Mid-America Taping & Reeling, Inc. v. SMT Corporation, 1:16-cv-10703

Background

Mid-America Taping & Reeling, an Illinois company, sued SMT Corporation (Connecticut), SMT owners Kirsten and Thomas Sharpe, and former employee Robert Lingl for trade secret misappropriation, breach of NDA/fiduciary duties, and tortious interference.
Lingl previously worked for SMT, later returned to Mid-America; Mid-America alleges Lingl took SMT customer lists and hardware to SMT and/or used SMT materials to solicit SMT customers for Mid‑America. SMT contends Lingl colluded with Mid‑America to divert SMT business and shipped SMT property without authorization; SMT later discovered missing records, terminated an SMT employee, and criminal charges were brought against Lingl and another.
SMT sent a demand letter and the parties reached an agreement in principle in November 2016, but Mid‑America then filed this suit in Illinois on November 17, 2016 (shortly before SMT threatened to sue).
SMT and the Sharpes moved to dismiss (or transfer) for lack of personal jurisdiction. SMT is based and operates solely in Connecticut, does minimal business with Illinois, is not registered in Illinois, and the Sharpes do not personally conduct business or own property in Illinois.
The district court considered affidavits and other evidence and resolved factual disputes in Mid‑America’s favor for jurisdictional analysis.
The court concluded Mid‑America failed to establish either general or specific personal jurisdiction over SMT or the Sharpes and dismissed them without prejudice for lack of personal jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court has general jurisdiction over SMT/Sharpes	SMT’s purchases from and sales to Illinois (and alleged solicitations) establish continuous and systematic contacts	SMT’s contacts with Illinois are minimal, episodic, and insufficient to be “at home” in Illinois	No general jurisdiction: contacts too insubstantial to render SMT/owners "at home"
Whether court has specific jurisdiction over SMT/Sharpes	SMT purposefully directed activities at Illinois; injuries occurred in Illinois	SMT did not purposefully direct litigation‑related conduct to Illinois; alleged misconduct (Lingl’s acts) was unknown to SMT	No specific jurisdiction: plaintiff failed to show purposeful availment or a forum‑related nexus
Whether corporate contacts impute jurisdiction to individual owners	Mid‑America implies owners’ management/control supports jurisdiction over them	Sharpes observe corporate formalities; no basis to pierce veil or impute SMT’s contacts	No jurisdiction over Sharpes individually; ownership alone insufficient to establish contacts

Key Cases Cited

Int'l Shoe Co. v. Washington, 326 U.S. 310 (establishes "minimum contacts" due process standard)
World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (defendant must reasonably anticipate being haled into forum)
Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (general jurisdiction requires being "at home" in forum)
Tamburo v. Dworkin, 601 F.3d 693 (plaintiff bears burden; court may consider affidavits; prima facie standard pre‑hearing)
Purdue Research Found. v. Sanofi‑Synthelabo, S.A., 338 F.3d 773 (once defendant rebuts, plaintiff must produce affirmative evidence of jurisdiction)
Mobile Anesthesiologists Chicago, LLC v. Anesthesia Assocs. of Houston Metroplex, P.A., 623 F.3d 440 (specific jurisdiction requires purposeful direction and nexus to claim)
Felland v. Clifton, 682 F.3d 665 (tort claims require conduct expressly aimed at forum with knowledge of effects)
Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (contacts between plaintiff/third parties and forum cannot substitute for defendant's own forum‑related conduct)
Kipp v. Ski Enter. Corp. of Wis., Inc., 783 F.3d 695 (threshold for general jurisdiction is high)
Central States, Se. & Sw. Areas Pension Fund v. Phencorp Reinsurance Co., 440 F.3d 870 (pleading inferences in plaintiff's favor on jurisdictional facts)
Cent. States, Se. & Sw. Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934 (ownership/affiliation does not alone justify jurisdiction over individuals)