Pell v. Clarke

In Pell v. Clarke, 1994 WL 74075 [1994] the United States District Court for the Southern District of New York held that it lacked jurisdiction over a law firm under the circumstance where a man, who later became a resident of New York, contacted a law firm in London to solicit help in acquiring a company, relying upon the facts that the firm had no offices in New York, none of the attorneys were members of the New York bar, and it only communicated with the resident by telephone and by writings mailed to New York. Hence, it was held that defendants did not "project themselves" into New York through their communications with plaintiff, reasoning, as is relevant herein, that "the courts have consistently held that merely sending letters and making telephone calls to New York are not by themselves sufficient to impose jurisdiction under 302 (a) (1)"