Courts have extended the rationale from these lockbox payment cases to payments made online via a third-party platform, where, once the payee establishes an account, unsolicited payments can be easily made "as they require nothing more than a few clicks and may even be made through an application on a cellular telephone." (1371 Franklin Ave LLC v Pugh, 67 Misc.3d 368, 370 [Civ Ct, Bronx County 2020]).