be2 LLC v. Ivanov

Dist. Ct. erred in denying defendant's post-judgment motion seeking to vacate default judgment in Lanham Act action on grounds that Dist. Ct. lacked personal jurisdiction over defendant due to lack of contacts with State of Illinois. Case concerned defendant's Internet activity with respect to its matchmaking website that plaintiff claimed was confusingly similar to plaintiff's website, and record showed that defendant, which had no physical tie to Illinois, did not deliberately target or exploit Illinois market where defendant's Internet activity produced only 20 Illinois customers who used defendant's free services. Moreover, mere operation of interactive website by itself was insufficient to establish personal jurisdiction.