One of the mainstays of New York real estate litigation practice is the Yellowstone injunction. First announced in the landmark case of First Nat. Stores, Inc. v. Yellowstone Shopping Ctr., Inc. (21 NY2d 630 [1968]), a Yellowstone injunction—available to commercial tenants—tolls the running of the cure period set forth in a default notice so that the tenant can challenge the notice and litigate the merits of the alleged default without losing its valuable commercial tenancy.