Fantis Foods, Inc. v. Standard Importing Co., Inc

In Fantis Foods, Inc. v. Standard Importing Co., Inc., 49 NY2d 317, 326, 402 N.E.2d 122, 425 N.Y.S.2d 783 (1980), the Court of Appeals stated that "residence or domicile of the injured party within a State is not a sufficient predicate for jurisdiction, which must be based upon a more direct injury within the State and a closer expectation of consequences within the State than the indirect financial loss resulting from the fact that the injured person resides or is domiciled there." The Second Circuit, in its construction of the New York long-arm statute, has also rejected "derivative commercial injury in this state" resulting solely from the fact that plaintiff is domiciled in New York. See American Eutectic Welding Alloys Sales Co., Inc. v. Dytron Alloys Corp., 439 F.2d 428, 433 (2d Cir. 1971).