Tai Matlin v. Spin Master Corp.
921 F.3d 701
| 7th Cir. | 2019Background
- Plaintiffs Tai Matlin and James Waring (Illinois residents) co‑founded Gray Matter, developed products (Snap-2-It mat, Aggressor hang glider), and signed a 1999 Withdrawal Agreement assigning IP to Gray Matter while reserving royalties.
- Gray Matter later assigned/sold asset rights (allegedly without plaintiffs’ consent) to Swimways; plaintiffs pursued arbitration and in 2014 lost a claim that Gray Matter assigned the Withdrawal Agreement to Swimways.
- Swimways (Virginia) never paid royalties; Spin Master (Canadian) acquired Swimways and the disputed IP in 2016. Plaintiffs sued Swimways, Spin Master Corp., and Spin Master Ltd. in N.D. Ill. (2017) for breach, fraud, and unjust enrichment.
- Defendants moved to dismiss for lack of personal jurisdiction and improper venue, submitting declarations showing no purposeful activities targeting Illinois; plaintiffs produced a purchase receipt showing one online sale into Illinois after suit was filed.
- The district court found no general or specific jurisdiction under Illinois law and federal due process, concluding the defendants’ contacts with Illinois were insufficient; plaintiffs appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Illinois courts have specific personal jurisdiction over defendants | Single online sale shipped to Illinois (purchase receipt) plus website accessibility establishes sufficient contacts | Defendants did not target Illinois, lack employees/agents/registration in Illinois; single post‑suit sale insufficient | No specific jurisdiction; dismissal affirmed |
| Whether plaintiffs may rely on a post‑filing, plaintiff‑initiated purchase to create jurisdiction | Yes — attorney’s purchase shows product entered Illinois and links to royalty dispute | No — contacts must exist at filing and be defendant‑directed; plaintiffs cannot manufacture jurisdiction | Rejected plaintiffs’ tactic; post‑filing contact inadequate |
| Whether website accessibility alone supports jurisdiction | Interactive website sales show targeting Illinois (citing Hemi Group) | Website accessibility without targeting is insufficient | Website accessibility alone insufficient absent purposeful targeting |
| Whether venue dismissal should be addressed given jurisdiction ruling | Plaintiffs argued improper venue as alternative basis | Defendants moved to dismiss for venue as well | Court did not reach venue because jurisdiction lacking |
Key Cases Cited
- Int'l Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts standard for due process jurisdiction)
- Walden v. Fiore, 571 U.S. 277 (forum contacts must be defendant’s own connections; focus on relation among defendant, forum, litigation)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and relatedness test for specific jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (limits of specific jurisdiction; relatedness requirement)
- J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (single or stream‑of‑commerce sales insufficient for jurisdiction without targeting)
- Hemi Group LLC v. City of Chicago, 622 F.3d 754 (7th Cir.) (systematic, repeated online sales into forum supported jurisdiction in regulated‑sales context)
- be2 LLC v. Ivanov, 642 F.3d 555 (7th Cir.) (web presence alone does not establish targeting; require forum‑directed conduct)
- Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir.) (focus on relations among defendant, forum, litigation for internet contacts)
- Tamburo v. Dworkin, 601 F.3d 693 (7th Cir.) (standards of review and plaintiff’s burden when defendant submits opposing evidence)
- Purdue Research Found. v. Sanofi-Synthelabo, S.A., 338 F.3d 773 (7th Cir.) (prima facie showing requirement when ruling on jurisdiction without evidentiary hearing)