Whether the Panel was correct in not following major decisions of both this Court including Daimler v. Baumann and International Shoe and its progeny in concluding that the District Court had jurisdiction over Grist Mill Capital LLC which had no contacts at all with New York

QUESTIONS PRESENTED “Absent an exceptional circumstance, a corporation is subject to general jurisdiction only in a State where it is incorporated or has its principal place of business.” Mallory v. Norfolk S. Ry. Co., No. 21-1168, 2023 WL 4187749, at *21, 2023 U.S. LEXIS 2786, *54-55 (U.S. June 27, 2023) (cit. omitted). Turning to the exercise of specific jurisdiction, “[t]he inquiry whether a forum State may assert specific jurisdiction over a nonresident defendant focuses on the relationship among the defendant, the forum, and the litigation.” Walden v. Fiore, 571 U.S. 277, 287 (2014) (internal quotation marks omitted). “[S] pecific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.” Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011). A court must look to “whether there was some act by which the defendant purposefully availed itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” Jd. at 924 (internal quotation marks and brackets omitted). “[T]he defendant’s suit-related conduct must create a substantial connection with the forum State.” Walden, 571 U.S. at 284; see also Goodyear, 564 U.S. at 919 (exercise of specific jurisdiction requires an “affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State”). “(A] defendant’s general connections with the forum are not enough” to support the exercise of specific jurisdiction. Bristol-Myers Squibb Co. v. Superior Court of Calif., San Francisco Cty., 585 U.S. 255, 264 (2017). Whether the Panel was correct in not following major decisions of both this Court including Daimler v. u Baumann and International Shoe and its progeny in concluding that the District Court had jurisdiction over Grist Mill Capital LLC which had no contacts at all with New York. Whether the Panel was correct in stating there was a “reasonableness” time limit on a Rule 60(b)(4) Motion to vacate a void judgment. Whether the Panel was correct in stating there was a “reasonableness” time limit on a Rule 60(b)(6) Motion to vacate a judgment in the interests of justice.