Romano v. Department of Public Works & Buildings

base of operations established in part by frequency of shipowner’s voyages beginning or ending in American ports | “substantiality [of contacts is] to be determined on an absolute scale and not by comparing or balancing the presence of certain contacts with the absence of others” | "Rule 59(d) has been interpreted by the courts as conferring jurisdiction upon the trial court to act upon its own initiative only during the ten days immediately following the entry of the judgment." | 40% of its voyages were either to or from American ports | most voyages either originated or terminated in United States ports | 40% of its voyages were either to or from American ports