the concerns against which the dormant Commerce Clause protects. See Mills, 593 F.3d at 667-68 (reasoning that allowing one state to trump the legislative determinations of another in this manner “would be arbitrarily to exalt the public policy of one state over that of another”). 29 . For much the same reasons, the statement in plaintiffs' complaint that "[t]he relationships between DBA Holdings and the debt collectors it engages to seek to recover on debts are governed by contracts that are entered into outside of N.Y. state,” is insufficient. (Compl. ¶ 53.) Even if this statement is construed as a factual assertion, rather than a conclusion of law, it is far too thin a reed to support summary judgment. Cf. S.K.I. Beer Corp. v. Baltika Brewery, 443 F.Supp.2d 313, 323 (E.D.N.Y.2006) (<HOLDING>). 30 . In adopting amendments to the
holding that conclusory allegation of conspiracy without supporting factual averments insufficient to state claim holding that the interstate commerce requirement for a hobbs act violation was met where the defendant robbed a new york grocery store that sold goods purchased in new york but produced outside of new york because the robbery depleted assets that might have been utilized to purchase outofstate goods holding that outofstate defendants transmittal into new york of ceaseanddesist letter to new york plaintiff for purported trademark infringement was insufficient to create jurisdiction over defendant in a new york declaratory judgment action holding jurisdiction over nonresident 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 holding that conclusory allegation in complaint was insufficient to demonstrate that defendant offered to sell goods within new york