Mepco Finance Corporation v. Warranty Administration Services, 1:11-cv-02919

Mepco Finance Corp funds warranty programs for consumers;
CDWS entered an Illinois-forum agreement with Mepco and sold 1,193 warranties in Illinois, generating over $1M in revenue;
Chapman (CDWS President) and Sletner (CDWS VP) are the sole officers and 100% CDWS shareholders;
Defendants failed to answer, leading to default and a judgment against them on Aug. 18, 2011;
Defendants moved under Rule 60(b)(4) to vacate the default and judgment arguing lack of personal jurisdiction;
Court held CDWS is subject to Illinois jurisdiction, and thus the individual defendants are subject to personal jurisdiction when fiduciary shield is lowered by their personal interests

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether personal jurisdiction exists over Chapman and Sletner	Individual acts imply personal interest; shield lowered	Jurisdiction should be limited to CDWS, not individuals	Personal jurisdiction over individuals established; 60(b)(4) denied
Whether the Rule 60(b)(4) void-judgment standard applies given jurisdiction	Judgment void due to lack of jurisdiction	Jurisdiction exists; no void judgment	Rule 60(b)(4) motion denied; judgment remains

Rice v. Nova Biomedical Corp., 38 F.3d 909 (7th Cir. 1994) (fiduciary-shield can be pierced when acts serve personal interests)
Rollins v. Ellwood, 565 N.E.2d 1302 (Ill. 1990) (fiduciary shield doctrine applicability)
Glass v. Kemper Corp., 930 F. Supp. 332 (N.D. Ill. 1996) (fiduciary shield doctrine discussion)
Femal v. Square D Co., 903 N.E.2d 32 (Ill. App. Ct. 2009) (personal-interest factors in shield analysis)
Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851 (7th Cir. 2011) (60(b)(4) standard vs. merits burden)