In Waters v. New York City Hous. Auth., 69 N.Y.2d 225 [1987], the Court found that a building owner had no duty to protect a plaintiff who was attacked by an assailant outside a building and then forced inside. Notably, the Court distinguished Nallan, infra, based on the fact that the plaintiff had no connection whatsoever to the building in which she was assaulted (Waters, supra at 228). In fact, the Court pointed to two important factors in determining the scope of a landowner's duty: (1) the relationship between the landowner and the assailant, and, (2) the relationship between the landowner and the victim (id. at 229-230). These factors are relevant because a landowner has no control over the acts of an assailant or of the conditions of public byways that make attacks common place (id. at 230). Further, if those two factors are not considered, a landlord would be subject to virtually limitless liability (id.). Concerned with the need to place controllable limits on liability, the Court declined to find that the landowner had a duty because the building had no association with the plaintiff, independent of the crime itself, and the building had no relationship at all with the unidentified wrongdoer (id. at 230-231).