In Chloe v. Queen Bee of Beverly Hills, 616 F.3d 158 (2d Cir 2010), the Court upheld jurisdiction in a trademark infringement action based upon CPLR 302(a)(1). The plaintiff was engaged in the business of selling leather handbags. As part of plaintiff's investigation, an administrative assistant employed by plaintiff ordered a counterfeit handbag from defendant Queen Bee's website which was shipped into New York. Defendant Simone Ubaldelli was deeply involved in the shipment of the handbag to the administrative assistant in New York. Additionally, Queen Bee shipped 52 other handbags into New York, even though defendant Ubaldelli may not have been involved with these sales. This was enough for the Court to exercise jurisdiction over Simone Ubaldelli. The Court emphasized that CPLR 302(a)(1) is a single act statute. Proof of one transaction is enough to sustain jurisdiction (even though the defendant doesn't travel to New York) where the defendant's acts were purposeful and there is a substantial relationship between the sale and the causes of actions asserted. The court indicated that absent the additional 52 bags shipped into New York, defendant Ubadelli's sole shipment of the bag into New York might well be sufficient to sustain jurisdiction.