## Facts

- Cook Associates, an executive placement firm, operated offices in Chicago and Massachusetts.
- A Lexington executive contacted Cook’s Massachusetts office seeking candidates for a sales management position.
- Cook sent candidate résumés and a fee schedule stating Lexington would owe a fee if it hired a submitted candidate.
- Candidate Gregg Hoegemeir interviewed in Chicago with Lexington and was offered a field sales manager job, which he declined.
- After Cook’s Massachusetts agent left and opened a new agency, Lexington contacted her and later hired Hoegemeir for a national sales manager position with materially different terms.
- Cook demanded a placement fee as the original referring agency; Lexington refused.
- Lexington was not licensed to do business in Illinois; its Illinois contacts included the Chicago interview and limited activities such as annual trade-show attendance.

## Issues

1. Whether Illinois’ long-arm statute allowed specific jurisdiction based on an Illinois contact when the fee claim did not arise from that contact.
2. Whether Lexington’s Illinois activities were sufficiently continuous and systematic to constitute “doing business” and support general jurisdiction.
3. Whether asserting jurisdiction would satisfy due process minimum-contacts requirements.

## Decision

- The Illinois Supreme Court affirmed the appellate court, holding Illinois courts lacked personal jurisdiction over Lexington.
- The long-arm statute did not apply because Cook’s fee claim did not arise from the Illinois interview and declined job offer.
- Lexington was not subject to general jurisdiction because its Illinois activities were sporadic and limited, not “doing business” in Illinois.
- The trial court’s judgment for Cook could not stand because service should have been quashed for lack of jurisdiction.

## Legal Principles

- Under the Illinois long-arm statute, specific jurisdiction based on transacting business in Illinois exists only for causes of action arising from that Illinois transaction.
- A contact in Illinois that does not result in the contract or obligation sued upon does not satisfy the statute’s “arising from” requirement.
- General jurisdiction over a foreign corporation requires continuous and systematic in-state activity; occasional trade-show participation and intermittent visits are insufficient.
- Statutory limits on jurisdiction may be more restrictive than constitutional due process; failure to meet the statute ends the jurisdictional inquiry.

## Conclusion

Illinois could not exercise personal jurisdiction over Lexington because the placement-fee dispute arose from a later, materially different hiring arrangement that did not stem from the earlier Illinois interview, and Lexington’s limited Illinois activities did not amount to “doing business” supporting general jurisdiction.


Cook Assocs., Inc. v. Lexington United Corp., 87 Ill. 2d 190, 429 N.E.2d 847 (Ill. 1981)