Irving Cohen, D/B/A Pralcoa v. Kalwall Corporation

Plaintiff instituted an action in the Supreme Court of New York, apparently for commissions on a sale of defendant’s product, by service of a summons upon defendant’s treasurer temporarily in New York City. As permitted by state practice, the complaint was not attached. Defendant removed the case to the court below and then secured an order of dismissal for lack of personal jurisdiction.

It may be, as plaintiff suggests, that jurisdiction over non-residents is being extended, see Wham, An Expanding Concept: Jurisdiction over Non-Residents, 44 A.B.A.J. 422 (1958); but we know of no case going…