the refusal of the failure of the district court to allow jurisdiction general jurisdiction discovery given what was in front of the court it was a clear abuse of discretion and i just want to live or what are you seeking discovery also you've had a deposition you've got a civil of course that action filed by the f c c you've got documents from the remus soffit principles of companies banks in a number of jurisdictions you've got a coordinate an agreement with the u front of the district court in they can remember what the test is the test is is the reason the possibility or possibility for additional phone contacts number one we have we have it was a large international bank that had  sixteen years the sixteen years run it had an office in in new york city less than ten miles from the forum an office which was dedicated to servicing the greek american community in the united arab emirates the senator's office in the in new them and as it relates to general jurisdiction if you look at the district court's opinion which was candidly an empress opinion if you look at what the district court didn't even look at there was a two thousand and four examination in a bank in the bankruptcy proceeding this is before there was a lawsuit if you look at the rest of appendix page seven fifty six you will see you'll see that the records at the head of that representative office this again is an office that existed the sixteen years less than ten miles from the floor i'm not either referenced in the district court's opinion he states he still sharana that that office was used to provide loans for residents who run the buy property in cyprus they opened accounts from that office the wired money from that office that they participated in recompence in fact he states that he was a member of the cyprus federation if one looks up the cyprus federation you'll see it you really have got i'm going i'm going to try to has to be that the bank is subject to personal jurist anywhere and your positive is located because all you have as far as i see with the new jersey and  would have to be with all due respect it defies common sense to not believe that a business that exists a bank that exists to service the united states the population that's existing in new york city should not one more time than your initial was a lot you've had a lot of questions grounds here expression in light of the europeans the decision that was issued by this court almost about a month ago we had an intellectual property contract where the services pursuant to that contract very similar to this case were issue brothers the mere fact that an adult state the fended contract with a resident of the form state alone does not give good grounds for or for personally jurisdiction in the in the home form would you c de that if this were a case where the bank had simply converted the funds of aramis off that there'd be personal jurisdiction in new jersey i don't believe so the transfers that all wedged in this complain there was a space when you were a swiss bank there was a specific finding given the contacts with the swiss form that swiss where would a pawn so i think in that instance even if the there was some some  facts that would tend to show all of that would tend to approximate physical presence in the form and i don't see any good house coverage they have to present allegations that suggest with reasonable particular have them to open their accounts on their way back to cyprus we give them information from cyprus how to wire their money from the banks here over there just information and this is critical but instead listed any other kind of business presence in new jersey cannot exist by virtue of their statue they were not engaging in in the business of banking in the united states the purpose of the represented of the office was to make available customers for their  products are available and in cyprus and that's what their position  hyperspace and even employees under the regulation of the central bank page seven fifty six they said mr cafe this is on the examination that he says basically to offshore loans open accounts for those to verify their signatures because we have lots of documents to center cyprus like we did with roy that it was or what if you're right but we don't know they even have a new york office and you have well you have three different offices listed london and new jersey and new york just within a few pages of appendix b the issue is is what they had to rely upon the protections of the full faith and credit of new jersey law you know we were doing first there was this was tens of millions of dollars you run it with respect to general jurisdiction because that really addresses to suggest that we don't show  possibility of additional contacts and specific challengers stiction the head of the office talks about everything they've done they provide loans out of this office the bank accounts you know this one was this case file jurisdiction you know it is true we have lots of documents lots of documents relating to bank of cyprus relating to learn spank if you're honest may not even it's not easy when you are dealing with foreign banks and when they want to play when they want to not give you documents they have been very successful in this case to seem to suggest i don't want proved to be is wrong stablish third circuit precedent that we individuals will say when they're asked what their activities were for sixteen years what do you think i respectfully submit that that what they're really concerned about is that this bank engaged in systematic and continuous what is banking activity