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Telemedicine Solutions LLC v. WoundRight Technologies, LLC

United States District Court for the Northern District of Illinois
27 F.Supp.3d 883 (2014)


Illinois company Telemedicine Solutions LLC (Telemedicine) (plaintiff) developed a wound-care management system called “Wound Rounds” that included an internet-based platform, software, and hardware it launched from 2005 to 2007. In 2012, Wyoming company WoundRight Technologies, Inc. (WoundRight) (defendant) registered a website marketing a similar system called “WoundRight.” WoundRight’s website advertised a mobile application, downloadable from third parties. Both companies used social media marketing channels. WoundRight purchased a Google ad that appeared when users searched the term “woundrounds.” The ad read, “Considering WoundRounds?—Don’t waste your time[.] Try the latest woundcare app for free!” and provided a link to WoundRight’s website. Telemedicine sued WoundRight in Illinois for business disparagement, trademark violation, and interference with prospective business advantage. WoundRight moved to dismiss, arguing the court lacked personal jurisdiction over it because WoundRight never specifically marketed in Illinois, targeted Illinois consumers, or had other significant contact there. Telemedicine responded with some 75 pages of exhibits, none of which referenced Illinois, but asked the court to allow jurisdictional discovery to determine the extent of WoundRight’s contacts with Illinois and prior knowledge about Telemedicine’s system.

Rule of Law


Holding and Reasoning (Dow, J.)

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