TechnoLines, LP v. GST Autoleather, Inc., No. 11 C 965, Slip Op. (N.D. Ill. Jun. 30, 2011) (Grady, J.).
Judge Grady granted defendant GST’s motion to dismiss plaintiffs’ patent claims for improper revenue and lack of production and dismissed the remaining state law claims without prejudice to be refiled pursuant to diversity jurisdiction, if possible.
The Court’s key rulings were:
- GST’s failed license negotiations with plaintiff Echelon in Illinois alone could not create personal jurisdiction.
- Echelon residing in Illinois and, therefore, having been allegedly harmed in Illinois does not create personal jurisdiction. GST’s conduct must have been specifically directed at Illinois. And there was no evidence that GST sold product into Illinois.
- GST’s phone calls and emails to Echelon in Illinois did not create personal jurisdiction.
- The Court refused supplemental jurisdiction over the remaining state law claims, and gave plaintiff a deadline for repleading based upon diversity jurisdiction, if it could.