Tri-Plex Technical Services, Ltd. v. Jon-Don, LLC

Summary

The Illinois Supreme Court reversed the appellate court and affirmed the circuit court’s dismissal of Tri‑Plex’s claims under the Deceptive Trade Practices Act, the Consumer Fraud Act, and a civil conspiracy claim, holding that the plaintiff failed to exhaust administrative remedies and did not plead the required proximate‑cause element. The court also overruled prior appellate decisions that applied a “consumer nexus” test to business plaintiffs.