In Frummer v. Hilton Hotels Inter., Inc., 19 NY2d 533, 536-37, 227 N.E.2d 851, 281 N.Y.S.2d 41 , plaintiff was injured in the London Hilton Hotel. He sued Hilton Hotels (U.K.) Ltd., lessee and operator of the hotel and a British Corporation, in New York.
The Court of Appeals, interpreting Section 301, held that a plaintiff who alleged that he was injured in the Hilton Hotel in London could establish personal jurisdiction in New York over the British corporation which operated the London Hilton.
The Court of Appeals reasserted its rule that solicitation of business in the state without more is insufficient to provide a basis for personal jurisdiction.
It therefore found the necessary additional activities in the corporation's use of a New York representative to make reservations at the London Hilton and to do "public relations and publicity work" (Frummer v. Hilton Hotels International, Inc., supra at 537).
The Court of Appeals stated in Frummer that to establish that a domestic corporation is an agent for a foreign parent, "the plaintiff must show that the subsidiary 'does all the business which the parent corporation could do were it here by its own officials'" (Id. at 537).