In Briggs Ave. LLC v. Insurance Corp. of Hannover, 11 NY3d 377, Briggs' Articles of Organization designated the Secretary of State as its agent to receive process. The articles included Briggs' address but Briggs moved, and Briggs' manager/only member did not notify the Secretary of State of the address change. A tenant in the building Briggs owned commenced a personal injury action against Briggs. Because of the change of address, Briggs did not know of the action until one year later when the tenant served Briggs directly with a default judgment. The Court of Appeals held that Briggs should have notified the Secretary of State of the address change, Briggs was directly responsible for the error, and Briggs' liability carrier could disclaim coverage.