In our opinion, the totality of defendants’ activities in Illinois, including (1) the contract negotiations and follow-up AKC registration of Mohanna, (2) maintenance of a commercial interactive website, and (3) use of Tibetan mastiff chat rooms to reach potential customers of Tibetan mastiff breeders, including plaintiffs, were of suffi cient quantity and quality to constitute minimum contacts in Illinois under federal due process analysis.


Next, we must consider whether plaintiffs’ cause of action arose out of defendants’ contacts with Illinois. This question is easily resolved in plaintiffs’ favor. Plaintiffs’ primary complaint is of tortious interference with prospective business advantage. According to the complaint, defendants’ initial contact was by telephone, offering to sell “pick-of-the-litter” female pups to plaintiffs. They followed up on the agreement with a contact by mail, forwarding AKC registration papers to plaintiffs’ home showing that Mohanna was “for breeding.”


They subsequently published allegedly false information about Mohanna’s lineage in Internet chat rooms targeting Tibetan mastiff owners and breeders, again reaching into Illinois and adversely affecting plaintiffs’ Illinois dog-breeding operation. Accordingly, it is clear that defendants’ contacts with Illinois gave rise to plaintiffs’ cause of action. Next, we consider whether it is reasonable to require defendants to litigate in Illinois. If the plaintiff has established that the defendant purposely directed his activities at the forum state, it is the defendant’s burden to show that litigating the dispute in that state would be unreasonable.