in dismissing my client's complaint with prejudice based on a lack of personal jurisdiction you know i know they've read the briefs prior to this morning but  because we are discussing personal jurisdiction it's necessarily a fact intensive discussion i'd like to just give a nutshell version of the events that brought us to this place today which is one who literally question certainly yes our main focus is general personal jurisdiction tears continuous systematic contacts with the state of illinois so that there would be general jurisdiction here when all we hand were  telephone calls over two and a half months i made one trip here well the counter to mr war was a little more extensive than that so how do you get around the fact doctor  you know i i certainly have to say that he the entity of war in terms of applying for the medical marijuana concern with this situation was that it was dismissed with prejudice and we never got a chance to address that issue nor was it raised by counsel at the time so do accordingly our pleadings in the subsequent motion that we are going never  dressed any of this because the issue itself is just never on the table but counsel the standard for general jurisdiction is quite high you need to have continuous and systematic context this is general business context what you described just a few minutes ago and what we've read here doesn't seem to rise to that level why his response to that i would say that if you look at the in terms of  record culture to get the licensing things like that just because a business ultimately in or was not a decision maker who has been the c e o ultimately because the business as you know you've got down this route of either the money's not available or the wife says things too difficult or we just don't like illinois and decides not to move forward with that i don't think that it's their back that decision a defendant in this case i mean is there any way that you can concede that he could have been a defendant in this case float doesn't hold which the state did or made the statement but it him i think there's additional and probably stronger her arguments to be made about their liability maybe stemming from their employment contracts both or into big head written employment agreements with delt ny and i think that there's definitely an issue there as to whether there was one from a nation been i think you know probably the only way that we could have done better would be to are the evidence is that and allegations contained in those mere five pages three pages from us an affidavit two pages from that and mr easy is an affidavit indicates he is there on behalf of down to nine correct the reasons that the courts in those cases deny it said that there was no personal jurisdiction in acid it did to the part about email and telephone communication number one i david said earlier that even though the household correctly states the holdings of those cases i think there's a very different in the fact patterns of those cases aside from the only communications in those cases a fundamental issue to the her from the the rounds these companies are doing business they are buying art in selling art that is and to make the decisions that we need in those cases i think even as you describe the current state of business across state lines with e mails and phone calls u nder the law it was even risky however here they said we have a person that is being sued not a business not the c e o of the business but the a person