Johnson a/k/a Sylvester Thompson v. Barrier p/k/a Eric B., No. 15 C 3928, Slip Op. (N.D. Ill. Jan. 4, 2017) (St. Eve, J.).

Judge St. Eve granted defendant UMG Recordings’ Fed. R. Civ. P. 12(b)(2) motion to dismiss for lack of personal jurisdiction over plaintiff’s third amended complaint. Of particular note, the court held as follows:

  • Even if plaintiff had sufficiently pled “express aiming” it would only be a part of a broader minimum contracts analysis.
  • Plaintiff only made broad accusations that UMG authorized third party distribution throughout the US, including Illinois. That was not sufficient.
  • Plaintiff’s limited allegations of UMG’s litigation-specific content did not constitute the rare case where Keeton-style national jurisdiction was appropriate.

Without evidence beyond UMG’s 1% of sales in the U.S. or more evidence of UMG’s deliberateness, the Court lacked jurisdiction.