Sarah FackrellMar 10
"[T]he district court clearly erred in finding that the defendants sold products to Illinois customers. Nor was that error harmless. Without those sales, the court’s basis for personal jurisdiction is merely that the defendants operated a website accessible in the United States."

RE: https://bsky.app/profile/did:plc:hvwhptk4oerwsuzau66ikwfy/post/3mgpghyo65s25
Show threadSarah FackrellMar 10
This is a nonprecedential, per curiam decision. But it's still notable because it appears to be rejecting the theory of "jurisdiction by shopping cart."
Show threadSarah FackrellMar 10
The panel writes: "The evidence upon which the district court relied shows only that it was possible to order the defendants’ products and have them shipped to Illinois, not that such sales took place."
Show threadSarah Fackrell
Comparing the arguments here, the decision, as well as the Second Circuit American Girl case could be the start of a nice #LawStudentNote.
Mar 10 at 1:48pmWeb