam v. Taylor Freres Capital Markets, No. 655074/2021, 2023 WL 9018613 (N.Y. Dec. 29, 2023), a recent decision from the New York Supreme Court applying New York’s long-arm statute to assess specific personal jurisdiction over a non-resident defendant.

In recent years, decisions from both the New York Court of Appeals and the First Department have highlighted that a broad scope of conduct and activities can support the exercise of personal jurisdiction by New York courts. See, e.g., State v. Vayu, 39 N.Y.3d 330 (2023) (holding that a company’s use of phone calls and emails to negotiate contract terms with contacts in New York and the hosting of two in-person meetings within the state established a clear intent to form a substantial ongoing business relationship and constituted the purposeful activities required to establish jurisdiction); People v. JUUL Labs, 212 A.D.3d 414 (1st Dep’t 2023) (highlighting marketing strategy targeting New York, hosting New York-based social events and advertising in New York as sufficient in-person activities within New York State to support the exercise of personal jurisdiction); 4069 Rosen Associates v. Tournamentone, 206 A.D.3d 464, 2022 N.Y. Slip Op 03864 (1st Dep’t June 14, 2022) (finding personal jurisdiction due to defendant’s in-person negotiation of loan agreements, defendant’s retention of a local law firm and the establishment of an ongoing business relationship with New York plaintiffs).