whether the Maunder analysis is distinct from the equitable device of piercing the corporate veil.
See, e.g., Central States, 230 F.3d at 940; IDS Life Insurance Co. v. SunAmerican Life Insurance
Co., 136 F.3d 537, 540 (7th Cir. 1998). Indeed, United States Gypsum blurs the distinction
between alter ego theory and Maunder. United States Gypsum, 508 F. Supp. 2d at 643; see also
FAIP North America, Inc. v. Sistema S.R.L., No. 05 C 4002, slip op. at 4 (N.D. Ill. December 14,
2005). But see Gruca v. Alpha Therapeutic Corp., 19 F. Supp. 2d 862, 866 (N.D. Ill. 1998)
(recognizing the distinction and explaining that “Illinois courts appear to use two approaches in
examining whether the activities of the subsidiary give rise to jurisdiction over the parent”).
The decisions of our state courts make clear that piercing the corporate veil is a distinct
analysis from the Maunder agency theory of jurisdiction. Notably, in Maunder, the supreme
court declined to engage in an alter ego analysis after it found jurisdiction based on the agency
theory, implying that these are two distinct means of establishing personal jurisdiction in Illinois.
Maunder, 102 Ill. 2d at 354, 466 N.E.2d at 223. That alter ego theory is distinct from Maunder
was also implied in Alderson, in which we explained that blurring of separate corporate identities
was not dispositive but, rather, separate corporate formalities may be observed and jurisdiction
may nevertheless be obtained over the parent if the subsidiary is functioning as the parent’s
agent. Alderson, 321 Ill. App. 3d at 854, 747 N.E.2d at 944. Thus, Old Orchard is not relieved
of its burden to establish that fraud or injustice before we may pierce the corporate veil.
To that end, Old Orchard knew that it would have no recourse against Harry Rosen in the
event SSIOO defaulted on its obligations under the lease. Although Old Orchard initially
requested that Harry Rosen guaranty SSIOO’s lease, Old Orchard ultimately agreed to a guaranty
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