GZ Long Ya Trading Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 24-cv-4193, (N.D. Ill. Apr. 24, 2026) (Holleb Hotaling, Mag. J.).

Magistrate Judge Holleb Hotaling granted plaintiff GZ Long Ya Trading’s motion for summary judgment and permanent injunctive relief against the remaining Schedule A defendant Tonchean, denied plaintiff’s request for attorneys’ fees, and ordered supplemental briefing on damages in this design patent infringement case involving U.S. Design Patent No. D986,339, directed to an ornamental design for a puzzle table.

Of particular interest, the Court held:

  • Defendant failed to properly dispute plaintiff’s Local Rule 56.1 statement of undisputed material facts. Although Defendant filed a response, it failed to cite specific evidentiary material controverting the asserted facts, merely stating certain facts were disputed because “the licensee has a different name from that of the Plaintiff” or that certain evidence was “self-serving.” All properly supported facts were therefore deemed admitted.
  • The Court rejected Defendant’s standing challenge based on the difference between “GZ Long Ya Trading Co., Ltd.” and the assignment’s reference to “Guangzhou LongYa Trading Co. Ltd.” The Court found “GZ” is a common abbreviation for “Guangzhou,” and the inventor’s sworn declaration confirmed the assignment to plaintiff. Plaintiff had standing as sole assignee.
  • The ’339 Patent was valid despite containing functional features. The Court held that the existence of functional elements does not itself invalidate a design patent; rather, the claimed design must be viewed in its entirety. The shape of the tabletop, symmetrically arranged drawers, side placement of drawers, leg shape, and connecting bar placement were all ornamental features entitled to protection. Defendant conceded alternative designs exist, further supporting validity.
  • Infringement was established both by deemed admissions (Defendant served discovery responses more than three months late) and, independently, under the ordinary observer test. The Court’s side-by-side comparison found the accused Wayfair puzzle tables were substantially similar to the patented design, with the only identified difference being two additional drawers beneath the top flipped table.
  • The Court granted permanent injunctive relief, applying the same irreparable-harm findings that supported the earlier preliminary injunction: diminished goodwill, damage to reputation, loss of exclusivity, and loss of future sales.
  • The Court denied attorneys’ fees under 35 U.S.C. § 285 because plaintiff had not shown the case was exceptional, notwithstanding Defendant’s late discovery responses and Local Rule noncompliance.
  • The Court requested supplemental briefing on whether plaintiff seeks more than $55,300 in damages and the basis for any additional amount.

Anderson Design Group, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 25-cv-11640, (N.D. Ill. Apr. 24, 2026) (Rowland, J.).

Judge Rowland held in abeyance the Group A Defendants’ motion to dismiss for misjoinder under Fed. R. Civ. P. 20(a)(2) and granted plaintiff Anderson Design Group 60 days of limited expedited discovery to probe relationships among the remaining Schedule A defendants in this copyright infringement Schedule A case.

The Group A Defendants, the only remaining defendants, moved to dismiss for improper joinder, arguing they are unrelated and unaffiliated. While acknowledging that joint representation alone does not automatically imply coordination, the Court found the scale difficult to ignore. By the Court’s count, counsel for the Group A Defendants represents roughly 290 Schedule A defendants across this case and ten other Northern District cases. Nearly identical misjoinder motions had been filed in at least eight of those cases.

The Court also pointed to counsel’s admission in a related case before Judge Durkin that he communicates with a “single representative” for all Schedule A defendants in that matter. Though no such admission was made in this case, when considered alongside the lockstep conduct across cases, the Court found those circumstances suggested central coordination inconsistent with defendants’ claim that they are unaffiliated.

The Court granted 60 days of limited expedited discovery and required the parties to submit a joint status report by May 1, 2026 with agreed-upon dates and discovery parameters.

On Thursday, September 17, 2026, from 3:00 p.m. – 4:00 p.m. CT, the Federal Bar Association Chicago Chapter and the United States District Court for the Northern District of Illinois will present Celebrating Hispanic Contributions to the Law, a complimentary CLE program honoring Hispanic Heritage Month.

The in-person event will be held in the Ceremonial Courtroom of the Everett McKinley Dirksen United States Courthouse, 219 S. Dearborn Street, Chicago, IL 60604. The program offers 1 hour of Professional Responsibility/DEI CLE credit, pending approval, and attendees are invited to a reception immediately following the program.

Highlights of the program include:

  • Hon. Rubén Castillo, Former U.S. District Chief Judge, Northern District of Illinois
  • Hon. Sonia Antolec, Judge, Illinois Court of Claims
  • Hon. Alfredo Maldonado, Associate Judge, Circuit Court of Cook County
  • Susana A. Sandoval Vargas, Midwest Regional Counsel, Mexican American Legal Defense and Educational Fund

Click here to register.

AbbVie Inc. v. BeiGene, LTD., et al., No. 24-cv-8167, (N.D. Ill. May 12, 2026) (Cummings, J.).

Judge Cummings denied defendants’ Fed. R. Civ. P. 12(b)(6) motion to dismiss AbbVie’s Defend Trade Secrets Act claim. AbbVie alleges that BeiGene lured former AbbVie Senior Research Scientist Dr. Huaqing Liu out of retirement to serve as Executive Director of BeiGene’s Department of Chemistry in order to gain access to AbbVie’s BTK degrader trade secrets. AbbVie further alleges that BeiGene then used those secrets to dramatically change the course of its own BTK degrader development, filing at least six patent applications containing designs that closely resembled or exactly replicated AbbVie’s trade secret designs.

Defendants raised four arguments:

  1. AbbVie failed to allege Liu took any tangible information;
  2. AbbVie did not plead protective measures specific to the BTK program;
  3. AbbVie failed to plausibly allege BeiGene’s patent applications were derived from AbbVie; and
  4. the Complaint failed to adequately specify the alleged trade secrets.

The Court rejected each argument. Of particular interest, the Court held:

  • AbbVie only needs to plausibly plead misappropriation of a single trade secret to survive a motion to dismiss. A Rule 12(b)(6) motion does not permit piecemeal dismissals of parts of claims, chipping away at claims is the role of summary judgment.
  • Combinations of publicly available components can still qualify as trade secrets where the unique combination affords a competitive advantage.
  • The Seventh Circuit requires only that protective measures be “reasonable,” and it is “immaterial” that AbbVie applies the same confidentiality policy to other information. AbbVie need not necessarily show a heightened protection program for the specific trade secrets at issue.
  • Trade secrets can exist in employees’ memories. A trade secret plaintiff does not need to show that an actual document was taken.
  • Circumstantial evidence, including suspicious timing between Liu’s departure and BeiGene’s filing of patent applications containing AbbVie’s designs, is sufficient to support misappropriation allegations at the pleading stage.
  • Claims under the DTSA are not subject to a heightened pleading standard. At the pleading stage, plaintiffs can plead specificity “in broad strokes.”

The motion to dismiss was denied in its entirety.

Chicago Cubs Baseball Club, LLC v. Dunican and Rooftop by the Firehouse, Inc. d/b/a Wrigley View Rooftop, No. 24-cv-05086, (N.D. Ill. May 1, 2026) (Coleman, J.).

Judge Coleman denied defendants’ Fed. R. Civ. P. 12(c) motion for judgment on the pleadings as to the Cubs’ Lanham Act misappropriation and unjust enrichment claims.

The Cubs alleged that defendants sold tickets to view Cubs games from their rooftop across the street from Wrigley Field after the Cubs informed defendants that their license to sell such tickets would not be renewed for the 2024 season. Despite that notice, defendants listed the Cubs’ schedule on their website and sold tickets to access the rooftop, even selling out on several dates.

Defendants argued that the Cubs do not possess a property right in the experience of live games and that defendants are entitled to profit from the views around their own rooftop. The Court disagreed, relying on Pittsburgh Athletic Co. v. KQV Broad. Co. and Right Field Rooftops, LLC v. Chicago Baseball Holdings, LLC to recognize a property right in profits from live games. The Court held that the Cubs plausibly alleged misappropriation: (1) the Cubs created a product through substantial investment approaching a billion dollars annually; (2) defendants used that product in competition with the Cubs for their own commercial benefit without bearing any of the production costs; and (3) the Cubs alleged commercial damage in the form of lost revenue from ticket sales, concessions, and merchandise.

The unjust enrichment claim likewise survived because it “stand[s] . . . with the related claim” of misappropriation. The Court also noted that defendants’ own Answer raised disputes of material fact—by denying facts essential to the Cubs’ claims and asserting facts of their own—which independently precluded judgment on the pleadings.

McLellan v. Google LLC, No. 25 C 12761, (N.D. Ill. May 4, 2026) (Kennelly, J.).

Judge Kennelly granted Google’s motion to transfer this patent infringement case to the Northern District of California pursuant to 28 U.S.C. § 1404(a) and left Google’s motion to dismiss for the transferee court.

Plaintiff McLellan alleged that Google’s search engine infringed his patent on an algorithm for ranking search results based on the frequency that websites’ “promoters” perform twenty-eight “defined actions,” such as logging into or creating an account. McLellan resides in Delaware and had no meaningful ties to the Northern District of Illinois, weakening the deference normally given to a plaintiff’s choice of forum.

Google identified six employee witnesses with the alleged most relevant knowledge, five of whom are based at Google’s headquarters in the Northern District of California. Google also identified three former Yahoo! employees who could be witnesses on validity issues and who appear to reside in the Northern District of California. Physical evidence, including two servers, an original Yahoo! prior-art device, and a Google prototype, were also located there. No comparable witnesses, prior-art systems, documentation, or evidence were identified in Illinois.

McLellan argued that party-employee witnesses would appear voluntarily and that video testimony was available for others. The Court acknowledged these points but held they did not erase the importance of witness location. The Court noted that the non-party Yahoo! witnesses could not be compelled to travel to Illinois and that live testimony remains significantly preferable to video.

The Court gave limited weight to docket-congestion statistics, viewing the time-to-trial comparison as anecdotal based upon the small sample size. In the final analysis, the Court concluded that this case had no connection to the Northern District other than McLellan’s decision to file here despite it not being his home venue. The Northern District of California was clearly more convenient, with better access to witnesses and evidence.

On August 27, 2026 from 2:00 p.m. – 5:00 p.m. CT, the Chicago Chapter of the Federal Bar Association and the Seventh Circuit Bar Association Pro Bono & Public Service Committee will host a free CLE event focused on effective settlement advocacy for pro se matters. The program will be held at the U.S. District Court for the Northern District of Illinois, 219 South Dearborn Street, Courtroom 2525.

Topics will include:

SAP Matters: Overview and the Volunteer Experience: Presented by J. Cunyon Gordon, Settlement Assistance Program Director, Chicago Lawyers’ Committee for Civil Rights, and Rami Fakhouri of Goldman Ismail Tomaselli Brennan & Baum LLP.

Listening Differently: Client Communication Strategies: Presented by Jim Alrutz of the Center for Conflict Resolution.

Strategies and Pitfalls: Lessons from the Bench: Moderated by Margot Klein of Ogletree Deakins and presented by a panel of federal magistrate judges:

  • Judge Jeannice Appenteng;
  • Judge Albert Berry III; and
  • Judge Laura K. McNally.

Attendees will receive 3 hours of general CLE credit pending approval and become eligible to participate in the Pro Se Litigants Settlement Assistance Program (SAP). Registration is free, but space is limited. To register, contact Debbie Groboski at admin@7thcircuitbar.org.

On October 6, 2026, the Federal Circuit Bar Association will present its 2026 Bench & Bar® in Dialogue – Chicago CLE program at the University Club of Chicago, 76 E. Monroe Street, Chicago, IL 60603.  The CLE program aligns with the U.S. Court of Appeals for the Federal Circuit’s Court Week in Chicago.  The program will feature judges from the Federal Circuit, the U.S. Court of Appeals for the Seventh Circuit and the U.S. District Court for the Northern District of Illinois, as well as members of the legal and academic communities. I will also be speaking on Panel Two about Schedule A cases.

The event will begin with registration from 12:45 p.m. to 1:15 p.m., followed by programming from 1:15 p.m. to 6:00 p.m. A reception will follow from 6:00 p.m. to 7:00 p.m., with dinner from 7:00 p.m. to 9:00 p.m.  Click here to register.

The Agenda is below:

12:45 PM – 1:15 PM   Registration

1:15 PM – 1:20 PM     Welcome Remarks

1:20 PM – 2:05 PM    Panel One: Pleading Standards Post Hikma v. Amarin

2:05 PM – 3:10 PM    Panel Two: Chicago’s Role in Enforcing Patents Against Online Infringers

3:10 PM – 3:30 PM    Networking Break

3:30 PM – 4:15 PM    Panel Three: Review of Recent Federal Circuit Remedies Decisions and Their Implications

4:15 PM – 5:15 PM    Panel Four: Federal Circuit Judicial Panel

5:15 PM – 5:25 PM    Chief Judge Moore’s Federal Circuit Community Outreach Update

5:30 PM – 6:00 PM    Panel Five: Fireside Chat with the Chiefs

6:00 PM – 7:00 PM    Reception

7:00 PM – 9:00 PM    Dinner

Sagent Pharmaceuticals v. Farco USA, LLC, et al., No. 25 C 14080, (N.D. Ill. May 5, 2026) (Kocoras, J.).

Judge Kocoras granted in part and denied in part defendants’ partial Fed. R. Civ. P. 12(b)(6) motion to dismiss in this Defend Trade Secrets Act, Illinois trade secret, and breach of contract action. Sagent alleged that three former employees conspired with German pharmaceutical manufacturer FARCO-PHARMA to replace Sagent as the exclusive U.S. distributor for GLYDO, a lidocaine jelly product, by forming defendant Farco USA.

The Court held that direct evidence of trade secret misappropriation is rare, and that Sagent’s allegations plausibly pled misappropriation as to Szurgot and Blasik, including:

  • that Szurgot surreptitiously renamed confidential term sheet documents and sent them to his personal email;
  • that Blasik emailed over 1,500 hospital division contacts to his personal email and downloaded confidential files to a personal USB drive;
  • that both lied to Sagent investigators; and
  • that Szurgot disclosed Sagent’s privileged negotiation strategy to FARCO-PHARMA.

The Court held that these allegations were not sufficient to state a direct misappropriation claim against Jensen, who served as Vice President of Finance and did not personally take or forward documents. However, the Court found that Sagent plausibly pled inevitable disclosure as to all three individual defendants. The Court noted that Farco USA was created to compete in the same national market Defendants oversaw at Sagent, that Defendants are poised to hold similar positions there, that none had experience in urology products before joining Sagent, and that Defendants had taken no steps to prevent use of Sagent’s trade secrets.

The Court also held that defendants’ request to strike injunctive relief was premature.

The tortious interference with contract and tortious interference with prospective economic advantage claims were dismissed without prejudice because Sagent failed to allege an actual breach of contract or adequately allege damages. Claims against Jensen for breach of fiduciary duty, unfair competition, civil conspiracy, breach of contract, and unjust enrichment survived.

On Thursday, August 13, 2026, at 12:00 p.m. Central, volunteer attorneys are invited to attend a Zoom orientation to learn more about the Hibbler Help Desk, a free resource for pro se litigants with cases in the Northern District of Illinois.

The Uptown People’s Law Center (“UPLC”) coordinates the Hibbler Help Desk – a free, virtual resource designed to assist pro se litigants navigate federal court – for the Northern District of Illinois.

Volunteers provide unrepresented litigants practical guidance on procedures and rules as their case proceeds through the Northern District.  The Hibbler Help Desk requires no specific subject matter expertise beyond some federal practice experience and independent malpractice insurance. It is also entirely virtual. 

If you are interested in this great opportunity or would like to learn more, please join the orientation via Zoom:

https://us02web.zoom.us/meeting/register/mHkHASXnS86wp36Hv41A1w