In July 2009 the trial court granted Trambert’s motion to dismiss holding that, “the mere formation of an on-line contract in the defendant’s limited e-mail and telephonic correspondence with the Illinois plaintiff regarding that contract are by themselves insufficient to establish minimum contacts with Illinois, and the defendant did not purposely direct any eBay sales specifically toward Illinois residents or use Ebay to establish the regular business in Illinois.” In the instant appeal, the appellate court agreed that MacNeil could not establish general or specific jurisdiction over the Trambert.
The court held that MacNeil could not establish general
jurisdiction because Trambert’s advertisements for the vehicle on eBay alone
were insufficient to show that he had continuous and systematic contacts with
In Foley v. Yacht
Management Group, Inc., the defendant, a
Likewise, in this case, the court held that the eBay
transaction plus the other limited communications between parties was
insufficient to establish personal jurisdiction over the defendant in
involved a continuous and intimate business relationship in the forum, unlike the “one-time deal” transaction that occurred in the instant case.
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