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One Meeting and Partial Performance in State of Illinois Is Enough

Although an agreement was not reached, defendant and plaintiff had a single meeting in Illinois at which they negotiated various terms of a contract. In addition, the contract that was ultimately reached was to be partially performed in Illinois. These two facts are enough to provide personal jurisdiction over the defendant under the Illinois long arm statute, 735 ILCS 5/2-209 (West 2000). Thus, the Illinois Appellate Court reversed the trial courtâ„¢s dismissal for lack of jurisdiction in Viktron Limited Partnership v. Program Data Inc., No. 2-00-1445, 2001 WL 1450983 (Ill. App. 2nd Dist., Nov. 14, 2001).

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