In this case, plaintiffs allege that defendants telephoned plaintiffs at their residence in Illinois and initiated negotiations for the sale of pick-of-the-litter “breeding quality” puppies. After plaintiffs [visited Oklahoma, purchased Mohanna and another puppy, and] returned to Illinois, defendants forwarded AKC registration papers through the United States postal service to plaintiffs’ Illinois residence.
[The mailed papers] documented Mohanna’s lineage and [stated] that she was sold “for breeding purposes.” If the only contacts defendants had with Illinois consisted of a single telephone call and one mailing in connection with their sale of the two pups to plaintiffs, we might agree with the trial court that plaintiffs failed to establish sufficient minimum contacts to satisfy due process. But, plaintiffs insist, there was more. Plaintiffs allege, and defendants agree, that defendants maintain an interactive commercial website advertising their pups and encouraging visitors to communicate with them about potential purchases of puppies via a direct link to defendants’ e-mail address.
Moreover, plaintiffs allege, defendants’ publication of untrue statements about Mohanna’s lineage in Tibetan mastiff chat rooms constitutes activity in Illinois. According to plaintiffs, defendants’ statements targeted Mohanna and her littermates and falsely indicated that no genetically sound puppies would result from breeding Mohanna. The type of Internet activity that is suffi cient to establish personal jurisdiction remains an emerging area of jurisprudence.