Kroto Inc. v. Chapa, No. 17 C 1218, Slip Op. (N.D. Ill. Jun. 22, 2017) (Der-Yeghiayan, J.).

Judge Der-Yeghiayan granted defendants’ motion to dismiss for lack of personal jurisdiction, but denied defendants’ motion for sanctions in this declaratory judgment copyright case.

The only link plaintiff Kroto established between defendants and Illinois was the sending of cease and desist letters regarding Kroto’s copyrighted works to defendants. Those letters and communications alone were insufficient to create personal jurisdiction.

Finally, while a more detailed Rule 11 investigation may have uncovered defendants’ lack of contacts with Illinois, there was insufficient evidence to warrant the severe penalty of sanctions.