09-2658 Mobile Anesthesiologists Chicago, LLC, v. Anesthesia Associates of Houston Metroplex, P.A.

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Civil Procedure
Personal jurisdiction

A doctor in Texas, licensed only in Texas, cannot be sued for cybersquatting in Illinois.

“A defendant’s deliberate and continuous exploitation of the market in a forum state, accomplished through its website as well as through other contacts with the state, can be sufficient to establish specific personal jurisdiction. See, e.g., uBID, Inc. v. The GoDaddy Group, Inc., No. 09-3927 (7th Cir. Sept. 29, 2010). Mobile/Houston’s relationship with Illinois stands in stark contrast to such cases. Dr. Chan is not licensed to practice medicine outside of Texas. His website does not contain much, but it does contain a Houston-area phone number, an e-mail address, and an invitation to doctors in the ‘greater Houston area’ to contract for his services. If a doctor in Chicago stumbled upon Dr. Chan’s website and called for an appointment, their conversation would be very short.”

Affirmed.

09-2658 Mobile Anesthesiologists Chicago, LLC, v. Anesthesia Associates of Houston Metroplex, P.A.

Appeal from the United States District Court for the Northern District of Illinois, Norgle, J., Hamilton, J.

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