A defendant may waive the issue of lack of personal jurisdiction by appearing in an action, either formally or informally, without raising the defense of lack of personal jurisdiction in an answer or pre-answer motion to dismiss. A defendant may appear in an action where counsel communicates a clear intent to participate by actively litigating the action or participating in the lawsuit on the merits.
HSBC Bank USA, N.A. v. Whitelock, NY Slip Op 01500 (2d Dep't March 22, 2023)
