Coach IP Holdings, LLC v. ACS Group Acquisition LLC
1:23-cv-10612
S.D.N.Y.Jun 11, 2025Background
- Vinci Brands LLC (“Vinci”) asserted third-party claims against Case-Mate, Inc. (“Case-Mate”), alleging tortious interference related to a licensing relationship with Coach, a New York-based corporation.
- Case-Mate moved to dismiss for lack of personal jurisdiction; the motion was construed to address Vinci’s Amended Answer.
- Vinci’s Amended Answer alleged jurisdiction under New York’s long-arm statute (CPLR § 302) and general jurisdiction (§ 301), but later focused solely on § 302(a)(1)—transacting business in New York.
- The Amended Answer asserted that Case-Mate entered into a licensing agreement with Coach, which included a New York forum-selection and consent to jurisdiction clause.
- Key factual allegations about Case-Mate’s direct business conduct in New York (such as sales or physical presence) were omitted from the Amended Answer.
- The court considered whether these facts supported personal jurisdiction over Case-Mate for Vinci’s claims.
Issues
| Issue | Vinci's Argument | Case-Mate's Argument | Held |
|---|---|---|---|
| Personal jurisdiction (transacting business) | Case-Mate’s activities with Coach tied to New York suffice for § 302(a)(1) jurisdiction. | Case-Mate lacks sufficient contacts; no specific NY transactions alleged. | No jurisdiction; insufficient factual basis for transacting business. |
| Enforcement of forum-selection clause | Consent in Coach agreement binds Case-Mate to NY jurisdiction. | Vinci is not a party or beneficiary to Coach agreement. | Vinci can’t enforce clause; not a third-party beneficiary. |
| Factual sufficiency for jurisdiction | Previous answer included specific NY contacts, suggesting sufficiency. | Amended Answer omits key allegations of NY contacts. | Allegations too conclusory; absence of specific New York acts fatal. |
| Statutory and due process requirements | CPLR § 302(a) and due process satisfied by Coach licensing. | No specific NY-directed acts; due process not satisfied. | Both statutory and due process bases for jurisdiction lacking. |
Key Cases Cited
- Am. Girl, LLC v. Zembrka, 118 F.4th 271 (2d Cir. 2024) (prima facie showing required to establish personal jurisdiction)
- Peterson v. Bank Markazi, 121 F.4th 983 (2d Cir. 2024) (must show statutory and due process bases for jurisdiction)
- In re Platinum & Palladium Antitrust Litig., 61 F.4th 242 (2d Cir. 2023) (due process requires minimum contacts for personal jurisdiction)
- Nat’l Union Fire Ins. Co. of Pittsburgh v. UPS Supply Chain Sols., Inc., 74 F.4th 66 (2d Cir. 2023) (pleadings construed in light most favorable to plaintiff)
- In re Terrorist Attacks on Sept. 11, 2001, 714 F.3d 659 (2d Cir. 2013) (courts do not accept conclusory allegations for personal jurisdiction)
- Dormitory Auth. v. Samson Constr. Co., 94 N.E.3d 456 (N.Y. 2018) (third-party may not enforce contract unless intended beneficiary)