Ariel Investments, LLC v. Ariel Capital Advisors LLC

Dist. Ct. lacked personal jurisdiction over defendant in trademark infringement claim under Lanham Act, where defendant had no client in Illinois, did not have any property or staff in Illinois, did not advertise in Illinois and never had employee or agent visit Illinois until it defended instant lawsuit. Lanham Act does not authorize nationwide service of process, and thus plaintiff had to secure personal services under Illinois state law. Moreover, fact that defendant may have known that its choice of name would injure plaintiff, which was located in Illinois, was insufficient to establish personal jurisdiction over defendant, since mere knowledge of potential harm to plaintiff in particular state is not same as acting in said state.