Alzal Corp. v. Emporio Motor Group
U.S. DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Judge Laura Taylor Swain
Through their principals, Alzal Corp. and Emporio Motor Group agreed, in January 2012, to jointly operate an auto dealership in New Jersey. Their joint venture ended in August 2012. In addition to seeking rental and equipment costs incurred prior to Emporio's purported breach, Alzal sought legal fees and increased rents stemming from Emporio's alleged tortious interference with the sublease for the dealership's premises. Finding venue in the Southern District improper for Alzal's tortious interference claim, district court transferred suit to the U.S. District Court for the District of New Jersey, but otherwise denied dismissal. Noting allegations that the parties had engaged in negotiations and other actions in New York and had intended that business activities relevant to New Jersey auto sales would occur within New York, district court found Alzal stated a prima facie case for exercise of long-arm jurisdiction. However, all events giving rise to Alzal's tortious interference with contract claim occurred in New Jersey. Emporio purportedly barred persons associated with Alzal from the New Jersey premises. Also, Alzal allegedly had to pay increased rent for premises in New Jersey following eviction from the dealership's location.