This is now the latest Second Circuit decision on minimum contacts in NY in an IP context.
Chloe sues Defendant. Defendant sold 52 non-Chole bags into NY and one alleged Chloe-counterfeit to Chloe’s NY law firm. The 2d Cir finds the totality of those sales sufficient for personal jurisdiction Page 18: the court says that

In a copyright action involving works uploaded to the Internet, does New York jursidiction lie over an out-of-state defendant with no contacts with New York, if, inter alia, the defendant is alleged to have committed a tortious act outside the State that caused, and reasonably should have been expected by the putative defendant to cause,

Plaintiff alleges that Baidu, China’s largest search engine, infirnged its copyrights. Held: (1) Baidu’s designated US agent, CT Corp., may limit its agency to service of process to matters relating only to securities; and (2) Baidu’s NASDAQ listing constitutes insufficient contacts for purposes of NY personal jurisdiction.
Decision Baidu Service Personal Jursidiction

Virginia defendant operates a website that allows listeners to listen to music, create playlists and to download ringtones. Site is advertiser-sponsored and targeted at the Indian non-resident population. NY plaintiff sues in NY. It has no specific allegations of sales or other contacts with NY, but makes inferential arguments based on fact that 15% of