48th Restaurant Associates LLC v. Avra Hospitality LLC et al
Date: January 24, 2022
Docket Number: 1:2019cv07708

Defendant is headquartered in Minnesota. It operates restaurants and resorts.  One resort is in Connecticut. Defendant’s website is accessible in NY.

“However, as the Second Circuit has explained, “[w]hile analyzing a defendant’s conduct under the Zippo sliding scale of interactivity may help frame the jurisdictional inquiry in some cases, . . . traditional statutory and constitutional principles remain the touchstone of the inquiry.” Best Van Lines, 490 F.3d at 252 . . . In other words, a court need not embark on a Zippo-like interactivity analysis if it can understand the basis for personal jurisdiction through traditional statutory and constitutional principles alone. . . .

The CT Inn may “regularly attract[] visitors from New York,” (Compl. ¶ 50), but merely doing business with New Yorkers cannot lead to personal jurisdiction under Walden.”

Text of 48th Restaurant Associates v Avra Hospitality: sdny 48 v avra personal jurisdiction