What is the test for a person to be found guilty of trespass in a foreign country?

"New York", United States of America

The following excerpt is from 166 Fifth Avenue LLC v. 168 Fifth Avenue Realty Corp., 2008 NY Slip Op 31811(U) (N.Y. Sup. Ct. 6/19/2008), 2008 NY Slip Op 31811 (N.Y. Sup. Ct. 2008):

invasion, and the intrusion must at least be the immediate or inevitable consequence of what he willfully does, or which he does so negligently as to amount to willfulness. To constitute such a trespass, the act done must be such as "will to a substantial certainty result in the entry of the foreign matter." [citations omitted].

Phillips v. Sun Oil Co., 307 N.Y. 328, 331 (1954)

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