disagree with his analysis even to that standard but ultimately we believe apply in general jurisdictional analysis as opposed to a specific jurisdictional analysis within a long term statute when you look at this case first thing it would seem pop out to me is why are you asking for four defendants in jurisdiction over four defendants when you had a contractual relationship with one entity you know i think what that goes into is kind collector car people where you have a car drive then and it lifts it up and you can in other car come in under need it and you can maximize storage space is very familiar with the industry was very familiar with the players in this industry  subscribe to the image motor news which is a very well respected national magazine that caters to the collective car market we saw this ad in this magazine for in the with a company like many consumers you might know a business name you don't necessarily know who you're dealing with he didn't know this company so they call said hey i'm interested in your lives they say go to the website the dirty look at the website and saw that they were very similar to packer buddies lives and he asked he said these look very much like becker but they told him we're a bunch of disgruntled former employees of backyard buddy we started our company it's a similar product very good product duped backyard buddy was the puppet master in the background pulling the springs jason wood and larry gross are the admitted owners of auto butler l g r t in the v a although butler lives and they were the ones who wrote he never gets this product this this goes on for several months phone calls are made back and forth whereas my product eventually they send a letter to him say yes pursuant to our conversation they're going to ship this week they don't if you don't this they do that the company was had no problem with it the people weren't involved and that's when they cut their own check shut everything down etc there was a criminal investigation in ohio about this aspect accounting for all of about what was really going through back there but that the design was in fact taken from backyard buddy and there's e mails back and forth from back everybody on those issues indicating how the design changes will be made from backyard buddy to all of their lives various other instances of things like that so what he sensibly really found was that although he thought he was dealing with backyard body behind the scenes he was really dealing or he thought he was now there's various things obviously the first and foremost issue is who's responsible for what and that's why we have brought all the parties in in an effort to have the litigation of the only consumer fraud away with a false representations of who we was we business with what was going on where these shipments coming back and forth from and who's taken the money and who's not because in reality we really whenever a party does business with somebody you don't really know unless you go into the shop physically and purchase something who really is that someone they could tell you who would do this which you don't know and we've amassed all of this information now to give us that but the real issue really comes down to jurisdiction who do we have jurisdiction over who we not paid jurisdictional the pellet or the trial just said you don't have jurisdiction over a buck we don't believe that's accurate we believe we have jurisdictional we're all fo l for various reasons the biggest issue though is the long arm statute which the judge for the trial judge didn't even consider and we told him be careful judge the arguments are coming here under general jurisdiction this is a specific jurisdiction case and when he announced his ruling he was very scant when he said there is no evidence that any of these defendants do business with the type of degree of permanency that would be required for jurisdiction but the long arm statute connected to the state now that it has to come within the context of fourteenth amendment constitutional due process for enough minimum contex that due process is not offended our primary argument in this case is this contract in this case arises out of the transaction of business within this stick that transaction was richard else's contract with although baller to purchase eleven lives to be delivered to the state of illinois in rock family town he paid his money the list never came back to rock and one count he substantial nexus is the defendant's agreement to produce the documents or to produce the list shipped them to rock town they were never shipped he never got his money back so our argument is that clearly over arises out of the context of this that is then there is sufficient minimum context for the state of illinois primarily as i said the ultimate performance of the contract was the delivery in illinois of eleven automobile lips in addition to the act we look at what other issues transacted between the  the defendants purposefully sending a national magazine out advertising they have an internet site which you know of itself i don't think is ever sufficient for jurisdictional purposes we have my client calling  e mails that are within the record all deal with the transactions between the gang manufacturing and his communications with backyard but because all the only thing that really happened with all the butler lists is they had a little storefront they had a computer a desk and phone and a sales rep everything else was done through back yard buddy and we believe the record is very clear on that in the stair machine that that's how they did business  jurisdiction would be appropriate in this case in that case there is a plaintiff in a defender that had a contract and the contract was with plaintiff's texas subsidiary for delivery in louisiana invoice was sent the only parent corporation checks came from the only parent corporation so when this there was a breach suddenly discussions occurred through the only parent corporations negotiator in chicago and the lawsuit was brought in illinois the court found sufficient negotiations that it would not offend due process well in my case we clearly have delivery in illinois to case was delivery in louisiana the party is in illinois mr l us the payment for the credit card from illinois so all those factors are stronger than what we have in the compass case so we believe that when you look at the specific jurisdictional issue clearly that specific jurisdiction exists on the basis of the long arm statute that's not the end of it though never get into the reasonableness to litigate in illinois under the due process clause truffle did not address that issue of but we believe that that's a that's an easy win for the plaintiff opponent in this case because under the reasonable most standard it is the defendant's burden to show it's unreasonable not only is it their burden to show that it's unreasonable the cases of describe it as a compelling burd a compelling burden to show that there is something that is fundamentally unfair about having the case in illinois and the commerce trust case not only says that that burden is rarely met but when you have a consumer fraud case you have the fundamental state policy of consumer protection the middle militates towards our case and that's what we do here we have a case involving the consumer fraud act that's what we're seeking to do and that's why we believe that there's a fundamental fairness issue for us to be able to have that case here in illinois now getting back to this issue a why did you bring these other parties in and how do you have jurisdiction over  we believe it's all tied in together and the cases that we've signed before that talked about the issue not in terms of how the court the trial court looked at it think i'm not going to pierce the corporate veil today counsel that's not what we're here about those arguments are piercing the corporate veil slowly for purposes of jurisdiction to show that the relationships are there the control is there so that what we're actually showing is my client has in fact contracted with them it's not a  not ruling on the corporate veil as a matter of the substantive issues we're only saying is there enough evidence to enable the companies owner to drop in the personal journey to the personal jurisdiction of the district court and that's exactly what we're doing here owners of l t r t now these two men from ohio are employees of becker body but they've also stated in an affidavit form that they are not in any way ownership have a new ownership ohio which there's a contingent litigation in ohio where the defendants here of sued the police department for making these recordings not disclosing that there was recordings we're not sure if it was legal under ohio law to actually make these recordings on the would be severe as opposed to the only party known that's going to be called from the point of is the plaintiff himself  further another factor to go to the reasonableness argument of litigating in illinois is whether the point you can obtain effective relief in illinois and the plaintiff in his brief is argue that the states are limitations mr gross and mr wood were submitted to the court but not served on me until after the hearing three days after the hearing so we would not have an opportunity to respond to those but i don't think it matters really i filed a motion to iraq there is a comment with regard to be evidentiary hearing that the documents that i serve the non injury here in my ability to get that that was denied i made an offer of proof and now the criticism is well you don't have an off indication of the documents you put in your offer of proving what you said the court will give testimony well but that's what the purpose of the offer of proof is is to say to the core you didn't allow me to introduce this evidence here it is this is what i would  in reviewing documents my client as i believe there's a negative in there saying he did not get refund the police before the defendants indicated that they believed all credit cards were refund the problem with my clients is it was the large it was a large amount three thousand dollars as a deposit most of them put down three thousand dollars on deposit but more importantly his was helped along there was a timeframe for getting a refund on the credit cards through your own credit card system my clients was held to long because this was one of the initial orders but because of the so we got pushed back to the end by the time all that came about it was too so he did not get that the one issue that really didn't get a whole lot of play is the general jurisdiction issue as i indicated before we believe we have specific your section but in general jurisdiction the issue is whether they do business with sufficient continuity in the state of illinois to open them up thank you real briefly backyard buddy there's evidence in the file that every single year that my client was around through the year that this happened to him they attended the bloomington gold auto show which was the biggest auto show in the midwest they were a vendor they had signed vendor contracts that is in the file they regularly do business in the state of illinois l g r t it was as an internet provider or as an internet business all of their credit cards went through a bloomington illinois bank we put that into evidence every credit card sale had to go it was on the internet had to go through that blue meeting the only bank we have a copy of the contract we have copies of the and it was a continuous contract for twelve or eighteen months so every single month they were making payments to the state of illinois in bloomington to that bank so for them to argue that they don't do business on a regular basis in illinois for general jurisdiction purposes i find it hard to believe that's all i have on the 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