Personal Jurisdiction In a Lawsuit for Loss of Business

In Janmark v. Reidy, 132 F.3d 1200 (7th Cir. 1997), the plaintiff, a corporation based in Illinois, sued the defendant, a corporation based in California, for interference with prospective economic advantage. The plaintiff alleged that the defendant's threat to the plaintiffs customer, who was located in New Jersey, had caused the customer to cancel their order, which resulted in a loss of business to the plaintiff. The court of appeals held that personal jurisdiction over the defendant in Illinois was proper pursuant to section 2-209(a)(2) of Illinois' long-arm statute, because the alleged economic injury, which was the loss of business to the plaintiff, occurred where the plaintiff corporation was based. Specifically, the court held, "the state in which the victim of a tort suffers the injury may entertain a suit against the accused tortfeasor." Janmark, 132 F.3d at 1202.