In Talbot v. Johnson, 71 NY2d 827, a St. Lawrence University student related to her father (both being California residents) that she observed the university's basketball coach "guzzling beer" at a campus party and sleeping it off on a sofa, all this occurring within two weeks of a vehicular death involving a student driver charged with alcohol impairment after leaving the coach's home. The student's father wrote letters to university trustees recounting his daughter's observations. A trustee forwarded the letter to a local newspaper which after a telephone interview with the daughter printed part of the letter, prompting the coach's defamation suit. The Court of Appeals affirmed the CPLR 302(a)(1) dismissal as against the California student and her father, reminding that there must be "purposeful activities" within the state and a "substantial relationship" between them and the transaction out of which the cause of action arose," citing McGowan v. Smith, 52 NY2d 268, 272. The Talbot court found that even if the daughter's enrollment satisfied the requirement of purposeful activities, there was no showing that "there was the required nexus between the MacLarens' New York 'business' and the present cause of action." Id. at 829.