Seven Oaks Millwork Inc. d/b/a Royal Corinthian v. Royal Foam US, LLC, No. 19 C 6234, Slip Op. (N.D. Ill. Dec. 13, 2019) (Kocoras, J.).
Judge Kocoras granted defendants’ Fed. R. Civ. P. 12(b)(2) motion to dismiss for lack of personal jurisdiction and denied as moot defendants’ Fed. R. Civ. P. 12(b)(6) motion to dismiss for failure to state a claim in this copyright dispute over a copyrighted product catalog.
Plaintiff Royal Corinthian’s operation of an interactive website with sales capabilities did not alone create personal jurisdiction in Illinois. Furthermore, defendants’ use of targeted advertising was not sufficient to create specific jurisdiction because it was done after Royal Corinthian filed suit, not before. Finally, a single sale into Illinois did not create specific jurisdiction. And even limited jurisdictional discovery to identify additional sales was not warranted because Royal Corinthian had not met its burden to show a colorable claim of jurisdiction before discovery should be allowed. Finally, Royal Corinthian’s alleged injury did not arise from defendants’ alleged contacts with Illinois.
Having held that the Court lacked jurisdiction, there was no reason to consider whether Royal Corinthian had sufficiently stated its claims.