The protection of New York's medical consumers took another blow last week from the Court of Appeals in Paterno v. Laser Spine Inst. (2014 NY Slip Op 08054, 11/20/14). In an almost counter-intuitive analysis, the Court decided that defendant, who gleefully trolled for NY back patients to surgically repair at their facility in Florida, could avoid NY jurisdiction because all it did in NY was, well, inveigle its patients into coming to Florida. A passive website, emails and instructions for tests to be conducted in NY were not enough, said the Court, to justify long-arm jurisdiction and the NY malpractice action is dismissed. The reality, the Court offers, is that "[i]t is no longer unusual or difficult, as it may have once been, to travel across state line in order to obtain health care from an out-of-state provider." Nor is it unusual to "expect follow up for out-of-state treatment." The reality is, the Court suggests, that this is a new, internet/fax/email world which affords less protection to a NY victim, thanks, in no small part, to a long-arm thesis which no longer has any tether to the real world in which it exists.