John Crane, Inc. v. Shein Law Center, Ltd.

Dist. Ct. did not err in dismissing for want of personal jurisdiction claim by Illinois plaintiff that defendants-citizens of Pennsylvania, California and Texas subjected plaintiff to conspiracy by filing fraudulent lawsuits in Pennsylvania, California and Texas regarding exposure of defendants' clients to asbestos allegedly manufactured by plaintiff. Parties conceded that Dist. Ct. lacked general personal jurisdiction over defendants, and Ct. of Appeals found that plaintiff did not establish specific personal jurisdiction over defendants, since defendants' directing pleadings, discovery and other litigation communications to plaintiff in Illinois, who faced said litigation in other states, was insufficient to create specific personal jurisdiction over defendants, where plaintiff was only link between defendants and instant Illinois forum. This especially true, Ct. found, since any unlawful conduct at issue in instant lawsuit was targeted at litigation conducted in other states.