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connection be- tween the conduct and the injury; and (4) severe emotional distress." Stuto v. Fle- ishman, 164 F.3d 820, 827 (2d Cir.1999) (citing Howell v. New York Post Co., 81 N.Y.2d 115, 121, 596 N.Y.S.2d 350, 612 N.E.2d 699 (1993)). "'Liability has been found only where the conduct has been so
i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where
m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira
ollaborative." The Washington Times <https://www.washingtontimes.corn/news/2020/nov/24/alex-azar-health-secretary- already-briefing-biden-/> (11/24, Howell, 492K) also reports Azar "said Rear Adm. Erica G. Schwartz of the Public Health Service spoke to the Biden team late Monday, after the General Servi
gh the Wall Street Journal <https://vvww.wsj.corn/articles/new-york-city-police-sheriff-wont-enforce-thanksgiving-covid-limits- 11606231659> (11/24, Calder, Subscription Publication, 7.57M) reports the New York Police Department and the New York City Sheriff's Office will not enforce Thanksgiving restri
eel they need." Azar said the "transition planning and execution will be professional, cooperative and collaborative." The Washington Times (11/24, Howell, 492K) also reports Azar "said Rear Adm. Erica G. Schwartz of the Public Health Service spoke to the Biden team late Monday, after the General Servi
t government restrictions and have frequently flouted guidelines like mask-wearing and social distancing," although the Wall Street Journal (11/24, Calder, Subscription Publication, 7.57M) reports the New York Police Department and the New York City Sheriff's Office will not enforce Thanksgiving restr
minimum contacts existed since dispute arose from a contract with substantial con- tacts with the forum) (internal quotations and citations omitted); Calder v. Jones, 465 U.S. 783, 789, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (finding personal juris- diction appropriate over non-resident de- fendants who “e
Page: HOUSE_OVERSIGHT_017872 →tates. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise to their clai
Page: HOUSE_OVERSIGHT_017874 →sal connection be- tween the conduct and the injury; and (4) severe emotional distress.” Stuto v. Fle- ishman, 164 F.3d 820, 827 2d Cir.1999) (citing Howell v. New York Post Co. 81 N.Y.2d 115, 121, 596 N.Y.S.2d 350, 612 N.E.2d 699 (1998)). “ ‘Liability has been found only where the conduct has been so out
Page: HOUSE_OVERSIGHT_017895 →Entities connected to both Howell and Calder

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