heard in case we rule against you and you don't have jurisdiction your honor i've had preliminary discussions with two potential local counsel for such an action and certainly it would be the intention to take further steps  holmes the reason i asked whether there was some sort of bar to bringing suit in d n a here is would you agree that what you're asking us to do to find personal jurisdiction in illinois under these circumstances could have far reaching consequences clearly police do nat confine their investigations to the borders within their states and even if there was some police work here that resulted in your client spending a day in jail there is you know the city of holbert has said look there there is jurisdiction in indiana but wouldn't you agree that such an opinion providing jurisdiction in illinois for sergeant gonzales's police work could have far reaching consequences here and by the way we don't look we don't really look to the plaintiff right we look to the we look to the defendant's conduct so to look at what the police officer did in the in in the in the particular state this case in illinois to determine whether personal jurisdiction exists is your honor just hersh what i would say to that is that and it's speculation that they may have even searched another state such as indiana and we can see why this is it was a publicly known fact established before the district court that as of early march two thousand nine hundred dollars are of course rogers the homicide suspect and the father is because the person of interest in self was an eighteen year old so if you are an investigator and starting his own shoes and you want to know where his wires rogers lives is is very like it's more plausible more than plausible it's likely he's going to be living in the same jurisdiction of this parent which was known not just in the press release but also to many contemporaneous news articles which actually somebody just one of those articles if you even google or as rogers in march of two thousand nine hundred you would immediately become aware that he is no one resident so what we say your honor is when starting it was public knowledge and invest in ordinary investigator is chargeable with knowledge of the public information directly pertaining to his investments what does it have to do with his what does it have to do with what he did in the illinois putting aside if you are you're arguing shoddy police work here what is they have to do with his contacts with the state of illinois such to confer personal jurisdiction against him in the city in illinois so your honor we are it is the nuclei of all five sets of facts and not just the transmission weren't the play of israel i hear mr rogers himself is a homebody he doesn't own a driver's license he doesn't have a car he doesn't travel to these other jurisdictions if they were going to find him ever it was going to be in illinois and i would just also clear honor to the taylor decision from the th circuit which we cited in our opening brief and also the district court cases and meenie which was that wisconsin district court case little minute remeron i understand your enemy events concerning a hypothetical case but in this case and these facts it all happened in illinois it didn't happen in one of those other jurisdictions but i can understand your concern your honor  officer has sought an arrest warrant that is later enforced by law enforcement and the orange for that reason we're asking the court to affirm this morning i just i did want to take a  the plaintiff or do you mean the son of the murder defendant well i guess this for the purposes i guess it the distinction is it doesn't really name in the knowledge that they were from the same state maybe he wasn't the correct suspect but he at least for short time was a suspect in the case  from the perspective of the officer and the officers can't tax with the aura where the suspect he happens to be investigating is from or has their ideation from it is is random unfortunate it's not it's not directed i think this is a reason why this type of cases specifically unique from  you know the more common business or commercial type of cases that you see these jurisdictional issues razor where you can see the defendant targeting the for jurisdiction for its its commerce here the case led my client's case use investigating lead my clients eleanor he did not drag the case there another case would be pushed vs they had no where the plaintiff was arrested in pennsylvania and in virginia warren the plaintiff sued the virginia officers in pennsylvania and that case personal jurisdiction so if in your hypothetical judge a private person makes a phone call to  correct ok and is there any difference between that and the swatting example other than whether it was deliberately malicious or just mistaken the difference is is submitting false application for a warrant in the indiana and in indiana crime to in indiana just the fact that the target of the warrant happens to be in ell residence is not significantly case related from the perspective of the defendant so i think to make that big there swatting an l z more appropriate you would have to have  my client in indiana submitting his request for an arrest warrant to a judge over in illinois and specifically targeting illinois in that way  swearing vesa gating crimes in their states don't choose whether suspects are real briefly and i would like to discuss what i what i think the noun form officer had an established relationship or the former officials closely coordinated with their communities with every henchman of across state lines those would be sufficient case related contacts between the defendant or in this case there is no establish relationship between my clients and the c p d and there is no acknowledge an important concession very early in his presentation just just given which was that the defense didn't know that they were seeking a person or suspect in a one way i mean only resident so every aspect of what they were doing as previously resided in the defendant law enforcement officers jurisdiction so it wasn't clear that the law enforcement officers even knew or had reason to know that the plaintiffs in that case left the jurisdiction here at every given moment the defense in this case knew that my client was in illinois and therefore there