context: Several courts have declined to treat different firms as a single entity, holding them jointly and severally liable for one another's acts, simply because they shared an associational name and/or collaborated on certain aspects of the relevant transaction.
citation_a.signal: see
citation_a.identifier: 599 F.Supp. 1241, 1249
citation_a.parenthetical: holding that existence of DH & S International, "an organization composed of a large number of affiliated accounting firms," did not prove DH & S was "a single worldwide entity" even though some brochures described DH & S (U.S.
citation_a.sentence: See In re AM Int’l, Inc. Sec. Litig., 606 F.Supp. 600, 607 (S.D.N.Y.1985) (dismissing complaint against Price Water-house entities outside the United States after rejecting argument that all Price Wa-terhouse affiliates worldwide were “in fact one entity, and acted as agents of one another”); Reingold v. Deloitte, Haskins & Sells, 599 F.Supp. 1241, 1249, 1254 n. 10 (S.D.N.Y.1984) (holding that existence of DH & S International, “an organization composed of a large number of affiliated accounting firms,” did not prove DH & S was “a single worldwide entity” even though some brochures described DH & S (U.S.) as “a single cohesive worldwide organization”).
citation_b.signal: cf.
citation_b.parenthetical: noting in dicta that defendant was not a legal entity, but "an associational name used by a group of affiliated advertising agencies which are incorporated in different countries"
citation_b.sentence: Cf. Noonan v. Winston Co., 902 F.Supp. 298, 300 n. 6 (D.Mass.1995) (noting in dicta that defendant was not a legal entity, but “an associational name used by a group of affiliated advertising agencies which are incorporated in different countries”); Howard v. Klynveld Peat Marwick Goerdeler, 977 F.Supp. 654, 660, 662 (S.D.N.Y.1997) (finding, in evaluation of personal jurisdiction, that “public relations materials suggesting] that Klynveld is a global firm or an international network of member firms” do not justify a finding of a partnership or agency between Klyn-veld and Peat Marwick US).