Mobile Anesthesiologists Chicago, LLC v. Anesthesia Associates of Houston Metroplex, P.D.

Dist. Ct. did not err in dismissing for lack of personal jurisdiction, plaintiff's action alleging violation of federal anti-cybersquatting statute when defendant registered domain name that was confusingly similar to plaintiff's registered trademark. Defendant did not purposefully direct its activities at Illinois so as to subject it to specific personal jurisdiction of Illinois courts where defendant had no physical presence in Illinois and marketed its services only to Houston, Texas area physicians. Fact that defendant's website was accessible in Illinois and/or that plaintiff sent defendant cease-and-desist letter were insufficient by themselves to establish specific personal jurisdiction.