Semisilicon Technology Corp. v. Changzhou Jutai Electronic Co., Ltd., et al., No. 25 C 7388, (N.D. Ill. June 11, 2026) (Kendall, C.J.).

Chief Judge Kendall denied plaintiff Semisilicon’s motion for a preliminary injunction and its motion for alternative electronic service, and dismissed defendant Jutai for lack of personal jurisdiction, in this patent infringement action involving LED string lights sold on Amazon. Semisilicon, a Taiwanese patent-licensing entity, asserted two patents against five Chinese defendants—four “Amazon Defendants” that sold finished products through Amazon storefronts, and Jutai, a component manufacturer that does not sell directly to consumers.

Of particular interest, the Court held:

  • Personal Jurisdiction Waiver: The four Amazon Defendants each stated in their Answers that they “denied the allegations…except that for purposes of this action only, Defendant does not contest that this Court has personal jurisdiction.” None raised lack of personal jurisdiction as an affirmative defense. The Court held this constituted an express waiver under Fed. R. Civ. P. 12(h)(1), finding that “no amount of zeal can turn this into a straight-faced” denial of jurisdiction.
  • No Jurisdiction Over Component Manufacturer: Jutai, by contrast, expressly denied personal jurisdiction and raised it as an affirmative defense. The Court analyzed Fed. R. Civ. P. 4(k)(2) and the stream-of-commerce doctrine under both the Brennan and O’Connor formulations from Asahi Metal Industry Co. v. Superior Court. Because Semisilicon offered no evidence that Jutai’s products were sold or available in Illinois, products listing Jutai as manufacturer were “currently unavailable” on Amazon, and Jutai’s unrebutted declaration denied any Illinois contacts, the Court dismissed Jutai for lack of personal jurisdiction.
  • Preliminary Injunction Denied on the Merits: Even with jurisdiction established over the Amazon Defendants via waiver, the Court denied a preliminary injunction because Semisilicon’s infringement showing was “facially deficient.” Semisilicon relied solely on Amazon screenshots and a 2024 cease-and-desist letter sent only to Jutai that analyzed only one of three accused products against only one of two asserted patents, with no claim charts for the remaining products or patent. The Amazon Defendants submitted an unrebutted expert declaration raising substantial questions of non-infringement on both patents, including the absence of a “predetermined voltage” limitation and an address-data comparison limitation. Because a substantial question of non-infringement was raised and unrebutted, the PI could not issue.
  • Delay Undermines Irreparable Harm: Semisilicon waited approximately ten months from its cease-and-desist letter to seek a PI, and its only harm evidence was a boilerplate declaration with no specific damages figures. The Court found this delay undermined the PI.
  • Electronic Service Violates Hague Convention: The Court denied Semisilicon’s motion for alternative electronic service, holding that service by email in China violates the Hague Service Convention and Fed. R. Civ. P. 4(f)(3), regardless of defendants’ litigation conduct or “waiver” arguments—a party cannot waive an international treaty’s exclusive service methods. However, because the Amazon Defendants had already appeared and litigated without preserving an objection to service, their appearance was as effective as actual service under Rule 12(h)(1).

Juncheng Kao v. Hengda Kite, No. 25 C 8491, (N.D. Ill. May 26, 2026) (Alonso, J.).

Judge Alonso denied defendant’s Fed. R. Civ. P. 12(b)(6) motion to dismiss in this design patent infringement case involving a kite. The Court applied Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008) (the ordinary observer test), which asks whether an ordinary observer familiar with the prior art would be deceived into thinking the accused design is the same as the patented design. The Court held that the complaint, which included a side-by-side comparison of the patent drawings and photographs of defendant’s kite, along with an allegation that the products were “materially identical,” was sufficient to plausibly allege design patent infringement and to give defendant fair notice of the accused activity. The Court rejected defendant’s argument that detailed written descriptions of how each design element infringes are required, holding that such specificity is not necessary at the pleading stage. The parties were ordered to submit a joint status report and address settlement.

Chrome Hearts LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 26 C 497, (N.D. Ill. May 18, 2026) (Kendall, C.J.).

Chief Judge Kendall, in this Schedule A trademark and copyright action against 92 e-commerce defendants, granted six defendants’ motion to sever for improper joinder. The Moving Defendants submitted a declaration from their common owner denying any relationship, communication, or coordination with the other defaulted defendants. Under Fed. R. Civ. P. 20(a)(2), permissive joinder requires that claims arise from the “same transaction, occurrence, or series of transactions” and share a common question of law or fact. The Court emphasized that this standard requires a “logical relationship” based on shared, overlapping facts, not merely similar but coincidental conduct. The Court found that Chrome Hearts failed to allege any actual coordination or overlapping facts connecting the Moving Defendants to the other sellers beyond independently selling similar counterfeit goods. The Court ordered the six defendants severed into a new, separate case and directed Chrome Hearts to file an amended complaint in that action.

Mobile Motherboard Inc. v. AIOEXPC, ALADAWN, and AKLWY, No. 24 CV 8703, (N.D. Ill. May 29, 2026) (Shah, J.).

Judge Shah denied plaintiff’s Fed. R. Civ. P. 59(e) & 60(b) motion to alter or amend the judgment and for leave to amend in this patent infringement case related to a two-part computer system comprising a “computer box” and a separate, external, handheld “motherboard” that connects to it. The Court had previously granted judgment on the pleadings for defendants, Chinese companies selling handheld “computer sticks.” The Court found no manifest error warranting the extraordinary relief available under Rule 59(e). Plaintiff’s own claim charts demonstrated that defendants’ computer sticks satisfied both the “computer box” limitations (housing, internal circuitry, communication ports, internal bus) and nearly all the “motherboard” limitations in a single integrated product. This was fundamentally inconsistent with the patent’s requirement of two physically separate components. Because the accused products cannot simultaneously be both the external motherboard and the computer box under the patent’s own claim language, plaintiff had pleaded itself out of court.

The Court denied leave to amend as futile because the same claim-chart specifications would still show the integrated single-device design.

GZ Long Ya Trading Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule “A” (Defendant Tonchean), No. 24-cv-4193, (N.D. Ill. May 29, 2026) (Holleb Hotaling, Mag. J.).

Magistrate Judge Holleb Hotaling, after granting summary judgment and a permanent injunction for plaintiff in this design patent case regarding a puzzle table, addressed damages under 35 U.S.C. § 289. Under the framework established by Samsung Electronics Co. v. Apple, Inc., 137 S. Ct. 429 (2016), the Court first identified the “article of manufacture” to which the infringed design was applied and then calculated the infringer’s total profit on that article. Plaintiff identified the infringing puzzle tables themselves as the article of manufacture and demonstrated through Wayfair sales data that defendant Tonchean sold at least 402 infringing units generating at least $55,300 in net revenue. The burden then shifted to defendant to identify an alternative article of manufacture or substantiate deductible costs, citing WMS Gaming, Inc. v. WPC Prods. Ltd., 542 F.3d 601 (7th Cir. 2008), and Mishawaka Rubber & Woolen Mfg. Co. v. S.S. Kresge Co., 316 U.S. 203 (1942). Defendant never contested the article of manufacture, proposed an alternative article, or documented any deductible costs—offering only an unverified claimed per-unit cost without supporting documentation. The Court found defendant waived the argument, citing Bonte v. U.S. Bank, N.A., 624 F.3d 461 (7th Cir. 2010), and awarded $55,300 in damages.

Blue Spring Partners, LLC v. The Individuals, Corporations, LLCs, Partnerships, and Unincorporated Associations Identified on Schedule A, No. 23 C 983, (N.D. Ill. May 18, 2026) (Kendall, C.J.).

Chief Judge Kendall denied a non-party’s motion to intervene and for relief from judgment under Fed. R. Civ. P. 60(b) in this trademark and copyright Schedule A case involving swimmable mermaid tails allegedly sold by over 177 e-commerce defendants. The case had been terminated following entry of default judgment more than a year and a half before movant Shenzhenshi Hengzhiyi E-Commerce Co., Ltd. filed its motions.

On intervention, the Court held that motions to intervene after a case has ended are almost always denied as untimely absent unusual circumstances, citing Humphrey v. Sheriff and CE Design Ltd. v. King Supply Co., 791 F.3d 722 (7th Cir. 2015). One cannot intervene in a dismissed case. On the Rule 60(b) motion, the Court held that relief under Rule 60(b)(1) was barred outright because it was filed more than one year after judgment. Even construing the motion under Rule 60(b)(5) or (6), which require filing within a “reasonable time,” the approximately eighteen-month delay was unreasonable given movant’s unconvincing excuses for not learning of the default order sooner. The Court emphasized that Rule 60(b) is not a license to sleep on rights.” Lobrow v. Vill. of Port Barrington, 406 F. App’x 60 (7th Cir. 2010).

Bright Hand LLC v. Shenzhen Aoya Kuajing Dianzi Shangwu Youxiangongsi d/b/a Mylivell, No. 1:25-cv-11700, (N.D. Ill. May 26, 2026) (Coleman, J.).

Judge Coleman, in this patent infringement action involving an LED “flashlight glove” granted defendant’s Fed. R. Civ. P. 12(b)(6) motion to dismiss plaintiff’s Lanham Act unfair competition claim. Plaintiff’s complaint asserted both false association and false advertising. Defendant argued these were improper attempts to repackage the patent infringement claim as a Lanham Act violation. The Court agreed, finding that plaintiff never alleged the use of its marks, passing off, false designation of origin, or any specific false or misleading statement. The complaint merely alleged that defendant made and sold an infringing product, which does not state a cognizable Lanham Act claim. Relying heavily on Dastar Corp. v. Twentieth Century Fox Film Corp., 539 U.S. 23 (2003), the Court held that the Lanham Act cannot be used to backdoor patent-type claims absent a source-identifying mark or an affirmative misleading statement. Count I, the patent infringement claim, survived the motion.

Hublot SA v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 26 C 4668, (N.D. Ill. May 18, 2026) (Kendall, C.J.).

Chief Judge Kendall, in this Schedule A case, dismissed plaintiff Hublot’s complaint without prejudice for lack of personal jurisdiction pursuant to Fed. R. Civ. P. 12(b)(2). The Court had previously denied Hublot’s ex parte TRO motion based on the Seventh Circuit’s decision in Liu v. Monthly, 170 F.4th 1090 (7th Cir. 2026), and afforded Hublot an opportunity to supplement its jurisdictional showing. Hublot’s supplemental filing relied only on vague assertions of interactive communications, transaction-oriented conduct, and willingness to ship, without any evidence of a completed sale into Illinois. The Court held that under Liu and Curry v. Revolution Labs., 949 F.3d 385 (7th Cir. 2020), operating an interactive website accessible in Illinois is insufficient to establish specific personal jurisdiction. A plaintiff must demonstrate at least one completed sale into the forum state. The Court granted Hublot leave to amend within two weeks to demonstrate jurisdiction or face dismissal with prejudice and unsealing of the record.

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.