In Bank of Communications v. Ocean Dev. Am., Inc. (2010 WL 768881 [SD NY 2010]), the plaintiff sought to enforce a New York judgment against a company and asserted claims based on DCL 272, 273, and 276 against the company's officers. Before the plaintiff had obtained a judgment against the company, while the suit was pending, the officers, who resided in California, had conveyed the company's California warehouse to themselves. The plaintiff argued and the court agreed that by taking possession of the warehouse during the pendency of the New York action, the officers committed an act which they reasonably could have expected to have consequences in New York. The court determined that the plaintiff was injured in New York because the transfer of the warehouse was intended to prevent the satisfaction of the plaintiff's New York judgment.