A federal district court in Illinois recently determined that corporate officers could be personally liable for corporate intellectual property infringement: “When corporate officers are in control of the decisions of the corporation at all times…they may be liable for the intellectual property infringements of the corporation.” In this Memorandum Opinion and Order, the court denied the defendants’ motion to dismiss because, among other things, the plaintiff made a sufficient showing that the defendants participated in the corporation’s infringement (at issue was the defendants’ unauthorized use, on their website, of copyrighted text from the plaintiff’s website): “It is at least plausible, taking all the allegations as true, that the [defendants] used the corporation as an instrument to carry out their own willful and deliberate infringements and knowingly used an irresponsible corporation with the purpose of avoiding personal liability…Accordingly, [plaintiff] has sufficiently alleged a level of personal participation in the allegedly infringing activities to survive the [defendants’] 12(b)(6) motion.”