In SPCA of Upstate New York, Inc. v. American Working Collie Association, 74 AD3d 1464, 1465, 903 N.Y.S.2d 562 (3d Dept 2010), plaintiff sought to base jurisdiction against the Vermont-based defendant for allegedly-defamatory remarks made in Vermont, which were then broadcast on a website.
Jurisdiction was claimed to be had based on three phone calls defendant had made to New York, along with two short visits, as well as the website.
The Court found that "we are unpersuaded that extending jurisdiction on these facts would be consistent with this state's narrow approach to long-arm jurisdiction in defamation cases." (Id. at 1466.)