chain based on the activities of affiliated reservations service); Gelfand v. Tanner Motor Tours, Ltd., 385 F.2d 116, 120-21 (2d Cir.1967) (applying Frummer to find jurisdiction over tour operator based on the activities of affiliated travel agent). To come within the rule, a plaintiff need demonstrate neither a formal agency agreement, see, e.g., New York Marine Managers, Inc. v. M.V. “Topor-1”, 716 F.Supp. 783, 785 (S.D.N.Y.1989), nor that the defendant exercised direct control over its putative agent, see, e.g., Palmieri v. Estefan, 793 F.Supp. 1182, 1194 (S.D.N.Y.1992). The agent must be primarily employed by the defendant and not engaged in similar services for other clients. See, e.g., Miller v. Surf Properties, Inc., 4. N.Y.2d 475, 481, 176 N.Y.S.2d 318, 151 N.E.2d 874 (1958) (<HOLDING>). Both Magistrate Judge Pitman and Judge Wood
holding that independent contractors with many clients are not considered agents of their individual clients for jurisdictional purposes holding immunity from liability is not jurisdictional holding that wrongful or improper purpose must be shown for jurisdictional purposes holding that regulatory requirements are not jurisdictional in nature holding that statutes of limitations are considered substantive matters for purposes of the erie doctrine