William Kipp v. Ski Enterprise Corporation, 2015 U.S. App. LEXIS 6146

Kipp, an Illinois resident, sued Ski Enterprise in the Northern District of Illinois for injuries from boarding a chairlift operated in Wisconsin.
District court dismissed for lack of personal jurisdiction; the case was in diversity jurisdiction, Ski Enterprise being Wisconsin-based.
Ski Enterprise operates Devil’s Head Resort in Wisconsin; its offices are in Wisconsin and it has limited Illinois reach via a trade show, email marketing, and a website.
Illinois customers constitute a substantial portion of Ski Enterprise’s clientele, but there is no Illinois office, employees, or business registration; lift-ticket sales cannot be completed on its website.
The court applied Illinois long-arm jurisdiction up to due process limits, reviewed de novo, and analyzed whether Ski Enterprise was “at home” in Illinois.
The court held Ski Enterprise is not at home in Illinois, so general jurisdiction does not exist and affirmed dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether general personal jurisdiction exists over Ski Enterprise in Illinois.	Kipp argues Illinois is a suitable forum due to substantial Illinois clientele.	Ski Enterprise argues it lacks sufficient contacts to be at home in Illinois.	No general jurisdiction; not at home in Illinois.

International Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court 1945) (establishes minimum contacts for personal jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (S. Ct. 2011) (general jurisdiction exists only where affiliations are essentially at home in the forum)
Daimler AG v. Bauman, 134 S. Ct. 746 (S. Ct. 2014) (limits on general jurisdiction; only min. contacts to be truly at home in the forum)
Hyatt Int'l Corp. v. Coco, 302 F.3d 707 (7th Cir. 2003) (applies state law for personal jurisdiction; per se rule when no evidentiary hearing)
Tamburo v. Dworkin, 601 F.3d 693 (7th Cir. 2010) (website alone not sufficient for general jurisdiction)