in the manufacture of watches, its subsidiaries that acted as its sole sales agents in America were “almost by definition ... doing for their parent what their parent would otherwise have to do on its own.” Bulova Watch Co., Inc. v. K. Hattorri & Co., Ltd., 508 F.Supp. 1322, 1342 (E.D.N.Y.1981). The Bulova court thus attributed the subsidiaries’ contacts to the parent company. Id.; see also Chan, 39 F.3d at 1405-06 (remanding to the district court for additional findings of fact regarding agency where the German parent corporation owned and operated cruise ships and its local subsidiary marketed cruises and chartered cruise ships and sold the cruise ticket to the plaintiffs out of which the claims arose); Modesto City Schs. v. Riso Kagaku Corp., 157 F.Supp.2d 1128, 1135 (E.D.Cal.2001) (<HOLDING>). In contrast, where the parent company owned a
holding subsidiary involved in manufacturing marketing selling and distributing cigarettes was not parent companys agent under gallagher test because the parent holding company could simply have held another type of subsidiary holding that control person liability adequately alleged because as the sole shareholder of the subsidiary the parent corporation had the potential power to influence and direct the activities of its subsidiary holding subsidiary was parents agent for personal jurisdiction purposes where subsidiary acted as sole conduit for marketing and selling parents products in the united states holding there is no precise test for defining how much control a foreign parent corporation must wield over its domestic subsidiary before the subsidiary will be deemed its agent for the purposes of service recognizing separate corporate identity of parent despite evidence that parent consolidated its profits and losses with that of its whollyowned subsidiary in presenting parents financial reports to shareholders that subsidiary was considered a division of parent and that subsidiary accounted for 60 of parents and subsidiarys combined operations