Taca Int'l Airlines v. Rolls-Royce of England

In Taca Int'l Airlines v. Rolls-Royce of England 21 AD2d 73 [1965], the Court determined the defendant Ltd. was doing business in New York through Inc., as its separately incorporated department or instrumentality. The court found Ltd. was in fact doing business within the state because Inc. only sold Rolls-Royce automobiles, but owned none. Instead, when a sale was made, Inc. purchased cars from Rolls-Royce Ltd. (Taca, 21 AD2d 75). Rolls Royce Ltd. would in turn pay for service rendered to customers. The Taca court held that therefore, Inc. was a "mere department" of the parent company because not only does Inc. sell only products manufactured by the parent, but also Inc. conducted no other business, principle personnel was shared, and all operations of Inc. were reported to Rolls Royce (Id, 75). Thus, all relevant factors coupled together satisfied the requirement of doing business within New York.