Lelchook v. Société Générale de Banque au Liban SAL, No. 21-975 (2d Cir. 2023)
Annotate this Case
Plaintiffs are 21 U.S. citizens who were harmed, and the estate and family members of a U.S. citizen who was killed in rocket attacks carried out in Israel in 2006 by the terrorist organization Hizbollah. Plaintiffs alleged that the Lebanese Canadian Bank (“LCB”) provided extensive financial assistance to Hizbollah in the years leading up to the attacks. In 2011, Defendant Société Générale de Banque au Liban SAL (“SGBL”) acquired all of LCB’s assets and liabilities in a transaction conducted under the laws of Lebanon. Plaintiffs sued for damages under the Anti-Terrorism Act of 1990 and sought to hold SGBL liable as LCB’s successor. The district court dismissed the complaint, concluding that SGBL did not inherit LCB’s status for purposes of personal jurisdiction when it acquired LCB’s assets and liabilities.
The Second Circuit concluded that Plaintiffs’ successor-jurisdiction theory raises an important and unresolved issue under New York law. Accordingly, the court certified the following two questions to the New York Court of Appeals:
1. Under New York law, does an entity that acquires all of another entity’s liabilities and assets, but does not merge with that entity, inherit the acquired entity’s status for purposes of specific personal jurisdiction?
2. In what circumstances will the acquiring entity be subject to specific personal jurisdiction in New York?
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.