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In Illinois, Cook (P) sued Lexington (D) over a breach of contract. P was a headhunting firm and had submitted applicants to D that were not employed, but eventually, an applicant that was referred by P was hired by D after the search contract had expired. D was a Delaware corporation not licensed to do business in Illinois. P served the president of D while he was at a trade show in Chicago. D attended that trade show on a regular basis but did not have an office, a phone number, or an employee within the state. D disputed personal jurisdiction but was overruled and summary judgment was eventually granted in P's favor. D appealed and the appellate court held that there was no personal jurisdiction over D.

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