keep going on good morning good morning mate please the court i'm having a rubenstein representing the divided petitioners i will address the jurisdictional issues and my colleague mr major will address the remaining issues in his argument twenty  section seven hundred eighty two allows district courts to order discovery from any person who resides or is found in the district the district court below held that it lacked personal jurisdiction over banco santander under section seven hundred eighty two and in doing so committed reversible error for at least three reasons what this found mean found the plane the plain meaning of the word would require some form of presence but in this but this court in edelman interpreted  process was satisfied that section seven hundred eighty two and the term found in the statute did not impose any additional requirements above and beyond due process so i would say our responsibility is to sufficient to comply with due process if the basis of jurisdiction is specific personal jurisdiction then in that case the if the respondents contacts in the district must either relate to or arise from the from those activities so in this case we're relying on specific personal jurisdiction so the test is whether the discovery that sought arises from or relates to the respondents contacts with the district and how exact has made here so in this case the appellants are seeking discovery regarding santander's participation in the acquisition and resolution of in this district before with before and after the acquisition baucus entendu air participated in a multi billion dollar capital raise in order to be able to fund that acquisition  daimler test applies both for jurisdiction as well as document production of seven hundred eighty two for four corp the rules of the save you don't think it's different you know at least you're not arguing here you're just arguing specific jurisdiction that's correct certainly in the appropriate case for general jurisdiction was otherwise met it would apply but in this case what we all we do contend that the statute also encompasses specific personal jurisdiction and we are relying on specific personal jurisdiction in this case and not general jurisdiction in this case the court has personal jurisdiction under section seven hundred eighty two both as a statutory matter and as a constitutional matter as a statutory eighty eight with over twenty five billion dollars into specific jurisdiction so in both chloe as well as in bank brussels lambert this court held that the relevant context for jurisdictional purposes in addition to those on which the cause of action or in this case the discovery is either arises from relates to other context can also be taken into consideration so for example in chloe this court relied in part on the fact that the defendant in that case in the trademark infringement case had sold bags counterfeit bags involving manufacturers that were not part of the cause of action the court nonetheless found that that was still part of the general plan that demonstrated that the defendant was targeting the particular district so we certainly are not saying that that underlay that context by themselves would be sufficient but what we are saying is that where the in this case the respondents contacts arise from  relate to the discovery that is being sought combined with other acts of bridge in new york city relate to that so in this case if for example the term found is interpreted to involve some form of presence in the district then the fact that they have had a branch in new york city since nine hundred seventy eight certainly implies a presence in the district but in addition to the statutory grounds we also believe that th personal jurisdiction over banco santander easily meets due process because sometime there has substantially avail itself of the privileges of doing business in new york and has purposely directed its activities at this district for decades for all of these reasons we respectfully ask this court to reverse the district court's holding and to find that the court that the district court has specific personal jurisdiction over there to order the request of discovery i reserve the balance of my time has got two minutes for hundred eighty two has authorized document discovery in accordance with the federal rules of civil procedure and since prior to nine hundred sixty four those rules have been consistently interpreted to allow discovery of materials in a respondent's possession custody or control regardless of physical location as the eleventh circuit held in syria gave the only circuit court to have decided this question to date the expressing corporation of the federal rules demonstrates that section seven hundred eighty two likewise permits discovery of materials in a response possession custody or control even if those materials are located abroad santander argues on appeal that the reference to the federal rules is not enough they say that if congress had intended section hundred eighty two to reach documents located abroad it would have said in the statutory text that it reached documents located abroad but in morrison versus national australia bank the supreme court said that such an explicit statement in the statutory text is similarly the rico statute allows the enforcement of a conduct regulating predicate statute but even if the presumption were to apply to a statute like seven hundred eighty two what it requires is a clear indication not a clear statement there was an exchange between justice stevens in dissent and justice scalia in the majority in morrison about that question and justice scalia tonight that morris and imposed any explicit statement rule and i would submit i don't think any of the subsequent cases have imposed any impediments imposed by letters rule retore which were converso and inefficient and so forth and give people a different and more clear cut route to getting discovery to be and foreign proceedings but here you come to new york and you're trying to get documents that  rules and your you know trying to capitalize on what seems to me to be slight contacts between the transaction in new york city to walk around all of this european litigation you are involved well a number of points if i may on your honor first i think you my clients pimco anchorage are american entities so i don't think that you know we've come from abroad to take advantage of american statutes i will say th i think a consequence of the per se bar that santander is asking for here is that the same subpoena if issued in a domestic litigation would reach documents in a respondent's control that happen to be located abroad but if that exact same subpoena is served on the same party out of the same issue in court in support of a foreign litigation it would not reach those documents and we would submit that that's well we would think that we submit that's contrary but in any event i would say more over gathering restrictions and if these documents are in spain or the e u why wouldn't run right up against that well i think you put your finger right on it your honor it is a factor to be considered by the district court in its discretion under entities but as to as i guess the determination was that this discovery was not as a practical matter available there is the question that it was really focusing on the first factor that there was not the santander entity certainly  s is not a party to any of those foreign proceedings the s a s being the domestic and city that we got discovery on but the others are the others are botanists so well now i know that third factor of into if i might be in the e u general court proceeding santander some of the santander entities have applied to intervene we have put in a an affidavit it's obviously not my area of expertise european law but my understanding is that it's far from clear that the interest santander claims there will be sufficient to allow intervention and it has not yet intervened so in that proceeding it's a and in the spanish criminal proceedings the district court noted the sent hand or had at the point at the time of the order produced only twelve documents that it was not participating and did not seem to be quick to participate in that proceeding intel also advises that the discoverability of the requested documents is not a barrier in foreign proceedings is not a barrier per se statutory barrier to discovery under section seven eighty two my point really your honor would be that all of these things are factors a district court is well equipped to assess on an application it has the authority on the statutory text to set the procedures for discovery and it has the authority under intel to exercise its discretion to deny discovery here that didn't happen and the district court did order the discovery and what we are resisting is the imposition of an extra textual per se bar in the statutory text that's what you're that's fine i one other point if i may briefly is that and i think i began to say in age there we don't think a petitioner will know ex ant its documents are necessarily located we don't think the court will know and so we don't think that santander's proposed rule would affect in any way the number of applications under seven hundred eighty two all it would do is require the district court to make a finding in the first instance as to the location of responsive documents seven hundred eighty two we think doesn't impose burden on the district courts its focus is not on the location of documents but on the location of the respondent as long as the respondent is here under the appropriate test it is compelled to participate in discovery the district court can limit that discovery but if it is pursuant federal rules it reaches all documents within the problem our control our have with your approach is that i mean if we if we adopt what you on wholesale and will mean that this city really will become you know the world capital for discovery when every major bank has  offices here every you know foreign financial institution of any kind of consequence has banks here has has branches here and cetera et cetera and it's you know it's a city full of good lawyers and you know come to new york and get your discovery for use in buenos aires or  that those rules were fashion you know before the cloud before the you know massive documents that are online in print possession and custody control had a very different connotation twenty five years ago than it does now i mean every document that you know paribus bank has could probably be accessed through some computer up on park avenue in their office here well i think that's an issue the court addressed in the microsoft case both in the panel decision and in the denials the distance from the denial of rehearing in bank  there it's a case that santander relies on there the question was whether a subpoena under the store communications act sorry a warrant under the store communications act ought to be treated like a civil subpoena under the federal rules or like a criminal criminal warrant which is generally territory restricted and the answer in that case was that it ought to be treated like a warrant and therefore did not reach abroad the assumption among everyone as far as i read the cases is that if it were treated as a civil subpoena it would reach abroad  we also think that i think the point the judge ronan raised in his denial from his dissent from the hearing is that the focus in discovery is typically on the location of the part good morning please the court my name is albert lin and i represent the respondents below your honors if i may i'd like to start with where judge parker had started which is what is the meaning of the word found and as my friend here i think candidly admitted the plain meaning of the word is physical presence and that's what this court said in edelman and so i don't mean to tag jurisdiction case and the holding applies to tag diction yes your honor what it was it was dealing with an individual who was nonresident he was subpoenaed when he came to new york city physically present in new york city and they served process on him and what the court said this court said in adelman was we endow the word found with the same breath it is given and burn jurisdiction case but what it's talking about there is exert exercising general jurisdiction over a nonresident physically present entity but how does that apply to corporations though it doesn't and i think that's exactly the point so adelman defines found as having the same breath which i think covers both the floor and the ceiling as to what it means which means that it goes to physical presence tag jurisdiction doesn't apply after  know i think i do use a different word than meaningless but i would say yes seven hundred eighty two this and that is because and you think congress intended this meaningless statute as to every other entity that doesn't have a principal place of business or is incorporated in new york surely they did not i think if you look at the twin purposes which are talked a lot about in the briefs as to efficiency and devising a regime that it encourages other countries to follow the same pattern to adopt the same type of statute  does make sense i think general jurisdiction is much more of an efficient at and minister will regime than a case by case basis if it jurisdiction where you're delving into the facts of what any individual entity did here and that has to do don't they they delve into the facts and make some discerns decisions which generally really we review for abuse of discretion i don't disagree with you and i'm just saying that in terms of the purpose one of the purposes is is efficiency and the other purpose is encouraging other countries to adopt the same regime and a regime that is limited to general jurisdiction makes sense if you applied in every country because then what you have is you come if you can't get the discovery for in your foreign proceeding in the case itself you go to the other country if it's the united states letters judge parker remarked i think in one of his questions earlier that that was a determined by congress to be a relatively inefficient system well what you have but you know and i know from having probably tried to do it right but what you have under our reading of the statute is you come to the united states if there's a u s resident there's a u s corporation or there's an individual who is suggesting through the united states who is temporarily right present but not physically present and we have unique access to those individuals and entities and to order them to produce discovery to a foreign proceeding and if the rest of the world follows that lead which was one of the purposes of seventy two then if you've got spanish corporations and spanish residents and individuals are joining through spain you go to spain and use their seven hundred eighty two mr what's the basis after dimler to say this if it jurisdiction doesn't exist under seven hundred eighty two so if you say everybody seems to agree that daimler applies here to the general jurisdiction of as to corporations under seventy two you are arguing that that portion of daimler that survives for a specific jurisdiction wouldn't apply is that right is what you're saying no your honor so what we're saying is there's no dispute as to let's go back to the statutory language if i may were resides or is found and everyone agrees that resides reaches residence and that that's most of general jurisdiction and then found what do you do with found and we think that the both the plain meaning and edelman say that found applies where there is physical presence and so before dime lower maybe there's a good argument there that physical presence applies to both individuals and corporations but after dime lower you cannot apply a physical presence test to corporations so you can apply a specific jurisdiction you can apply general jurisdiction pacific jurisdiction what about specific jurisdiction here under seventeen eighty two we don't think this is for the s o s ruling the basis for the jurisdiction over us i guess was gen asses principal place of business is here in new york that's right and its argument is that found doesn't reach specific jurisdiction found reaches as mr rubenstein said physical presence general jurisdiction where there is physical presence if we if the united states succeeds in one of their purposes in seventy two which is to get other countries to adopt the same regime then what you do with a foreign corporation is you go to that foreign corporations home and you use the sevent there to get the discovery from them you don't have to come to the united states the united states is seventeen she was not meant to fix all the world's discovery issues so if the problem with interpret essentially to be extended the limits of due process protection so our four main argument is we don't think we think this court decided that in edelman we think the plain meaning of the word found doesn't get you there we think it gets you only to physical presence and that if you apply that to corporations it runs into dima but if since my time is moving on if we want to talk about specific jurisdiction judge parker has asked what would the test be for a specific jurisdiction and we think if you follow the lead of the test is that there has to be a causal connection between the alleged specific contacts and the underlying foreign proceedings that the seventy two petition is seeking to aid because the test in the civil contract in the civil liability context is that there has to be a causal connection between the alleged contacts and the in a case where you have as in gucci itself just a discovery enforcement proceeding so you've got a subpoena you've gone to the district court and you're seeking to enforce a subpoena the causal connection between the alleged contacts and the relief requested is between the the alleged context and the discovery request here this is at an antecedent stage to the discovery request what they're asking for is the district court to exercise it authority under seventy two and to grant their seven hundred eighty two petition there's not always going to be a discovery request at this stage in the proceeding if you look at edelman itself the request in edelman was that the district know j p morgan to help them devise a a strategy for taking over the bank could you get documents here under seventy so there are first answer is that those are the facts here we don't think that they've court but i say that only to because we don't think that they have alleged enough here to make official case that citibank was retained a hypothetical question i understand your honor and my response would be appends on what the nature of the underlying foreign litigation is same same same far as we have you then i then the answer would be no and here's why because what's at issue in the underlying litigation is that they should put popular into resolution what's at issue in the criminal proceeding is the management conduct of the popular managers before and leading up to the resolution so we would say your honor even if there are sufficient facts to show that there was some sort of due diligence or planning done for the acquisition here in new york city and we don't think there are that would not be a but for cause or a proximate cause and as this court knows under chu versus dietrich you r specific jurisdiction causal connection is a sliding scale depending on how many contacts there are we don't think it would either be a but for cause or where do we get to yes in this case what would the facts have to be if you're george ramos you should have ordered discovery for get the foreign of course of course of course so i think  one if you had a bank that had its principal place of business or headquarters in corporation in new york city you'd have general jurisdiction so bongo would have to be here but if you were here so for example  contest that there was general jurisdiction over us yes they would also if you were to extend has to send tender if bango were here we would have general jurisdiction as to santander if santander's p p b or place of incorporation where officials with the banks and five hundred hours with goldman sachs trying to develop a strategy to get their hands on the bank the work product from those five hundred hours w j p morgan couldn't be reached from seven through seventy two not in this case because the underlying litigation is not calling into question that conduct if to spend the further hypothetical for judge if if the underlying litigation were calling that in question you don't you would agree that seven hundred eighty two subpoena could issue here we would have a much much closer case and maybe the answer would be yes for the goldman documents right if there were yes if there were if there were facts that show due diligence significant due diligence all the due diligence happening here in new york city the underlying litigation was specifically addressing the the i think you have to weigh the question about for cause versus proximate cause and how many contacts there are and right i mean i think if how could a judge do that and in that context all is asked to do is issue being asked to do is to impose on district judge and judge parker my answer to you there would be that's exactly i think the problem with getting into a specific jurisdiction analysis in seventy two context look before this case and before diamond  know i'm still wrestling with you is seems to me that the general i don't i don't really see you haven't convinced me that your general jurisdiction test is   that's why i ask you what tests we might have to fashion because we've got a job to do so the fact that you haven't found any cases you know is interesting but it doesn't get us very far helping to  create yes you're and i was i was just trying to address explain sort of give you an example of what district courts have been doing the way that they have applied much time or even tell us what the district courts have been doing but we need to know what we should well your honor i think we think the meaning of found was a terminal at home and i think that addresses the practicability concerns however i think if you extend it the statute to specific jurisdiction there's no basis for changing the way specific jurisdiction applies as this court recognized in future you translate the specific jurisdiction test from the civil liability context by asking what is the relief that is requested in the civil liability context you look for a causal connection between the claims and the alleged context in the discovery where you have a straight up discovery request like a subpoena and force make you look for the causal connection between the alleged contacts causal connection and the you're not dealing with a cause of action or claim you're simply asking for discovery you're trying to learn something you know necessary sometimes you're trying to confirm what you already know but you know the whole purpose of i mean one of the major purposes of the discovery provisions is to find stuff how well your honor i'm not sure what the what the relaxed test would be in the other side hasn't proposed one and i mean to answer your question for the deceiving you an opportunity for input into that because we are as i told you a minute ago we've got a fashion a test in the discovery context what this court looked to in requests of the specific requests that were being asked now i think that the issue with applying that test here is that this is not always going to be to your point about needing a test for all seven hundred eighty two petitions there is not always going to be a discovery request in a seventy two context at the outset and the reason for that is the request being made at the outset is a different question it's asking where the  the three statutory factors for seventy two satisfied do the what what does the district or do with the intel factors and so we think that the relief being requested is that the district court exercise his or her authority aid a foreign proceeding and so that is the thing to which the alleged contacts must be connected the underlying foreign proceedings here the underlying foreign proceedings challenge the actions of the european regulators they challenge the actions of the former popular managers and so even if there were facts here that had anything to do with banco santander as preparation those were not be enough but we also think that the facts alleged here are extremely thin i mean they they include an allegation as to the c e o suntanned they're ringing the bell the new york stock exchange and then the frankly unreasonable inference that you know he then talked about something that had to do with this acquisition but discover a the antecedent question here is are the are the legal requirements for seventeen to satisfy that's what's being asked for it's the what they're asking for is a district court to grant that authorization and so we think the connection is not between whatever subsequent disco use and the word found in seventeen eighty two means something different that what she was talking about for specific years the action under the federal rules of civil procedure document production is that is that why you think there's a distinction yes to a degree i mean again i think we think found his limited to physical presence but i think and so this is why i have having a little bit of trouble with your question because we don't think found a little trouble with your answer so i'm trying to figure out what the distinction is with gucci which said if they can establish this civic jurisdiction in  after talking about general jurisdiction talking about the difference between the the asset freeze order against the bank and then talked about the discovery request against the bank in gucci the court we said that we got to apply the general test after at this court cited is as to the the specific jurisdiction analysis you have to link there has to be a link between the alleged specific contacts and the relief that you're asking for in that case the relief the relief that they were asking for was the discovery and so the question that judge sullivan answered on remand was what were the things that are alleged to happen new york city and had to do with bank accounts transfers and those have a causal connection to the relief requested the discovery we're just saying that you take that same test connection between the alleged contacts and the relief requested and you apply that same test here that's the same test for specific jurisdiction that applies in every context the relief requested changes from context to context right and civil enters strategy for over comp for taking over the bank we would say that that would that be sufficient know your arm because that's not what honor i think if the underlying foreign proceedings were were actually asking about things that get bankers conduct here or there then it would be a different case and i think your point about as i was answering before i think that the connection would be tighter there likely to be about bank owns conduct anywhere that sandy handor ended up knowing about in the course of doing some due diligence here in new york it found out about some stuff under norden and therefore they're in trouble with you know they've got a case going in spain and the regulators you know about the regulators whether the declaration should be placed you know your honor i think it just it gets into a question as to what the underlying proceedings are about and i think only underlying proceedings are about somebody screwed up right here the allegation is that the people who screwed up were the european regulators or the former irregularity to pick up on judge parker's thread why should why is that not relevant to what's going on in spain and i think it again i think then it depends you know the answer depends on what exactly the specific alleged contacts here are i mean if the if the allegations are that you know we received information here in new york city that is you know somehow gives rise to or led to the resolution then yes your honor i think that there would be that connection i don't think in answer to that i don't think that that connection exists here because that adequately explored by the district court i think the i think the district court looked at the allegations that were made here for specific jurisdiction and concluded that they were far too thin  to to have that but it did did it analyze it in terms of what i what i something along the lines of what i said i think what the district what the district did was it said look there are no allegations about you know the non speculative allegations about things that happened before the resolution so i don't need to get i don't need to get into this question your honor that you're asking i think if there were non speculative allegations about things that came to new york city documents you know fraudulent documents i came to new york city and we relied on before the resolution we again we would have a different case in the district court may need to go into a deeper analysis but here the allegations have to do with things that happened afterwards or they're totally speculative allegations about things that may or may not have happened in new york city they allege as i sa that the c e o of cent under rang the bell at the new york stock exchange they allege that we hired citibank but there's no indication and there's no it's not a reasonable inference that the citibank individuals who we used were located in new york your honor if seventy two extensive specific jurisdiction i think they were there would be a different a different case did we want to talk about extraterritoriality at all your honor i do think it's it's relevant to remember  particular reason the factual allegations that they've alleged relate only to sometime there they do not relate to santander holdings they do not relate to sent on their bank the undisputed affidavits in the record as to santa and their show that all of those documents are located overseas sent on their after declaration we have says that the documents are primarily vast majority are in spain some are in the united kingdom the only documents that are acknowledged to potential to be in the united states that are potentially relevant are documents of sent on their holdings they have made no allegations at all with respect to any contacts in new against extraterritoriality yes your honor i just want to clarify that as to if you're looking at specific jurisdiction you're only looking at sent on there and i think the reason you should need to resolve the extraterritoriality question is because all of those documents are overseas so as to the analysis there we think first of all the presumption applies under morse and and cases of this court and then secondly we don't think the presumption is overcome because the federal rules of civil procedure are not mandatory in the statute and they don't give the authority for the district court to a foreign proceeding thank your honour's if you look at the al fayyad vs cia case from the d c circuit it provides a good explanation of the antecedent question as to where the authority comes from it doesn't come from the f r c p it comes from the statute to the new statutory language and so then i think judge droney we're into the second step of the extraterritor focus and i think as to the focus of the supreme court's recent decision in western geko the one that came out last spring by justice thomas it says when you're looking at the focus you're looking for the overriding purpose of the statute the focus is not in that case it was a damages remedy statute had to do with damages for a copyright infringement and what the supreme court concluded is the focus there was not the damages being rewarded but what is the overriding purpose the overriding purpose was the infringement and so what the court looked to is where does the infringement occur we think the overriding purpose of seventy two as the supreme court explained in intel he's giving access to this evidence and there's nothing in the statute that says the access to that evidence has to occur in the united states in fact if you're doing subpoenas under rule forty five for someone who's one hundred miles away from the district that has to occur in spain so the focus of the statute is the access to the evidence that accessed in this case could occur overseas so it's not a purely domestic application of the statute and i think you can't apply thank you your honor i'd like to begin by addressing the question of whether and to what extent sometimes there is conduct prior to the resolution actually is an issue in the form proceedings it very much is if if the court looks at the request for arbitration that's been filed and that's a page fourteen forty five of the appendix the our request for arbitration goes into great detail about the activities that sometime during gauged in including its contacts with the spanish government in the weeks leading up to the resolution it also specifically refers in the request for arbitration to santander's due diligence efforts prior to the resolution and the acquisition and as we've explained the  registration statements that sometimes are filed with the f c c make clear that the capital raise was an essential requirement in order for santander to be able to proceed with the acquisition in order to avoid a material adverse change on its financial condition now we are not asserting a claim in those form proceedings against suntan there which is precisely why the concept of imposing a but for cause requirement doesn't really make any sense we would essentially be having to make a claim against on time there or be suggesting that the conduct they engaged in actually gives rise to liability when the whole point of seven hundred eighty two is to allow for discovery from non parties and so i think the record is clear that the the conduct that santander gaged in and the information that we are seeking from santander is directly related to the claims that are being asserted at both the european court of justice as well that you're making here in new york extend documents warrant it seeks documents that are in their possession custody and control we have their declarations as to w documents are located but we don't know exactly where the documents are located that will be something that would obviously have to be decided during the course of the discovery process itself they have a they have presented affidavit testimony that the documents we're seeking are substantially located in spain but i think it is important that the due diligence that was done by santander involved to new york investment bank city and u b s i mean and so and again we don't know activities and its contacts with the spanish government are directly related to the claims that are being brought against both the spanish government as well as the european union we have we have no claims with regard to any activities by city partly the reason is we haven't seen the what exactly city did to spain so the reason is that in my clients are seeking to use these documents and to form proceedings international arbitration proceedings against the government of spain and claims that the european court of justice sometimes there is not a party to those clear to those cases some tender has tried to intervene in those cases but those intervention applications have not been granted  third party discovery in spain no the we have presented below expert testimony that where you have a nonparty the court and the arbiter tribunals cannot order those non parties to produce documents and so and i think that is important because i don't want the record to reflect or suggest that we're trying to circumvent any foreign proof gathering restrictions that is not the case and in fact the judge judge ramos found that the documents that are being sought are beyond the control beyond the reach of the foreign tribunals and we would submit that that was a correct determination going back to judge parker's question what is the test what is found mean and we believe that consistent with edelman and other courts that have interpreted the term found in other jurisdictions statutes we think that essentially there is no bright line but we think that it requires sufficient contacts in the district to meet to reach fireman's one the discovery must arise from or relate to the respondents contacts in the district and second those contacts in their totality which would include the related to contacts and general contacts with the district must be sufficient to satisfy due process and we think that those two requirements in combination with the discretion that courts have both under section seven hundred eighty two and the intel factors as well as the discretion that the courts have applying the federal rules we think that that will be sufficient to avoid any sort  of slippery slope or any clearinghouse for from arising and and as mr major said if that were to be incorrect and we don't think it is obviously then it would be up to congress to decide to intervene but we don't think that's necessary we think that the related to requirement and we think that the due process requirements of minimum contacts provide plenty of safeguards to prevent any sort of abuse of the statute judge ramos find related to  he consider that in the context of our and so our view is that the judge did not consider the related to component he certainly articulated the test but he only applied the arises from a piece of it the respondents were defendants context give rise to the cause of action that's one thing if on the other hand they're related to involves items that would not necessarily be related to the contacts in the district so a good example actually would be in chloe in chloe in chloe this court held that there was sufficient personal jurisdiction even though the the respondent counterfeiter had only sold one counterfeit bag into the city into new york city the court though also looked at other sales of counterfeit bags involving other manufacturers even though they didn't the the underlying cause of action for trading trademark infringement didn't arise from the sale of town or fit bags involving other manufacturers but the court said they do relate to the contacts in the district and that in combination the court held was sufficient to establish specific personal jurisdiction thank you very much thank you all three of  e arguments helpful and not surprisingly will reserve decision