Here is the opinion — Native American Arts v Contract Specialites — Sunburst Cos.

An excerpt:

The problem, for purposes of jurisdiction, is that NAA only made conclusory allegations that Sunburst’s products arc purchased in Illinois. (Compl. P 4.) Although this may be sufficient if left unchallenged, Sunburst submitted an affidavit, stating that it has never purposefully directed advertising to Illinois and that none of its eight Illinois customers (with the exception of NAA) has ever purchased goods of the type at issue in this suit. (Guarino Aff. PP 13, 14.) NAA did not attempt to refute that evidence. Therefore, the Court does not view this as a genuine factual dispute that warrants an evidentiary hearing. Cf. Hyatt, 302 F.3d at 713 (stating that evidentiary hearing would be necessary to resolve disputed matcrial facts relevant to jurisdiction). Because NAA also alleges that Sunburst sells products in the “traditional Indian style” throughout the United States, the absence of sales in Illinois does not doom NAA’s claim. It does, however, doom NAA’s assertion of personal jurisdiction over Sunburst.