Pinnacle Advertising and Marketing Group, Inc. v. Pinnacle Advertising and Marketing Group, LLC, 1:18-cv-02430

Plaintiff Pinnacle Advertising & Marketing Group, Inc. is an Illinois corporation owning federally registered "PINNACLE" word and stylized trademarks for advertising/marketing services.
Defendant Pinnacle Advertising & Marketing Group, LLC is an LLC formed and headquartered in Florida; Plaintiff alleges Defendant uses a nearly identical name in competition, infringing the mark.
Plaintiff sued under the Lanham Act and Illinois consumer/deceptive-practices statutes; Defendant moved to dismiss for lack of personal jurisdiction (Rule 12(b)(2)) or, alternatively, improper venue (Rule 12(b)(3)).
Plaintiff conducted jurisdictional discovery and pointed to two asserted Illinois contacts: (1) Defendant attended a 2016 Dealer Ad Association conference in Chicago; and (2) Defendant purchased radio ad space in Illinois for a Florida client; Plaintiff also cites invoices misdirected between parties as evidence of confusion.
The court evaluated whether those contacts established specific personal jurisdiction under due-process minimum-contacts principles and whether Plaintiff’s alleged injury arose from forum-related activities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court has specific personal jurisdiction	Defendant purposefully directed activities to Illinois by attending a Chicago trade conference and purchasing Illinois radio ads (causing confusion)	Defendant is Florida-based; attendance at a single out-of-state trade show and making ad purchases for a Florida client do not establish purposeful availment	No specific personal jurisdiction; motion to dismiss granted
Whether forum contacts caused the alleged injury	Misdirected invoices and marketplace confusion show injury arising from Illinois contacts	Invoices/misaddressed billing do not tie Plaintiff’s injury to Defendant’s forum-related conduct; purchases were at client's direction	Plaintiff failed to show the injury arose from forum contacts
Whether attendance at single trade show suffices	Trade-show presence shows targeting of Illinois market and potential confusion	Single attendance at an event that rotates locations is fortuitous and insufficient to target Illinois	Attendance alone insufficient to establish minimum contacts
Whether purchasing ad space for a client in Illinois creates jurisdiction	Purchases demonstrate deliberate targeting of Illinois	Purchases were made for a Florida client; mere purchases or payments into forum do not establish contacts by defendant	Purchases were attenuated and insufficient for jurisdiction

Int'l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (establishes minimum-contacts due-process test for personal jurisdiction)
Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (jurisdiction requires defendant's own forum affiliation; plaintiff's location alone insufficient)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and foreseeability of being haled into forum)
Calder v. Jones, 465 U.S. 783 (U.S. 1984) (express aiming/intentional targeting standard for jurisdiction)
Tamburo v. Dworkin, 601 F.3d 693 (7th Cir. 2010) (prima facie standard for personal-jurisdiction facts at motion-to-dismiss stage)
N. Grain Mktg., LLC v. Greving, 743 F.3d 487 (7th Cir. 2014) (contacts must show real relationship to the forum and transaction at issue)
Federated Rural Elec. Ins. Corp. v. Inland Power & Light Co., 18 F.3d 389 (7th Cir. 1994) (purchases or mailing payments into forum do not alone create jurisdiction)
Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir. 2014) (forum sales insufficient where plaintiff cannot show nexus between those sales and the alleged injury)