John Connelly suffered personal injuries when a tire manufactured by Uniroyal failed while his 1969 Opel Kadett was being operated on a highway in Colorado. Connelly's father had purchased the automobile from a Buick dealer in Evanston, Illinois. The tire bore the name "Uniroyal" and the legend "made in Belgium" and was manufactured by Uniroyal, sold in Belgium to General Motors, and subsequently installed on the Opel when it was assembled at a General Motors plant in Belgium. The automobile was shipped to the United States for distribution by General Motors. It appears that between the years 1968 and 1971 more than 4,000 Opels imported into the United States from Antwerp, Belgium, were delivered to dealers in Illinois each year; that in each of those years between 600 and 1,320 of the Opels delivered to Illinois dealers were equipped with tires manufactured by Uniroyal, and that the estimated number of Uniroyal tires mounted on Opels delivered in Illinois within each of those years ranged from 3,235 to 6,630. Connelly brought suit in Illinois against Uniroyal to recover damages for personal injuries. Uniroyal asserted that it was not subject to the jurisdiction of the Illinois courts because it is not registered to do business and has never had an agent, employee, representative, or salesperson in Illinois; that it has never possessed or controlled any land or maintained any office or telephone listing in Illinois; that it has never sold or shipped any products into Illinois, either directly or indirectly; and that it has never advertised in Illinois.
a. What arguments could Connelly make in support of its claim that Illinois courts have jurisdiction over Uniroyal?
b. What arguments could Uniroyal make in support of its claim that Illinois courts do not have jurisdiction over it?
c. Who should prevail? Explain