In Town of Smithtown v. National Union Fire Ins. Co. (191 AD2d 426, 594 N.Y.S.2d 318 [2d Dept 1993]), the plaintiffs commenced a declaratory judgment action seeking a declaration that their insurers were obligated to defend them in four actions brought by various school districts. The subject policy was issued by National Union Fire Insurance Company, a subsidiary of AIG. The Court held that "the plaintiffs have failed to allege or tender proof that the parent company, American International Group, Inc., exercised complete dominion and control over National Union Fire Insurance Company in this matter. Thus, liability of the parent company for the contractual obligations of its subsidiary may not be imposed" (id. at 428).