In Millicom Int'l Cellular SA v. Simon, 247 A.D.2d 223 [1st Dept 1998], the court found the Philippines to be a more viable and convenient forum in an action involving a one-time dissemination in New York of a report that was part of an alleged worldwide "smear campaign" against the plaintiff. The court found that this single act did not warrant keeping the case in New York because the crucial events underlying the action had occurred in the Philippines and a majority of witnesses were in the Philippines. The court stated that "clearly, the undue burden that would be placed upon the New York courts if jurisdiction were to be retained would be entirely unjustified given the extremely tenuous nexus between the claim asserted and this forum, notwithstanding the allegation that such nexus was deliberately created by defendants." (Id.)