The totality of Züfle's alleged acts, whereby she availed herself of the benefits and protection of New York law, constitute sufficient purposeful contacts with New York to bring her within the reach of § 302(a)(1) of New York's long arm statute. See Bank of New York v. Strumor, 179 A.D.2d 736, 579 N.Y.S.2d 124 (2d Dep't 1992) (holding jurisdiction over non-resident defendant existed where note was payable in New York, contained New York choice of law clause and proceeds were used to finance New York limited partnership).           Züfle's alleged contacts with New York also satisfy the constitutional requirements for personal jurisdiction, subjecting her to the jurisdiction of this forum.

In determining whether a non-domiciliary has engaged in the requisite transaction of business, "the proper analysis is for the court to consider the totality of circumstances surrounding defendant's activities in New York in connection to the matter giving rise to this lawsuit." Bialek v Racal-Milgo, Inc., 545 FSupp 25, 34 (SDNY 1982) (interpreting CPLR 302(a)(1); see also Bank of New York v Strumor, 179 AD2d 736, 737 (2d Dept 1992); Capitol Records, LLC v VideoEgg, Inc., 611 FSupp2d 349, 357 (SDNY 2009). The sine qua non of jurisdiction founded upon CPLR 302(a)(1) is evidence of activities through which the defendant has purposefully availed itself of the privilege of conducting business in New York, thereby invoking the benefits and protections of New York law.