So, for example, in Giammalvo v 2170-2178 Broadway ( 293 AD2d 390 [1st Dept 2002]), the court affirmed a decision to strike plaintiffs jury demand as "[m]ost of the relief sought in plaintiffs' original complaint is equitable in nature." Similarly, in Willis Re Inc. v Hudson ( 2005 NY Slip Op 30025[U]), the Supreme Court struck a jury demand as having been waived by the plaintiffs initial request for injunctive relief, clearly equitable, even after that claim had been withdrawn. As that court pointed out, such a determination involving a motion to strike a jury demand must include a determination of "the primary character of the case" ( id. at *3, citing Downtown Art Co. v Zimmerman, 227 AD2d 226 [1st Dept 1996]).