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Canadian Thermal Windows, Inc. v. Magic Window Co.

Citations: 529 F. Supp. 2d 881; 2007 U.S. Dist. LEXIS 66400; 2007 WL 2481295Docket: 07 C 1784

Court: District Court, N.D. Illinois; August 27, 2007; Federal District Court

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Plaintiffs Canadian Thermal Windows, Inc. and 420820 Ontario Limited Corporation filed a lawsuit against Defendant Magic Window Company in the United States District Court for the Northern District of Illinois. The court addressed the issue of personal jurisdiction, noting that while plaintiffs chose a forum that was inconvenient for them, it was convenient for their legal counsel based in Chicago. 

Defendant opposed the venue, leading plaintiffs to request a transfer to the Eastern District of Michigan. Unlike typical cases where defendants might prefer a transfer without seeking additional relief, the defendant sought recovery for over $50,000 in fees and costs, alleging misuse of the judicial system. The court agreed with the defendant's position, referencing the precedent set in Methode Electronics, Inc. v. Adam Technologies, Inc.

The court emphasized that the plaintiffs were well aware of the defendant's business operations localized in Michigan, having a longstanding relationship for nearly a decade. Discovery indicated that plaintiffs lacked grounds for personal jurisdiction in Illinois, as the defendant's limited business activities in the state—primarily purchasing unrelated supplies—did not constitute sufficient business operations to establish jurisdiction. 

The court concluded that the plaintiffs had no legitimate basis for the lawsuit in Illinois, as none of the alleged infringements occurred there; instead, they were tied to actions in Michigan. Consequently, even if jurisdiction had been established, the case would have ultimately been transferred to Michigan, confirming that the defendant incurred unnecessary expenses due to the plaintiffs’ actions. The parties were directed to follow LR 54.3 for determining reasonable fees and costs.