Bulova Watch Co., Inc. v. K. Hattori & Co., Ltd.

New York watch manufacturer and retailer Bulova Watch Company, Inc. (Bulova) (plaintiff) sued K. Hattori and Co., LTD (Hattori) and others (defendants) for unfair competition, disparagement, and conspiracy to raid staff and appropriate trade secrets. Hattori was a Japanese watch retailer and sole owner of New York corporation Seiko Corporation of America (SCA), which was itself the sole owner of New York corporations Seiko Time Corp. (Seiko), Pulsar Time, Inc. (Pulsar), and SPD Precision, Inc. (SPD). Hattori distributed its products world-wide via its wholly owned subsidiaries, and the U.S. was Hattori’s largest foreign market. In 1975, Hattori assigned its manager, Moriya, to New York, where Moriya served as president of SCA; director of Pulsar, SPD, and Seiko; and on the boards of other Seiko distributors. Prior to moving to New York, Moriya had only worked for Hattori or one of its American subsidiaries, and Moriya maintained his managerial positions with Hattori even after his relocation to the U.S. In 1978, Hattori sought to market a new product line that Seiko had acquired. To that end, Moriya hired three Bulova executives to work for Seiko in 1978, who then recruited several other Bulova sales managers and salespeople to join Seiko or one of its subsidiaries over the course of the following year. Bulova sued, and Hattori moved to dismiss the complaint for lack of personal jurisdiction, claiming that Moriya’s actions were performed solely for the American subsidiaries and not for Hattori and that the subsidiaries were formally separate entities whose New York presence did not confer jurisdiction over Hattori.