In Getty Petroleum Corp. v. Am. Ex., 90 NY2d 322, rearg denied 97 N.Y.2d 764 (1997) an employee used forged, employer checks to pay her American Express credit card bill. The court found "American Express routinely processed stale checks, checks payable to neither American Express nor the customer, checks where neither American Express nor the customer was listed on the check, checks from unrelated third parties and multiple checks from multiple third parties with different addresses in different states for a single transaction." Id. at 331-332. Nonetheless, the Court held that the plaintiff failed to meet its burden of proof in showing that American Express's conduct "amounted to dishonesty or complicity" required to show bad faith. Id. at 331.