continuous presence and substantial activities that satisfy the requirements of doing business do not necessarily need to be conducted by the foreign corporation itself.” Wiwa, 226 F.3d at 95. While “the presence of [a] subsidiary alone does not establish the parent’s presence in the state,” Jazini, 148 F.3d at 184 (citing Volkswagenwerk AG v. Beech Aircraft Corp., 751 F.2d 117, 120 (2d Cir.1984)), personal jurisdiction over a foreign parent exists where its New York subsidiary is either a “mere department,” or an “agent,” of the parent. Id. (citing Koehler v. Bank of Bermuda, Ltd., 101 F.3d 863, 865 (2d Cir.1996)). Conversely, jurisdiction exists over a subsidiary that is a mere department of a parent corporation which has a presence in New York. See Cornell, 2000 WL 284222, at *3 (<HOLDING>)(citing cases). To determine whether Siemens
holding that the agency and mere department tests may be applied where the foreign parent is doing business in new york and plaintiffs seek to attribute its contacts to a subsidiary ie the converse of the ordinary cplr  301 attribution case holding that a close relationship between a parent corporation and a subsidiary may justify finding that the parent engages in business in the jurisdiction through the local activities of its subsidiary holding that a parent corporations contacts may not be imputed to its subsidiary holding that a parent company was not liable for aiding and abetting a breach of fiduciary duty by its subsidiary because the parent company was not a stranger to the business relationship between its subsidiary and the plaintiff giving rise to and underpinning the contract holding that a parent must exercise some control over the subsidiarys activities which does not require that the subsidiary be controlled to an ultimate degree by its parent  although something more than mere passive investment by the parent is required the parent must have and exercise control and direction  over the affairs of its subsidiary in order for venue to be proper