activities to residence in illinois did the defendant derive economic benefit from that one key another key is what are the contacts in illinois and activities in illinois through which the defend was context of illinois and purposely directed activity that the rest of illinois another key is the case law which indicates that a defendant cannot afford jurisdiction fight delegating another company to conduct its activities in illinois for conduct its contacts in the illinois you know the key is instead of running to the defending champs under the due process clause that they may be called into court in illinois another key in this particular case is the fact that the defendant in mobilia area which is an occidental hotel entered into a contract with an illinois company apple vacations west concerning  illinois they specifically indicate in those cases that if the plaintiffs is enticed or makes their trip to the resort or to that defendant process as a result of the direction activities to residence in illinois in this case unlike i think almost all of the other cases cited we have an actual contract that actually says this defendant was purposely directing activit applications west and chicago was listed as a primary target of that partnership co op partnership agreement with up of occasions west entered into by the occidental hotel and i'm still having a hard time indicate otherwise that a defendant cannot afford jurisdiction in the form state by delegating infectivity in the form of state to another company in this case the occidental hotel which this agreement is to follow correct partnership with apple vacations west to target the cities in illinois and behalf of the occidental resorts which include immobility aria for that now so you say that because a company they paid that money was also paid for to set up training of agents by occidental did a lot of training of the upper west agents their contract always paid for them to set up different  was they are separate entities separately they're separate i agree but they are together they have signed this contract as a group for what that is the nature of reality you can take it stands there's no contract between immobility ari the sec there may be a conflict but we didn't need to pursue the contract because they have admitted in their affidavit that the occidental hotels are owned by the parent company and all the occidental our so it's clearly one of the hotels that has signed this agreement with apple it's clearly one of the hotels that they are hosting trade shows about one of the hotels where they have bonus programs about one of the hotels where occidental has agree these bookings and that web site if you believe that website it says in the website all just future relative to this contract or to any application shelby litigated in the forms of illinois or with a company that doesn't exist well if you if you look at the actual contract itself the subject matter of the contract is the advertising properties i think the most think there is not a single chicago tribune advertisement in the record there's not a reference in the record to any radio advertising and for this property owned by mobility over there is was hit on the fact that it was probably a thousand dollars total contribution and that he has fostered it as being purposely directed to the state of illinois however and up on the second page of that marketing proposal it specifically lists twenty seven markets that this proposal list is intended for twenty seven only one of which is in illinois so twenty option of some sort of advertising be made for this caribbean the hotel there is zero evidence to the record that in ever ties it was actually made ok why is that position you are taking inconsistent with the manson case to which your colleagues meet soon such a reference sure eight between all the parties of both of our briefs there are nine illinois case that were that have to do with someone from illinois traveling outside of them vacation or other writers and injuring themselves while outside only coming back here to file suit out of all nine of those cases only one only mat's found that personal jurisdiction was appropriate based on advertising all four of the precedents i cited from the first district here  fall despite the fact that there was advertising found that that was not sufficient and it usually was two separate basis first is that a personal injury cause of action distinct from are you simply transact business with a person asked why they at first blush may seem to be related or similar concepts but they're quite different so district in two subsequent cases that i cited the brushy a case and the dressing case which both or similar facts in the northern district in those two cases moved away from that massive case refused to apply the reasoning and despite the fact that there were advertisements in those two cases the northern district said there is no person or station really under this faction there so because as i mentioned mass it is only one out of all the other eight precedents that were cited that follow that train of thought and by the northern district itself moving away from m and i think that it's important too to note then in one of those particular subsequent cases the brushy case that case involved a mexican resort that ha action did not arise out of the alleged attacks in the state of illinois and again that in and then this particular case or even further because in the brush case it was stuck hotel well court applies a proposal and marketing plan against a mobile area it is still your solicitation which is not enough and further than that there still is zero evidence in the record that advertise national advertising program with apple not related to the state in question specifically and that is the basis of their decision rests on the swiss completely different situation here  residents of illinois and they have asked why mr and mrs polos signed up for the whole trip and went to an accidental hotel the immobility are so that i don't think that with all due respect i don't think that's relevant that there's others have people come from illinois to target those residents to come to their hotel and then hide behind the fact that it's a west that they hired to do this in illinois and say that's not enough