Philos Technologies, Inc. v. Philos & D, Inc.

In breach of contract action alleging that defendants-Korean citizens unlawfully retained equipment that plaintiff had sent to defendants, Dist. Ct. did not err in granting defendants’ motion to vacate issuance of default judgment and to dismiss instant action after finding that it lacked personal jurisdiction over defendants. Fact that defendants formed contract with Illinois plaintiff was insufficient, by itself, to establish personal jurisdiction over defendants, and trips to Illinois by one defendant were also insufficient to establish personal jurisdiction where said trips were either irrelevant to formation of contract or were not taken for purpose of negotiating instant contract with plaintiff. Ct. further observed that instant contract was strictly Korean business deal, where defendants did not solicit plaintiff to enter into any agreement, and where original agreements were executed in Korea.