POET Research, Inc. v. Hydrite Chemical Company, No. 24-cv-01285 (N.D. Ill. Sept. 22, 2025) (Wood, J.).

Judge Wood granted defendant Hydrite’s motion to dismiss for lack of personal jurisdiction in this patent infringement case involving methods for remediating toxins in biorefinery processes. The Court held that POET failed to establish minimum contacts with Illinois sufficient to support specific jurisdiction or to show that the Northern District was the proper venue.

POET alleged that Hydrite infringed four patents covering mycotoxin remediation methods by selling products like Hydri-Maize CB-400. While Hydrite acknowledged conducting plant trials in Hennepin, Illinois, these occurred before the first patent was issued. The Court emphasized that pre-issuance conduct “cannot constitute infringing acts” under Federal Circuit precedent.

For direct infringement of method patents, the Court explained that all steps must be performed by a single entity. POET could not show Hydrite performed the patented processes in Illinois. Hydrite’s attendance at Illinois trade shows was insufficient because “mere demonstration or display of an accused product, even in an obviously commercial atmosphere is not an act of infringement.”

Regarding induced infringement, the Court found that Hydrite’s website offering to ship products anywhere in the United States was insufficient without evidence of actual sales to Illinois customers or affirmative acts encouraging infringement by Illinois residents.

The Court denied POET’s request for jurisdictional discovery, finding the request too speculative given Hydrite’s unrebutted declarations that it had not made, used, offered for sale, or sold the accused products in Illinois. Rather than dismissing, the Court transferred the case to the Eastern District of Wisconsin, where there appeared to be proper jurisdiction.