See Advanced Tactical Ordnance Systems LLC v. Real Action Paintball, Inc., 751 F.3d 799 (7th Cir. 2014) (placement of publications, advertisements email blasts in non-geographically received by forum restricted residents, fulfillment of orders placed by forum residents, and (source) maintenance 6 of interactive website insufficient to support personal jurisdiction); United Airlines, Inc. v. Zaman, 152 F. Supp. 3d 1041 (N.D. Ill. 2015) (allegedly tortious statements about plaintiff published on defendants website and communications primarily initiated by plaintiff insufficient). The facts set forth in the Edmonson affidavit are closer to those at issue in Felland, where the plaintiffs invested in a real estate project in reliance of misrepresentations the defendants made over the course of years. In addition, Felland makes clear that in cases such as this, where the plaintiffs claims include an intentional tort such as fraud, communications expressly aimed at the forum state that contain intentional misrepresentations can support jurisdiction.
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