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The New York Appellate Division, Second Department, recently issued its ruling in In re OxyContin II, reversing the trial court’s denial of Defendants-Appellants’ motion to dismiss suits filed on behalf of 246 non-New York residents who claimed they had been injured by their use of the prescription painkiller, OxyContin.  In so ruling, the Court rejected the trial court’s reasoning that so-called “mass torts” in non-class actions should be adjudicated in a single forum to maximize judicial efficiencies, without regard to whether any particular non-resident’s case, standing alone, would be properly subject to dismissal under the long-standing doctrine of forum non conveniens.  The decision is important to manufacturers of nationally marketed products as it thwarted plaintiffs’ counsel’s efforts to utilize the State’s procedure for pre-trial coordination of cases properly filed in New York to bring and aggregate hundreds of actions by out-of-state plaintiffs in a New York forum.