FIRST DIVISION
March 29, 2004

JUSTICE McBRIDE delivered the opinion of the court:

Illinois residents Marilyn L. Riemer and George Riemer filed this suit on October 20,2000, seeking damages for personal injuries and loss of consortium, after Marilyn was allegedlystruck and injured when a mirror fell from a wall on August 5, 1999, while the Riemers wereguests at the Claremont Resort & Spa in California. The sole issue on appeal is whether thecircuit court of Cook County correctly determined that the only defendant named in the Riemers'suit, a nonresident corporation, is subject to personal jurisdiction in Illinois because it was "doingbusiness" in Illinois through the sales activities of a subsidiary to a subsidiary corporation. The"doing business" doctrine is codified in section 2-209(b)(4) of the Code of Civil Procedure. 735ILCS 5/2-209(b)(4) (West 2000). Under the doctrine, a foreign corporation that engages in acontinuous and systematic course of business in Illinois becomes subject to the general jurisdictionof its courts, and may be called upon to defend suits in the forum even when those suits have noconnection with the corporation's activities in Illinois. The circuit court denied defendant's section2-301 motion to quash service of process and dismiss plaintiffs' cause of action based upon lack ofpersonal jurisdiction. 735 ILCS 5/2-301 (West 2000). This court, however, granted defendant'sinterlocutory petition for leave to appeal pursuant to Supreme Court Rule 306(a)(3) (166 Ill. 2dR. 306(a)(3)), and we now address its contention that it lacked sufficient business contacts withIllinois to invoke the general jurisdiction of its courts.

Discovery on the issue of jurisdiction revealed the following facts. Defendant KSLRecreation Corporation is a Delaware corporation with its primary place of business in La Quinta,California. Defendant corporation, formed in 1992, specializes in identifying and purchasingresort properties and then selling them to sub-subsidiary or "indirect subsidiary" corporationswhich operate and manage the properties. In 1993, defendant acquired the Doral Golf Resort &Spa in Miami, Florida, and the La Quinta Resort & Club and PGA West in La Quinta, California. In 1996, defendant acquired the Lake Lanier Islands Resort near Atlanta, Georgia. In 1997,defendant acquired the Grand Traverse Resort & Spa in northwest Michigan near Traverse City,Michigan. In 1998, defendant acquired the Claremont Resort & Spa near Berkeley, California,and the Grand Wailea Resort Hotel & Spa in Wailea, Maui, Hawai'i. Finally, in 2000, defendantacquired the Arizona Biltmore Resort & Spa in Phoenix, Arizona. None of the resort propertiesare owned, operated, or managed by the defendant corporation, and none of them are located inIllinois. Further, defendant does not own or lease any property in Illinois, it maintains no offices,mailing address, telephone number, or employees in Illinois, it is not licensed to do business inIllinois, and it does not have a registered agent for service of process in Illinois. One ofdefendant's wholly owned direct subsidiary corporations is KSL Recreation Group.

Direct subsidiary KSL Recreation Group is also a Delaware corporation, which in turnwholly owns at least 26 other Delaware corporations. The sub-subsidiaries include: (a) KSLClaremont Resort, which, since 1998, has owned and operated the facility where Marilyn Riemeris alleged to have been injured in 1999; (b) various corporations which own and operate the five other resort properties and develop and sell surrounding real estate; and (c) KSL Resorts Group,which solicits business for the six resorts. Operating the resorts includes providing lodging,conference services, food and beverages, golf and spa facilities, club memberships, entertainment,and athletic-focused special events.

The sub-subsidiary soliciting business for all of the resorts, KSL Resorts Group, is basedin Reston, Virginia, but has regional United States offices, including a midwest location, nearChicago, in Arlington Heights, Illinois.

Defendant's only contacts with Illinois were through the activities of its sub-subsidiary'sIllinois office. However, plaintiffs were never solicited by the Illinois office and their stay at theCalifornia resort was unrelated to any activity in Illinois. Nevertheless, they served process inDecember of 2000, on the only employee of the sub-subsidiary's Illinois office, Laura JeanGydesen.

At a discovery deposition taken on July 19, 2001, Gydesen stated that her employer hadexisted for about three years and had maintained an Illinois office during that time frame. Gydesen had been in Illinois for approximately 18 months, working as the sub-subsidiary'sdirector of Midwest sales. The Midwest office had been located in Des Plaines, Illinois, but wascurrently located in her residence in a high-rise apartment building in Arlington Heights, and itsmailing address was at an Arlington Heights Mailboxes Etc. location. Her territory included themidwestern states of Illinois, Minnesota, Wisconsin, Nebraska, Iowa, North Dakota, and SouthDakota.

Gydesen specified that the only business her employer conducted was soliciting sales forthe six resorts and that her only duties were to solicit sales to groups and meetings. She neversolicited individual bookings. She performed her duties through direct contacts, phonecampaigns, and trade shows. She did not use telemarketing or advertise through radio ortelevision. She relied on her knowledge of potential clients, and most of her sales efforts wentinto direct sales calls and trade shows. Two of the four trade shows she attended were in Illinois.

According to defendant's answers to the Riemers' interrogatories, Gydesen had booked atotal of 18 events for the six resorts, including one for the Claremont Resort & Spa in April 2001. Gydesen also stated during her deposition that she had generated about $6 million in business forthe six resorts during her 18 months in Illinois (between approximately January 2000 and July2001). The record also includes a Form 10-K Annual Report filed for the fiscal year endingOctober 321, 2000, by the sales corporation's parent, KSL Recreation Group. The Form 10-KAnnual Report indicated that income generated from operating the resorts totaled $69.5 millionfor the fiscal year ending on October 31, 1999, and $80.1 million for the fiscal year ending onOctober 31, 2000. It also disclosed that 96% of the revenue derived in fiscal 2000 byintermediate subsidiary KSL Recreation Group "together with its subsidiaries" was attributable totheir ownership and management of the resorts, and the remaining 4% of their revenue wasattributable to their development and sale of real estate in and around the resorts. Theintermediate subsidiary listed its 26 subsidiaries by name, including the sales subsidiary at issuehere and multiple subsidiaries associated with each of the six resorts. For example, there werefour subsidiaries associated with the hospitality operations and real estate holdings in Michigan,and others associated with the Claremont operations. In the text of its Form 10-K filing, theintermediate subsidiary repeatedly referred to itself and its subsidiaries in the collective, as "theCompany," and all of the financial figures disclosed in the Form 10-K were aggregated for "theCompany," rather than being broken out by the specific corporations. In the Form 10-K filing, theintermediate subsidiary also made references to the defendant parent corporation, but consistentlyreferred to the defendant parent corporation either by name or as "the Parent," distinguishing itfrom all of the other KSL corporate entities. Despite these clear and repeated distinctions, theRiemers erroneously suggest to this court, "All of the corporations, parent and subsidiary, arereferred to collectively in this [Form 10-K] filing as the 'Company,' " and "The SEC filing lists thecorporate officers and directors of the Company (which comprises all the corporate entities) ***." It is apparent, however, that the Riemers' assertions about "the Company" are incorrect. TheForm 10-K report filed with the Securities and Exchange Commission by the intermediatesubsidiary, KSL Recreation Group, does not suggest in any way that the defendant parentcorporation, KSL Recreation Corporation, is part of "the Company."

Gydesen also said that sometimes she took part in negotiating room rates or specialconsiderations for a particular group, but that she never executed any contracts. The hotel wouldsend a standard 12- to 15-page contract directly to the client or to Gydesen for delivery to theclient, and the hotel would execute the contract and any contract amendments. Further, beforeGydesen became the Midwest sales director, she worked at the La Quinta and Grand Wailearesorts, and in those capacities she had executed contracts. No one at KSL Resorts executedcontracts.

Gydesen also related that accommodations could be booked through one of the regionalsales offices, such as her Midwest office, or directly with a hotel's on-property staff, but if a clientbooked through the hotel's website, Gydesen would not receive a sales incentive. She hadnothing to do with sales over the Internet.

Gydesen was asked about a trade publication which appears to have been the July/August2000 edition of "Medical Meetings," in which it was reported that Gydesen had been named"director of sales, Midwest" for defendant KSL Recreation Corporation, rather than for sub-subsidiary KSL Resorts Group. The publisher, Adams Business Media, also reported on theappointments and promotions of other individuals in the meeting sales field. Gydesen stated thatif a publication had listed her as a director of sales for KSL Recreation Corporation, thepublication was incorrect.

Larry E. Lichliter, the "L" in the various KSL corporations, swore in an affidavit that sub-subsidiary KSL Claremont Resort -- rather than parent KSL Recreation Corporation -- directlyowned and operated the Claremont Resort and Spa in California. Lichliter also provided detailsabout the sub-subsidiary responsible for sales for all the resorts, KSL Resorts Group. He swore ithad its own corporate charter, maintained its own bank accounts, corporate books and financialstatements, had its own tax identification number, and paid its own taxes. He also swore thatdefendant parent KSL Recreation Corporation did not "exhibit any amount of control" over theinternal affairs of sub-subsidiary KSL Resorts Group. Further, sub-subsidiary KSL ResortsGroup retained sufficient operating capital, it did not rely on defendant KSL RecreationCorporation to keep its business in operation, and none of its obligations had been guaranteed orco-signed by defendant KSL Recreation Corporation.

In addition to disclosing the intermediate subsidiary's sources of income, the Form 10-Kreferenced above also indicated that the various corporations had substantially the same directorsand key executive officers. Lichliter, for example, was a founding stockholder of the parentcorporation, defendant KSL Recreation Corporation, and had served as a director and itsexecutive vice president since its inception. He was also serving as the chief financial officer andtreasurer of the intermediate subsidiary, KSL Recreation Group, and was a director and eitherpresident or executive vice president of each of the sub-subsidiaries, including sub-subsidiary KSLResorts Group.

The intermediate subsidiary's Form 10-K also included a written expense allocationagreement that the intermediate subsidiary and defendant parent corporation had entered into onApril 30, 1997. According to agreement, if requested, defendant would provide general business,financial, legal, and tax advice to the intermediate subsidiary and its subsidiaries, and would becompensated for its advice. The agreement had an initial term of one year, but automaticallyrenewed unless terminated on 30 days' notice by either party. There is no indication in the recordon appeal that the agreement was ever terminated, and in fact, the Form 10-K disclosed that "theCompany," meaning the intermediate subsidiary KSL Recreation Group and its 26 subsidiaries,had expended $9.8 million in expense allocation agreement fees in 1999, and $10.7 million in2000. As noted above, however, all of the financial figures in the Form 10-K were aggregated for"the Company," and thus the report did not disclose which specific KSL entity or entities hadreceived the defendant parent corporation's advice and paid the resulting fees to the defendantparent corporation.

The intermediate subsidiary's Form 10-K also disclosed that "the Company" had enteredinto a "tax sharing" agreement with the defendant parent corporation, providing for the parent,the intermediate subsidiary, and the 26 sub-subsidiaries to share current and deferred income taxexpenses and benefits. The parent corporation filed consolidated federal and combined stateincome tax returns which included the subsidiary and sub-subsidiaries. If the defendant parentcorporation utilized tax losses of the intermediate subsidiary and sub-subsidiaries, it wouldcompensate them.

The intermediate subsidiary's Form 10-K also made disclosures about its liquidity andcapital resources. It indicated that "historically," the intermediate subsidiary and its 26subsidiaries (or "the Company") had funded their capital and operating requirements with acombination of operating cash flow and borrowing, and equity investments from the defendantparent corporation. It was expected, however, that they would fund their future capital andoperating requirements through a combination of borrowing and cash generated from operations.

Finally, discovery also disclosed that some of the corporate entities had Internet addresses. According to Gydesen and pages printed from the Internet, the sub-subsidiary responsible forsales, KSL Resorts Group, maintained a website at kslresorts.com. This site provided informationabout the resorts it was promoting, and links to (a) the resorts' websites, (b) the "Sales Team,"and (c) the parent corporation's website at kslrecreation.com. Gydesen's statements about theInternet indicated that the sales team link connected potential clients with hotel on-site staff,rather than with regional sales office personnel such as herself.

After discovery closed, the parties filed written briefs which included the defendantparent's interrogatory answers, Lichliter's affidavit, the intermediate subsidiary's Form 10-KAnnual Report, the transcript of Gydesen's deposition, and the printouts from the sub-subsidiary'swebsite. On November 26, 2001, after considering the written briefs and oral arguments, the trialjudge found defendant was "doing business" in Illinois. The judge stated there was "no issue" thedefendant's sub-subsidiary KSL Resorts Group was "actively 'doing business' in Illinois," becausethe sub-subsidiary had maintained a sales office in Illinois for three years, Gydesen's position waspermanent, Gydesen had generated $6 million in sales, and Gydesen had negotiated salescontracts involving Illinois residents and booked events for the California resort where plaintiffMarilyn Riemer was injured. The judge also stated the only issue to be decided was whether thesub-subsidiary and its California-based parent were insufficiently separate so as to make the parentamenable to suit in Illinois. The judge characterized the relationship between the twocorporations as "synergistic," and concluded that based on the six "Cannon" factors (CannonManufacturing Co. v. Cudahy Packing Co., 267 U.S. 333, 69 L. Ed.634, 45 S. Ct. 250 (1925))stated in Graco, Inc. v. Kremlin, Inc., 558 F. Supp. 188 (N.D. Ill. 1982), there were sufficientfactual ties between the two entities to warrant exerting personal jurisdiction in Illinois over theparent.

The following legal principles are pertinent to KSL Recreation Corporation's appeal fromthat ruling. A determination of personal jurisdiction based upon only documentary evidence isreviewed de novo. Alderson v. Southern Co., 321 Ill. App. 3d 832, 846, 747 N.E.2d 926, 938(2001). The plaintiff bears the burden of establishing a prima facie basis for exercising personaljurisdiction over a defendant. Alderson, 321 Ill. App. 3d at 846, 747 N.E.2d at 938. However,the plaintiff's prima facie case may be overcome by uncontradicted evidence which defeatsjurisdiction. Alderson, 321 Ill. App. 3d at 846, 747 N.E.2d at 938.

The United States Supreme Court has determined that a state's power to invoke personaljurisdiction over a nonresident defendant is limited by the due process clause of the fourteenthamendment (U.S. Const., amend. XIV). Maunder v. DeHavilland Aircraft of Canada, Ltd., 102Ill. 2d 342, 348, 466 N.E.2d 217, 220 (1984). Due process requires that if a defendant is notpresent within the territory, he must have " 'certain minimum contacts with it such that themaintenance of the suit does not offend "traditional notions of fair play and substantial justice." ' " Braband v. Beech Aircraft Corp., 72 Ill. 2d 548, 553-54, 382 N.E.2d 252, 254 (1978) ("BeechAircraft"), quoting International Shoe Co. v. Washington, 326 U.S. 310, 316, 90 L. Ed. 95, 102,66 S. Ct. 154, 158 (1945). The defendant's business contacts with the State must be "continuousand systematic" before its courts may exert jurisdiction. Maunder, 102 Ill. 2d at 349, 466 N.E.2dat 221, citing Helicopteros Nacionales de Columbia v. Hall, 466 U.S. 408, 80 L. Ed. 404, 104 S.Ct. 1868 (1984). Instead of conducting a mechanical or quantitative assessment of acorporation's activities within the state, a court evaluates the quality and nature of thecorporation's activities within the state, to determine whether it is reasonable to require thecorporation to defend a particular suit within that forum. Beech Aircraft, 72 Ill.2d at 554, 382N.E.2d at 255, citing Shaffer v. Heitner, 433 U.S. 186, 203-04, 53 L.Ed. 683, 697, 97 S.Ct.2569, 2580 (1977).

" '[T]o the extent that a corporation exercises the privilege ofconducting activities within a state, it enjoys the benefits andprotection of the laws of that state. The exercise of that privilegemay give rise to obligations, and, so far as those obligations ariseout of or are connected with the activities within the state, aprocedure which requires the corporation to respond to a suitbrought to enforce them can, in most instances, hardly be said to beundue.' " Maunder, 102 Ill. 2d at 348-49, 466 N.E.2d at 220,quoting International Shoe, 326 U.S. at 319, 90 L. Ed. at 104, 66S. Ct. at 160.

In addition, in Illinois, a court's assertion of personal jurisdiction over a foreigncorporation requires a determination that the corporation was " 'present and doing business' "within Illinois. Beech Aircraft, 72 Ill. 2d at 554-55, 382 N.E.2d at 255. The Illinois SupremeCourt has repeatedly indicated that there is no precise test for a court to determine whether aforeign corporation is doing business in Illinois and that each case turns on its unique facts. BeechAircraft, 72 Ill. 2d at 555-56, 382 N.E.2d at 255; Cook Associates, Inc. v. Lexington UnitedCorp., 87 Ill. 2d 190, 201, 429 N.E.2d 847, 852 (1981); Maunder, 102 Ill. 2d at 351, 466 N.E.2dat 221. The "doing business" standard is quite high (Alderson, 321 Ill. App. 3d at 848, 747N.E.2d at 940; Rokeby-Johnson v. Derek Bryant Insurance Brokers, Ltd., 230 Ill. App. 3d 308,318, 594 N.E.2d 1190, 1197 (1992)), and the defendant must carry on business activity withinthe State " ' "not occasionally or casually, but with a fair measure of permanence and continuity." ' " Alderson, 321 Ill. App. 3d at 849, 747 N.E.2d at 940, quoting Cook Associates, 87Ill. 2d at 203, 429 N.E.2d at 853; Maunder, 102 Ill.2d at 351, 466 N.E.2d at 221. In otherwords, there must be a " 'course of business or "regularity of activities" as opposed to isolated orsporadic acts.' " Alderson, 321 Ill. App. 3d at 849, 747 N.E.2d at 940, quoting Radosta v. Devil'sHead Ski Lodge, 172 Ill. App. 3d 289, 294, 566 N.E.2d 561, 564 (1988). In general, "doingbusiness" means conducting business in Illinois of such a character and to such an extent that itmay be inferred that the defendant has subjected itself to the jurisdiction and laws of this state andis bound to appear when properly served. Alderson, 321 Ill. App. 3d at 848, 747 N.E.2d at 940;Cook Associates, 87 Ill. 2d at 201, 429 N.E.2d at 853. The foreign corporation is considered tobe constructively present in Illinois and its assent to service on an agent in Illinois is implied, evenfor causes of action unrelated to its transactions in Illinois. Colletti v. Crudele, 169 Ill. App. 3d1068, 1078-79, 523 N.E.2d 1222, 1229 (1988), citing Cook Associates, 87 Ill. 2d at 199-200, 429N.E.2d at 851-52. In effect, the foreign corporation has taken up residence in Illinois and,therefore, may be sued on causes of action both related and unrelated to its activities in Illinois. Alderson, 321 Ill. App. 3d at 849, 747 N.E.2d at 940. In this regard, the "doing business"doctrine is distinguishable from the long arm statute, which is not at issue here. The long armstatute subjects a nonresident to jurisdiction in Illinois if the nonresident has taken certainenumerated acts, such as the transaction of business or the commission of a tortious act in Illinois,and the plaintiff's claim arises from that specific act. 735 ILCS 5/2-209 (a), (f) (West 2000). Another way of distinguishing these two concepts is to consider that the "doing business" doctrineresults in the assertion of "general" jurisdiction over a corporation, and the long arm statuteresults in the assertion of "specific" jurisdiction over a corporation. Spartan Motors, Inc. v. LubePower, Inc., 337 Ill. App. 3d 556, 561, 786 N.E.2d 613, 618 (2003); Alderson, 321 Ill. App. 3dat 857, 747 N.E.2d at 947.

In order to determine whether a foreign corporation has established a permanent andcontinuing relationship with Illinois, a court reviews its contacts with the forum over a continuousperiod of time rather than a specific, fixed point in time. Reeves v. Baltimore & Ohio R.R. Co.,171 Ill. App. 3d 1021, 1027, 526 N.E.2d 404, 407 (1988). The relevant time period to bereviewed begins approximately when the claim arose and it extends to when suit was filed andservice of process was attempted. Reeves, 171 Ill. App. 3d at 1027, 526 N.E.2d at 408. A courtshould review the contacts over this entire time period; however, the critical point of inquiry is thetime the defendant was made a party to the suit and was served. Reeves, 171 Ill. App. 3d at 1027,526 N.E.2d at 408.

Although there is no fixed "doing business" test, most Illinois courts finding personaljurisdiction over foreign corporations have based their determinations on facts such as whetherthe defendant has maintained offices or engaged in sales activities in Illinois. Huck v. NorthernIndiana Public Services Co., 117 Ill. App. 3d 837, 840, 453 N.E.2d 1365, 1368 (1983). Notably,mere advertisement, even through the Internet, participation in trade shows, or solicitation by anemployee or agent who lacks authority to do more have not been enough to sustain personaljurisdiction in Illinois. Cook Associates, 87 Ill. 2d 190, 429 N.E.2d 847 (trade shows); Radosta,172 Ill. App. 3d 289, 526 N.E.2d 561 (trade show and various advertising); Forrester v. SevenSeventeen HB St. Louis Redevelopment Corp., 336 Ill. App. 3d 572, 784 N.E.2d 834 (2002)(telephone book and website advertising); Kadala v. Cunard Lines, Ltd., 226 Ill. App. 3d 302,315, 589 N.E.2d 802, 810 (1992) (newspaper ads, travel brochures, and solicitation by travelagents); Dal Ponte v. Northern Manitoba Native Lodges, Inc., 220 Ill. App. 3d 878, 581 N.E.2d329 (1991) (trade shows through agent). Since deriving revenue from Illinois may simply be aconsequence of successful solicitation in the forum, even substantial earnings from this state havenot been considered indicative of whether a corporation has established a permanent andcontinuing relationship with the forum. Hulsey v. Scheidt, 258 Ill. App. 3d 567, 572-73, 639N.E.2d 905, 909 (1994) (no court has held revenue is the dispositive variable); Rokeby-Johnson,230 Ill. App. 3d at 319, 594 N.E.2d at 1198 (substantial revenue from sales is not enough tosatisfy "doing business" in a contract action); Kadala, 226 Ill. App. 3d at 315, 589 N.E.2d at 810(revenue is a natural result of successful solicitation). Compare Connelly v. Uniroyal, 75 Ill. 2d393, 389 N.E.2d 155 (1979) (products liability action). However, when a foreign corporationengages in more than mere solicitation through its own staff (St. Louis-San Francisco Ry. Co. v.Gitchoff, 68 Ill. 2d 38, 369 N.E.2d 52 (1977)), a subsidiary corporation (Maunder, 102 Ill. 2d342, 466 N.E.2d 217), or even an unrelated company (Beech Aircraft, 72 Ill. 2d 548, 382 N.E.2d252), the nature and quality of its contacts with Illinois may be considered significant enough toinvoke the jurisdiction of this forum's courts.

Since the present dispute involves subsidiary corporations, the most relevant Illinois caseis Maunder, in which it was argued that a Canadian corporation was doing business in Illinoisthrough a wholly owned subsidiary officed outside Chicago, in Rosemont, Illinois. Maunder, 102Ill. 2d at 345, 466 N.E.2d at 219. The Canadian parent designed and manufactured aircraft, andestablished the Rosemont subsidiary to sell and distribute parts for its planes. Maunder, 102 Ill.2d at 345, 466 N.E.2d at 218-19. The subsidiary's sole function was to sell and distribute thoseparts. Maunder v. DeHavilland Aircraft of Canada, Ltd, 112 Ill. App. 3d 879, 882, 445 N.E.2d1303, 1306 (1983), aff'd, 102 Ill. 2d 342, 466 N.E.2d 217 (1984). In addition, the parentdistributed an illustrated parts catalog indicating that its United States customers should sendparts orders to the subsidiary in Rosemont, and whenever the parent received parts ordersdirectly, it forwarded them to Rosemont. Maunder, 112 Ill. App. 3d at 882, 445 N.E.2d at 1306. The record also showed that print ads which the Canadian parent placed in American aviationjournals touted its aircrafts' reliability and simple maintenance, and the availability of parts andservice in Rosemont. Maunder, 102 Ill. 2d at 347, 466 N.E.2d at 219. The Canadian companynot only set up the Illinois subsidiary as its American supply depot, but it also owned all its stock,paid its directors, and guaranteed its lease. Maunder, 102 Ill. 2d at 346, 466 N.E.2d at 219. Further, one person was president of both corporations, and all the corporate officers and themanager of the Rosemont facility were accountable to that one individual. Maunder, 112 Ill.App. 3d at 883, 445 N.E.2d at 1306. A company manual even stated that the subsidiary wascontrolled by the Canadian parent, and the record showed the subsidiary's staff placed an averageof eight telephone calls per day to the Canadian office. Maunder, 102 Ill. 2d at 346, 466 N.E.2dat 219.

When one of the Canadian-made planes crashed in Central Africa, personal injury andwrongful death suits were filed in Cook County and the papers were served on a Rosemontemployee. Maunder, 102 Ill. 2d at 345, 455 N.E.2d at 218-19. The circuit court was persuadedto dismiss the tort suits for lack of personal jurisdiction, but the appellate court reviewed theCanadian defendant's activities in Illinois and found that jurisdiction was properly exerted. Maunder, 112 Ill. App. 3d at 883, 445 N.E.2d at 1306. The court remarked upon the greatextent to which the parent controlled the subsidiary and upon the parent's own activities atpromoting the sale of its products in Illinois, and concluded that the Canadian company had been"actively and systematically doing business in Illinois" through its Illinois subsidiary. Maunder,112 Ill. App. 3d at 883, 445 N.E.2d at 1306. The supreme court agreed with this assessment(Maunder, 102 Ill. 2d at 346, 466 N.E.2d at 219), characterizing the Rosemont office as an"essential component" of the Canadian parent's business activities in Illinois. Maunder, 102 Ill. 2dat 350, 466 N.E.2d at 221.

Maunder figured prominently in a subsequent court's analysis of whether Delawarecorporations which were principally officed in Georgia were doing business in Illinois through theactivities of a subsidiary corporation which, at least on paper, owned and operated a coal-firedelectric power plant at the Indiana/Illinois border. Alderson, 321 Ill. App. 3d 832, 747 N.E.2d.926. In Alderson, the court commented:

"The theory underlying Maunder is that, if a subsidiarycorporation is acting as the parent corporation's Illinois agent in thesense of conducting the parent's business rather than its own, then itis appropriate to assert jurisdiction over the parent. Parents ofwholly-owned subsidiaries necessarily control, direct, and supervisesubsidiaries to some extent. If, however, the subsidiary isconducting its own business, then an Illinois court may not assert inpersonam jurisdiction over the parent simply because it is theparent. [Citation.] Also, standing alone, the existence of commonofficers or directors serving corporations is not sufficient to conferjurisdiction over a nonresident parent corporation. [Citation.] " Alderson, 321 Ill. App. 3d at 854, 747 N.E.2d at 944.

The court considered the activities of the various defendant corporations and concludedthat the local subsidiary was simply a conduit through which the higher corporate entities wereselling electricity, or "doing business," in Illinois. Alderson, 321 Ill. App. 3d at 849-55, 747N.E.2d at 940-46. The evidence disclosed that the most senior corporation was "merely a holdingcompany that has established many subsidiaries to carry out its business" (emphasis added) andthat the intermediate corporations held the assets, and managed and oversaw day-to-dayoperations at the power-generating facility. Alderson, 321 Ill. App. 3d at 855, 747 N.E.2d at 945. The court emphasized that corporations should not be able to insulate themselves fromjurisdiction in a state in which they do business by simply establishing multiple subsidiarycorporations. Alderson, 321 Ill. App. 3d at 855, 747 N.E.2d at 946. Because the evidenceshowed the senior corporations actually controlled the power plant, the court concluded theywere doing business in Illinois through that local facility and were appropriately subjected tojurisdiction in this forum. Alderson, 321 Ill. App. 3d at 855, 747 N.E.2d at 945-46.

Before applying these legal principles to the present dispute, we point out that none of thecases cited above, particularly Maunder and Alderson, which specifically involve parent andsubsidiary corporations, endorse the analytical approach which the trial judge here employed offirst determining whether the local subsidiary was doing business in Illinois. When a courtdetermines whether a foreign corporation is doing business in this state, the question is notwhether its local affiliate is doing business in the jurisdiction, but whether the foreign parent isdoing business in the jurisdiction through its local affiliate. We reiterate the pertinent portions ofthose cases. In the first Maunder appeal, the court indicated that although there is no "all-inclusive test" for determining whether a foreign corporation is doing business in this state, thefinding "generally requires that the corporation conducts business in Illinois of such a characterand extent as to warrant the inference that it has subjected itself to the jurisdiction and laws ofIllinois." Maunder, 112 Ill. App. 3d at 882, 445 N.E.2d at 1305. After the supreme courtgranted leave to appeal, it independently evaluated the "business contacts between Ltd. [theCanadian parent] and the State of Illinois" (Maunder, 102 Ill. 2d at 350, 466 N.E.2d at 221) andconcluded, "Clearly Ltd. [the Canadian parent] through Inc. [the Rosemont subsidiary] was doingbusiness in Illinois." Maunder, 102 Ill. 2d at 352, 466 N.E.2d at 222. Finally, in Alderson, thecourt considered whether multiple parent corporations were doing business in Illinois through thelocal power plant, and concluded the power plant was a " ' conduit ' through which [the parentcorporations] did business [in Illinois.]" Alderson, 321 Ill. App. 3d at 855, 747 N.E.2d at 946. Inthese cases, the dispositive inquiry was the extent to which the foreign parent was controlling, andthus, doing business in Illinois through a local subordinate entity.

The two Maunder opinions are also significant here because both courts discredited theCannon rationale, which was at the heart of the trial judge's determination that there weresufficient ties between the Illinois and California KSL entities to exert personal jurisdiction overthe California parent. See Graco, 558 F. Supp. at 190-91, citing Cannon, 267 U.S. 333, 69 L.Ed.634, 45 S. Ct. 250. The appellate court indicated that despite the defendant's urging, it wouldnot rely on Cannon, because that case "was decided more than 20 years prior to InternationalShoe [citation], the decision in which the focus of the [United States Supreme Court] onjurisdictional questions shifted from a defendant's 'presence' in the forum State to his 'minimumcontacts' therewith." Maunder, 112 Ill. App. 3d at 883, 445 N.E.2d at 1306. "Consequently,Cannon merely purports to hold that conducting business through a wholly owned subsidiarydoes not necessarily render the parent corporation amenable to process in the State where thesubsidiary does business." Maunder, 112 Ill. App. 3d at 883- 84, 445 N.E.2d at 1306. Thesupreme court remarked, "Although Cannon has not been expressly overruled, its vitality hasbeen limited by the subsequent decisions in International Shoe and its progeny. [Citations.] Manycommentators have noted that the Cannon opinion is no longer followed in an era when theUnited States Supreme Court focuses on 'contacts' rather than 'physical presence' in determiningthe scope of State court jurisdiction over nonresident defendants. [Citations.]" Maunder, 102 Ill.2d at 353, 466 N.E.2d at 222. Furthermore, this was not the first time the Illinois Supreme Courtindicated that Illinois courts do not rely on Cannon or its progeny. Six years earlier, in BeechAircraft, the court remarked that the United States Supreme Court had recently reviewed thepertinent authorities dating as far back as 1878, a date well before the 1925 Cannon decision or1945's International Shoe, and had "concluded that the standards elucidated in International Shoe*** continue[] to be the test of a State's jurisdiction over a foreign corporation." Beech Aircraft,72 Ill. 2d at 553, citing Shaffer, 433 U.S. 186, 53 L.Ed.2d 683, 97 S.Ct. 2569. Even Gracoacknowledged that some courts have criticized the Cannon analysis and prefer to rely on statestatutes and constitutional due process to determine whether jurisdiction exists over a nonresidentparent corporation. Graco, 558 F. Supp. at 191. In fact, after applying the Cannon factors(Graco, 558 F. Supp. at 190-91), the Graco court engaged in a separate analysis of its defendant'sactivities under the "doing business" doctrine as stated in Cook Associates, 87 Ill. 2d 190, 429N.E.2d 847, a case cited extensively above, and another Illinois case that is specific to productsliability. Graco, 558 F. Supp. at 192-93. We also note that Graco, 558 F. Supp 188, is a lowerfederal court case. It was presented by the Riemers in opposition to the motion to quash serviceand dismiss based on lack of personal jurisdiction. However, lower federal court decisions are atbest persuasive rather than binding on Illinois state courts (People ex rel. Ryan v. World Churchof the Creator, 198 Ill. 2d 115, 127, 760 N.E.2d 953, 960 (2001)), and as discussed above,Illinois has declined to adopt a precise test for determining whether a foreign corporation is doingbusiness in Illinois. For these reasons, the trial judge's almost exclusive reliance on the Cannonfactors was misplaced. For these same reasons, we decline to address the extensive written andoral arguments the parties offer this court regarding Cannon's application to their dispute.

Finally, our de novo review of the business contacts between defendant and the State ofIllinois leads us to conclude that defendant did not have sufficient contacts to warrant invocationof personal jurisdiction by an Illinois court. The contacts to be reviewed span between August1999, when Marilyn Riemer was purportedly struck and injured in California by the resort's fallingmirror, and the last three months of 2000, when suit was filed and service was accomplished inIllinois. The record discloses that the California parent was not engaged in a pattern of permanentand continuous activities in Illinois during that time frame. Its only contacts with Illinois werethrough the presence of Gydesen, an Illinois resident, and Internet webpages that were accessiblein Illinois. Gydesen was an employee of one of defendant's sub-subsidiary corporations, theVirginia-based KSL Resorts Group, which functioned strictly as a solicitation arm for the six out-of-state resorts. She worked from her private residence, rather than from an office open to thepublic, and she initiated contacts with Midwest business groups or associations through targetedmeans such as direct calls and trade shows rather than to the general public through radio andtelevision broadcasts, newspapers, or telemarketing. Only two of the four trade shows sheattended were in Illinois. Her permanent base in Illinois made her presence more significant thanthe transient trade show attendance in cases such as Cook Associates (87 Ill. 2d 190, 429 N.E.2d847), Radosta (172 Ill. App. 3d 289, 526 N.E.2d 561), and Dal Ponte (220 Ill. App. 3d 878, 581N.E.2d 329); however, she merely solicited potential clients to enter into contracts withrepresentatives of the six out-of-state resorts. She did not execute any contracts, nor, for thatmatter, did anyone else who worked for the Virginia-based sub-subsidiary that employed her. Theagreements were executed by resort personnel outside Illinois and the agreed-upon services wereprovided by resort personnel outside Illinois. The Internet sites maintained by her Virginia-basedemployer and the six out-of-state resorts were simply additional means of enticing potential clientsto contract with resort personnel outside of Illinois. Forrester, 336 Ill. App. 3d at 581, 784N.E.2d at 840. In other words, Gydesen's activities and the webpages were mere solicitationcomparable to or even less than the advertising and trade show attendance that was consideredinsufficient in the four cases just cited to establish that foreign entities were doing business inIllinois. We could end our analysis here with the conclusion that the quality and nature of theactivities in Illinois -- mere solicitation -- were not enough to constitute doing business in theforum. However, in addition to the very limited quality and nature of the activity in Illinois, thereis absolutely no suggestion that it amounted to doing the business of the California parent.

In contrast to Maunder or Alderson, there is no evidence that Gydesen's activities or theInternet sites were essential components of the California parent's business or were controlled bythe California parent. The record shows the parent specialized in acquiring resort properties andthe surrounding real estate, but after it acquired these assets, it relinquished their direct ownershipand operation by selling the properties to other KSL corporations. The subsidiary KSLRecreation Group and the sub-subsidiaries, such as the one running the Claremont, were in thebusiness of owning and operating the six resorts. Gydesen worked for a separate sub-subsidiarythat solicited business for all of the resorts. It appears then that her solicitation activitiesbenefitted and were on behalf of the various sub-subsidiaries that actually owned and operated thefacilities and the subsidiary that claimed the resulting income in its Form 10-K Annual Report,KSL Recreation Group. Arguably her efforts were a component of the business at thatintermediate level. It is questionable, however, whether her solicitation efforts were an "essentialcomponent" of business at that intermediate level. More important, we cannot concludeGydesen's efforts in Illinois to solicit convention groups to stay at the various out-of-state resortproperties were essential to the California parent's business of acquiring the properties. In fact,the record does not show that any of the activity at the sub-subsidiary level, whether it wasGydesen's in-person, telephone, trade show, or mail solicitation, Internet solicitation, orownership and operation of the properties, was essential to the parent's business of acquiring theproperties. The record also fails to show that the parent exerted any control over Gydesen'ssolicitation activities. In other words, in contrast to both Maunder and Alderson, there is noevidence that the local office was conducting the parent's business, or put another way, that theparent was doing business through the local office. Facts that the Riemers now rely upon do notindicate that the local sub-subsidiary or even the intermediate subsidiary was controlled by theparent corporation. The Riemers couch these facts in terms of the Cannon factors. Nevertheless,to the extent they rely on these facts as indications that the parent was doing business in Illinois,we conclude that their reliance is misplaced. The Riemers point out, for example, that theintermediate subsidiary's Form 10-K disclosed the various KSL corporations were part of a tax-sharing agreement and that they consolidated their tax returns in order to take advantage ofcertain tax laws. Although the Riemers consider this fact significant, we do not, becausecombining financial data for tax purposes is not an indication that the defendant parentcorporation managed or oversaw the day-to-day operations in Illinois. Furthermore, it did notnegate or contradict Lichliter's specific sworn assertions that the local sub-subsidiary keptindependent financial records, paid its own taxes, and was not controlled by the defendant parentcorporation. The Riemers also point out that the Form 10-K itself provided "ConsolidatedStatements of Operations" and that an explanatory note in the report indicated that "intercompanytransactions and balances have been eliminated" in those statements. As summarized above, thereport filed by the intermediate subsidiary may have blurred the distinctions between itself and its26 subsidiaries but it consistently distinguished the parent corporation as a separate and distinctentity. We do not read the intermediate subsidiary's actions or remarks about itself and its varioussubsidiaries as indicators that its parent corporation subsumed any subentity into any of its ownfinancial records. Neither the multicorporation tax sharing arrangement nor the intermediatesubsidiary's Form 10-K filing refuted the sworn statement that the sub-subsidiary at issuemaintained a distinct financial identity from the parent corporation and was not controlled by theparent. The Riemers also attach great significance to the expense allocation agreement betweenthe defendant parent and the intermediate subsidiary KSL Recreation Group, indicating that, ifrequested, the parent would provide any of the various subsidiaries with management and adviceand use of the parent's resources. The fact that there was an agreement to that effect tells usnothing about the actual relationship between the California and Illinois entities. Although notargued by the Riemers, the Form 10-K specified that a substantial amount of fees had been paid tothe parent during the relevant time period as a result of this agreement -- $9.8 million in 1999, and$10.7 million in 2000. However, as noted earlier, the Form 10-K did not specify whether theintermediate subsidiary, one of its 26 sub-subsidiaries, or a combination of those 27 entities, hadobtained the parent's assistance. Furthermore, any general inference that might have been drawnin favor of the Riemers on the basis of this information was negated by Lichliter's specific swornstatement that the California parent did not control the Illinois office. The Riemers also point tothe fact that the California parent and Virginia sales sub-subsidiary had substantially the samedirectors and key executive officers. This fact alone does not demonstrate that the Californiaparent controlled the activities in Illinois and it is not enough to confer jurisdiction over thenonresident parent. Alderson, 321 Ill. App. 3d at 854, 747 N.E.2d at 944. Furthermore, even inthe aggregate, the facts emphasized by the Riemers do not demonstrate the local activities werecontrolled by the defendant parent corporation.

We conclude that the defendant parent corporation's contacts with Illinois were limited tomere solicitation by a sub-subsidiary that was officed in Illinios and sub-subsidiaries' Internet sitesthat were accessible in Illinois, which were not controlled by the defendant parent corporation. These contacts were an insufficient basis for concluding that defendant was doing business inIllinois through any sub-subsidiary and therefore subject to the personal jurisdiction of our courts. We find, accordingly, that defendant's motion to quash service of process and dismiss plaintiffs'complaint based on lack of personal jurisdiction should have been granted, and we reverse thetrial judge's order denying the motion.

Reversed.

CAHILL and GARCIA, JJ., concur.