" Ill. Rev. Stat. 1987, ch. 110, par. 2-209. Defendant contends, as it did in the trial court, that Cunard's jurisdictional status was previously decided adversely to the plaintiff in the case of Wiedemann v. Cunard Line Ltd. (1978), 63 Ill. App.3d 1023, 380 N.E.2d 932, and should not be altered on present reconsideration. We agree.

Since it cannot seriously be maintained that the tort complained of occurred anywhere other than Florida, § 2-209(a)(1) is the only source of statutory long-arm jurisdiction. Although at one time the Illinois courts interpreted the state's long-arm statute to be coterminous with the limits imposed by the Constitution's Due Process Clause, see, e.g., Biltmoor Moving and Storage Co. v. Shell Oil Co., 606 F.2d 202 (7th Cir. 1979); Wiedemann v. Cunard Line Ltd., 63 Ill. App.3d 1023, 20 Ill.Dec. 723, 380 N.E.2d 932 (1st Dist. 1978), the Illinois courts now use a more restrictive approach. See Young v. Colgate-Palmolive Co., 790 F.2d 567, 569 (7th Cir. 1986); Green v. Advance Ross Electronics Corp., 86 Ill.2d 431, 56 Ill.Dec. 657, 427 N.E.2d 1203 (1981).

Kadala, 226 Ill. App.3d at 313. In Wiedemann v. Cunard Line Ltd., 63 Ill. App.3d 1023, 380 N.E.2d 932 (1978), the plaintiff was injured on a cruise he took after responding to an advertisement shown in Illinois. The defendant two Illinois residents to promote, in Illinois, travel on the defendant's ships, and the defendant also did market research in Illinois.

See Logal v. Inland Steel Industries, Inc., 154 Ill.Dec. 152, 568 N.E.2d 152, 156-57 (1991) (use of another corporation's trademark is not enough to pierce the corporate veil). In Wiedemann v. Cunard Line Ltd., 20 Ill.Dec. 723, 380 N.E.2d 932, 934, 936 (1978), the plaintiff was injured while vacationing on a beach owned by Hotel La Toc. She alleged that Cunard, a "sister" corporation owned by the same parent of the hotel, "owned, operated, managed, maintained and controlled the hotel and its premises" and that Cunard induced them, through advertisements and language such as "Cunard's lovely Hotel La Toc" and "Cunard's luxurious La Toc resort on unspoiled St. Lucia", to contract for the tour. The court declined to hold Cunard liable because:

Id., 22 Ill.2d at 436, 176 N.E.2d at 763. The Illinois Appellate Court followed this aspect of Gray in Wiedemann v. Cunard Line Limited, 63 Ill. App.3d 1023, 20 Ill. Dec. 723, 380 N.E.2d 932 (1st Dist. 1978). In Wiedemann, a traveler sued a cruise ship owner, a vacation tour operator and others for injuries he sustained on a beach at a resort hotel in the West Indies. The court found no tortious act in Illinois, since the traveler was injured in the West Indies and that was the only place where any specifically alleged misrepresentations had been made.

It (CMH) then argues that its activities in Illinois, because of their general nature and in that they were reasonably limited in quantity and dollar amount, see footnote 5, page 536, cannot realistically be considered substantial. See Braasch v. Vail Associates, Inc., 370 F.Supp. 809, 813-14 (N.D.Ill.1973); see generally Wiedemann v. Cunard Line, Ltd., 63 Ill.App.3d 1023, 20 Ill.Dec. 723, 380 N.E.2d 932 (1978).           The term substantial, however, when utilized in a jurisdictional context, is both a relative and objective one.

¶ 93 "When a defendant challenges jurisdiction, a court will make a preliminary inquiry as to whether the complaint states a legitimate cause of action ‘to insure that acts or omissions which form the basis of a cause of action that is patently without merit will not serve to confer jurisdiction.’ " Zeunert v. Quail Ridge Partnership , 102 Ill. App. 3d 603, 608, 58 Ill.Dec. 242, 430 N.E.2d 184 (1981) (quoting Wiedemann v. Cunard Line Ltd. , 63 Ill. App. 3d 1023, 1030, 20 Ill.Dec. 723, 380 N.E.2d 932 (1978) ). A count that is legally insufficient cannot serve as the basis for personal jurisdiction.

However, where well-alleged facts within an affidavit are not contradicted by counteraffidavits, they must be taken as true notwithstanding the existence of contrary averments in the adverse party's pleadings. ( Kutner v. DeMassa (1981), 96 Ill. App.3d 243, 421 N.E.2d 231; Central Clearing, Inc. v. Omega Industries, Inc. (1976), 42 Ill. App.3d 1025, 1028, 356 N.E.2d 852, 855.) If a defendant's affidavit contesting jurisdiction is not refuted by a counteraffidavit filed by the plaintiff, the facts alleged in the defendant's affidavit are accepted as true. Kutner v. DeMassa (1981), 96 Ill. App.3d 243, 421 N.E.2d 231; Doolin v. K-S Telegage Co. (1979), 75 Ill. App.3d 25, 29, 393 N.E.2d 556, 559; Wiedemann v. Cunard Line Limited (1978), 63 Ill. App.3d 1023, 1031, 380 N.E.2d 932, 938. Plaintiffs' unverified complaint filed on December 27, 1983, alleged that defendants entered into the Florida agreement with DC, DCI and De Almeida, which provided that De Almeida, on behalf of DC and DCI would write the Accreditation Council in Lake Bluff, Illinois, informing it that seminars sponsored by plaintiffs were erroneously claimed by plaintiffs to have been certified by DC and DCI. The Florida agreement further provided De Almeida would send identical letters to post office officials in Washington and New York (Brooklyn, Rockville Centre, Oceanside) informing them that plaintiffs had used DCI's nonprofit mailing permit.

Id. at 166. See also Wiedemann v. Cunnard Line Ltd., 380 N.E.2d 932, 939 (Ill.App. 1978) ("use of the name `Cunard' by not only defendant Cunard Line Ltd. but also by other subsidiaries of the parent company for advertising purposes . . . does not make Cunard liable for the torts of the other subsidiary") The Dows place great emphasis on representations made on AK International's Internet website — www.abercrombiekent.com.

This is true even if these letters eventually led to a tortious act. See Wiedemann v. Cunard Line Limits, 63 Ill.App.3d 1023, 380 N.E.2d 932, 20 Ill.Dec. 723 (1st Dist.1978) (Illinois traveler injured in West Indies sued tour operator in Illinois). Stansell v. International Fellowship, Inc., 22 Ill.App.3d 959, 318 N.E.2d 149 (1st Dist.1974). (Illinois decedent killed in Peru sued president of association which arranged trip.)