2These documents also show that the venture of opening Hugo Boss boutiques in the
United States was not profitable, and ultimately resulted in roughly $8 million dollars of losses
for Specialty Stores and its subsidiaries.
Stores, and SSIOO were alter egos of Harry Rosen to the extent that the outstanding obligations
of HRUSA, Specialty Stores, and SSIOO are also the obligations of Harry Rosen. In count II,
Old Orchard requested that the $2,706,437.48 default judgment entered in federal court against
Specialty Stores be enforced against Harry Rosen.
In response, Harry Rosen filed a special appearance and a motion to dismiss Old
Orchard’s complaint for lack of personal jurisdiction pursuant to sections 2-301 and 2-619(a) of
the Code. In its motion to dismiss, Harry Rosen contended that it was not subject to personal
jurisdiction in Illinois because it was a wholly separate business entity from HRUSA, Specialty
Stores, and SSIOO, which did not conduct or transact business in the United States. Harry Rosen
further explained that unlike the American Hugo Boss boutiques, its Canadian menswear stores
operated a different kind of retail business, which sold multiple brands of high-end menswear,
including Armani, Zegna, Canali, Dolce & Gabbana, Versace, Prada, Etro, and, also, Hugo Boss,
in addition to others. Harry Rosen also employed different individuals and offered them different
benefits. Each entity also observed corporate formalities and retained separate identities. Harry
Rosen attached numerous items to its motion to substantiate these facts, including an affidavit
from its secretary and chief financial officer, Conrad Frejlich, certificates of incorporation for all
of the entities, bank account statements for the entities, lists of employees, benefits information,
and financial statements and tax returns for the entities.2 In particular, the financial statement for
SSIOO shows that the corporation had hundreds of thousands of dollars worth of inventory and
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