Conflict of Laws – Brokerage Contracts – Out-of-State Broker Denied Commission Because of Isolated Acts Within Forum

Plaintiff was a Massachusetts real estate broker, not licensed to do business in New York. Defendants, who resided in New York, owned real estate in Massachusetts and executed a brokerage contract there with the plaintiff. The real estate was leased to a Massachusetts corporation through plaintiff’s efforts. All of plaintiff’s services, with the exception of several important conferences in New York, were performed in Massachusetts. On plaintiff’s suit for unpaid commissions, held, for defendant. The New York brokerage laws prohibit recovery in a New York court by brokers, unlicensed in New York, who perform any brokerage services within the state. Plaintiff’s participation in the New York conferences constituted brokerage services within the meaning of the statute. Copellman v. Rabinowitz, 208 Misc. 274, 143 N.Y.S. (2d) 496 (1955).