The U.S. District Court for the Northern District of Illinois and the Federal Bar Association Chicago Chapter proudly announce the Courthouse Book Drive.  Donations of new or gently used children’s books (grades K-8) are being accepted for the American Dreams Playroom at the Dirksen Federal Building.  This incredible effort ensures that every child attending a naturalization ceremony receives a book to take home.

New or gently used books will be accepted at the Dirksen Lobby, 219 S. Dearborn Street, Chicago, IL 60610, from June 16, 2026, through July 15, 2026.

Click here for the Courthouse Book Drive Flyer.

Fitch, Even, Tabin & Flannery, LLP v. Dorsey et al., No. 1:25-cv-3141, Slip Op. (N.D. Ill. Feb. 23, 2026) (Coleman, J.).

Judge Coleman granted Defendants’ Fed. R. Civ. P. 12(b)(1) motion to dismiss in this declaratory judgment action where the plaintiff Fitch Even sought a declaration that its former client’s CEO was not a co-inventor of a patent the firm had helped prosecute. The Court found the firm was improperly using a federal patent inventorship correction claim to litigate defenses to a state court legal malpractice action.

Fitch Even had been retained by Prenatal Hope, Inc. (“PNH”) to prepare patent applications for PNH’s “Halo II” medical technology. PNH’s former CTO, James Balman, had independently filed a provisional patent application, and Fitch Even subsequently filed an international application claiming the benefit of that provisional. The resulting U.S. Patent No. 11,622,705 listed Balman as the sole inventor. PNH’s CEO, Tammy Dorsey, was not named as an inventor.

PNH subsequently sued Fitch Even for malpractice in state court, alleging the firm negligently failed to name Dorsey as a co-inventor. After the first malpractice action was dismissed as premature, PNH refiled in 2024. During discovery in that case, Fitch Even asked PNH to identify evidence supporting Dorsey’s inventorship claim; PNH allegedly provided none. Fitch Even then filed the federal declaratory judgment action seeking a ruling that Dorsey was not an inventor.

The Court acknowledged that federal courts have exclusive jurisdiction over Section 256 inventorship correction claims. However, examining Fitch Even’s actual motivation, the Court found the firm explicitly conceded its direct economic interest in declaratory relief was to mitigate potential malpractice damages or vitiate PNH’s negligence claim. The Court held that what Fitch Even sought was a declaration to mitigate damages, not a correction of inventorship.

A party cannot transform a state-law dispute into a federal action by injecting a federal question. The state court malpractice claims, whether the firm failed to follow client instructions, failed to list the proper parties, or failed to obtain an assignment, were rooted in state law.

On Thursday, June 25, 2026, from 3:30 to 5:00 p.m., the Northern District, the Asian American Bar Association, the Federal Bar Association, and the Asian American Judges Association of Illinois will host a reenactment of the historic court proceedings involving Fred Korematsu and his fight against Japanese-American internment.

The in-person program will take place in the Dirksen U.S. Courthouse ceremonial courtroom.  Afterward, guests are invited to attend a reception featuring light refreshments and enjoy the new art exhibit highlighting the history and impact of Japanese American incarceration.

The event is open to the public.  Pending approval attendees will receive 1.0 hour of CLE credit.  Click here to register.

Sueros & Bebidas Rehidratantes, S.A. de C.V. et al. v. Palimex Distributors Inc. et al., No. 1:25-cv-02171, Slip Op. (N.D. Ill. Feb. 24, 2026) (Rowland, J.).

Judge Rowland’s court received an agreed motion for entry of final judgment and permanent injunction in this gray market goods trademark infringement case involving Electrolit branded rehydration beverages.

Plaintiff Sueros, the Mexican owner of the ELECTROLIT trademarks, and CAB Enterprises, the exclusive U.S. licensee, sued Palimex Distributors for importing and selling foreign-manufactured ELECTROLIT products not authorized for the U.S. market (“Unauthorized Electrolit”). The parties stipulated to detailed findings of fact and conclusions of law establishing that the unauthorized products were materially different from the U.S.-authorized version.

The material differences catalogued in the stipulation are extensive:

  1. U.S. Electrolit packaging is in English; Unauthorized Electrolit contains Spanish;
  2. different product formulas;
  3. U.S. products include FDA-compliant Nutrition Facts labeling;
  4. U.S. products list a toll-free customer service number;
  5. U.S. packaging states the product is gluten-free and sweetened with natural glucose;
  6. U.S. packaging uses imperial measurements versus metric;
  7. Unauthorized Electrolit makes health claims not approved by the FDA for U.S. sale;
  8. U.S. products include “USE BY” dates; and
  9. U.S. packaging includes bottle deposit refund information.

The agreed judgment applies the well-established Societe Des Produits Nestle, S.A. standard, which holds that in gray market goods cases, the “threshold of materiality is always quite low” and the existence of any difference that consumers would likely consider relevant when purchasing a product creates a presumption of consumer confusion sufficient to support a Lanham Act claim. The judgment also notes that the Lanham Act is a “strict liability statute” where “ignorance is no defense.”

The permanent injunction broadly restrains Palimex, its affiliates, and those in active concert from purchasing, selling, distributing, importing, or advertising Unauthorized Electrolit, while expressly permitting the lawful sale of genuine U.S. Electrolit products. Plaintiffs’ breach of contract, fraud, and Illinois Consumer Fraud Act claims were dismissed without prejudice.

Shenzhen Langmi Technology Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 25 C 1966, Slip Op. (N.D. Ill. Feb. 26, 2026) (Ellis, J.).

Judge Ellis granted in part and denied in part Defendants’ motion to recover damages on a $10,000 TRO bond in this copyright infringement case involving cosmetic product packaging images. The Court found Defendants were entitled to recover the full $10,000 bond amount but refused to allow recovery in excess of the bond or award attorney’s fees.

Plaintiff Langmi, a Chinese cosmetics company, sued thirty-six Amazon sellers for copyright infringement as Doe defendants, later narrowing the case to eight defendants. After obtaining a TRO requiring a $10,000 bond, Langmi pursued a preliminary injunction but ultimately voluntarily dismissed the case. Defendants then moved to recover damages on the bond.

Applying Coyne-Delany Co., Inc. v. Capital Dev. Bd. of Ill., 717 F.2d 385 (7th Cir. 1983), the Court held that a prevailing defendant is entitled to damages on the injunction bond unless there is good reason not to require payment. Langmi’s voluntary dismissal established that Defendants were wrongfully enjoined, and Langmi offered no reason to deny recovery.

The dispute was over whether Defendants could recover damages exceeding the bond. Defendants argued Langmi acted in bad faith in obtaining the TRO, pointing to (1) allegedly false statements in Langmi’s owner’s declaration about when he licensed certain pre-existing images from a Chinese website, and (2) authorization letters Langmi later obtained during the litigation. The Court rejected both arguments.

Defendants’ alleged false statements were premised on metadata. The Court held that Defendants’ counsel’s own interpretation of website metadata was too speculative to support a bad faith finding, citing cases rejecting attorney analysis of metadata as “misplaced and unsupported speculation.” Defendants also submitted an expert declaration from a graphic designer only in their reply brief, which the Court declined to consider it as procedurally improper. The Court also found the graphic designer’s qualifications insufficient, and so it would not have been substantively considered regardless. The expert claimed “considerable experience” reading webpage metadata but provided no details about the nature of that experience or how it informed his conclusions.

On the authorization letters, the Court found while they were likely obtained after the TRO issued, retroactive ratification of an informal license may be permissible under Second Circuit authority.

Notably, the Court admonished Defendants’ counsel for misrepresenting the record, finding that Defendants repeatedly claimed a website representative said Langmi’s owner visited “recently” to obtain authorization letters, when in fact the representative made no such temporal statement.

Finally, the Court denied Defendants’ request for attorneys’ fees as procedurally improper because it was raised for the first time in reply.

Specialty Publishing Company v. UDA Technologies, Inc., No. 1:25-cv-3873, Slip Op. (N.D. Ill. Jan. 13, 2026) (Coleman, J.).

Judge Coleman granted Defendant UDA Technologies’ Fed. R. Civ. P. 12(b)(2) motion to dismiss for lack of personal jurisdiction in this trademark infringement case involving Plaintiff Specialty Publishing’s CONSTRUCTECH’S TOP PRODUCTS mark. Although the Court found Plaintiff sufficiently alleged that Defendant purposefully availed itself of Illinois through direct evidence of Illinois-based customers, the Court concluded that Specialty Publishing’s alleged injuries did not arise out of or relate to Defendant’s forum-based activities — a critical reminder that purposeful availment alone does not necessarily establish personal jurisdiction.

Specialty Publishing, a multimedia company originally incorporated in Illinois but now headquartered in South Carolina, alleged UDA Technologies — an Alabama-based construction technology company — committed trademark infringement, Lanham Act false advertising and related Illinois claims. The claims centered on UDA Technologies’ alleged continued use of Plaintiff’s mark years after the business relationship ended in 2012, as well as fabricating a quote attributed to Plaintiff’s endorsement.

On purposeful availment, the Court sided with Specialty Publishing. Although UDA Technologies argued its Illinois contacts were minimal, Plaintiff provided direct evidence of Illinois customers and pointed to UDA Technologies’ own website featuring blog entries and customer profiles from nearly a dozen Illinois-based entities. Applying Seventh Circuit authority including Illinois v. Hemi Grp. LLC, 622 F.3d 754 (7th Cir. 2010), and Curry v. Revolution Lab’ys, LLC, 949 F.3d 385 (7th Cir. 2020), the Court concluded Specialty Publishing sufficiently alleged UDA Technologies established minimum contacts through intentional, ongoing commercial relationships with Illinois entities. The Court distinguished be2 LLC v. Ivanov, 642 F.3d 555 (7th Cir. 2011), noting that unlike in be2, where there was no evidence of interaction with Illinois residents, Plaintiff here identified specific Illinois customers with whom Defendant maintained commercial contacts.

Turning to the second prong — whether Specialty Publishing’s injuries arose out of UDA Technologies’ forum-based activities — the Court found a fatal disconnect. UDA Technologies asserted it had never sold or shipped a product bearing the TOP PRODUCTS logo, CONSTRUTECH trademark design, or a fabricated quote to Illinois. None of the accused logos or statements appeared in the profiles of Illinois-based customers identified in Specialty Publishing’s Response. Applying Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir. 2014), the Court held that mere sales to forum-state customers are insufficient to establish personal jurisdiction absent evidence that any Illinois purchaser actually saw the alleged infringing advertising prior to purchase. Because the allegedly infringing conduct — publication of false advertising and unauthorized trademark use — occurred entirely in Alabama where UDA Technologies created and maintained its website, the injury did not arise from UDA Technologies’ Illinois-directed activities.

On Thursday, May 28, 2026 from 1:00 p.m. to 4:00 p.m. the P. Michael Mahoney Chapter of the Federal Bar Association will host a complimentary CLE program titled “AI for Attorneys: Risks & Rewards”. 

The program will address opportunities and risks artificial intelligence presents to the legal profession. Panelists include:

  • Maura R. Grossman, Research Professor at the University of Waterloo, Adjunct Professor of Law at York University, and Principal of Maura Grossman Law;
  • Phil Favro, Founder and President of Favro Law PLLC; and
  • Honorable Michael F. Iasparro, U.S. Magistrate Judge for the Northern District of Illinois.

The presentation will take place in-person at the Stanley J. Roszkowski United States Courthouse, with a Teams option available for remote attendees. There is no cost to attend, and advance registration is required. Click here to register.

Pending approval, 3 hours of continued legal education are being offered.

BCD Technology Holdings, LLC et al. v. Paragon Micro, Inc. et al., No. 25 CV 6944, Slip Op. (N.D. Ill. Jan. 9, 2026) (Jenkins, J.).

Judge Jenkins issued an order setting the framework for an evidentiary hearing on Plaintiffs’ preliminary injunction motion in this Defend Trade Secret Act and non-competition case. The Court gave 3.25 to 3.5 hours per side providing guidelines for the amount of time for each witness’s direct and cross exam.

The Court also gave each party 25 minutes for argument after the witness testimony, and identified specific legal and factual issues the parties should address during argument. Those issues included:

  1. the basis for plaintiff’s standing;
  2. identification of the specific confidential information each individual defendant allegedly misappropriated;
  3. the current state of damages and anticipated future irreparable harm from continued misappropriation;
  4. damages stemming from conduct other than trade secret misappropriation; and
  5. the effect of the Seventh Circuit’s LKQ Corp. v. Rutledge, 96 F.4th 977 (7th Cir. 2024) decision on Plaintiffs’ non-competition agreement claims.

For plaintiffs seeking preliminary injunctions in trade secret cases, this order underscores the importance of being prepared to establish standing on a granular, claim-by-claim level. The Court’s emphasis on distinguishing damages from trade secret misappropriation versus other types of competitive harm suggests that overbroad injunction requests untethered to specific secrets will face skepticism. The Court’s structured, time-limited approach to the evidentiary hearing is an interesting, hands-on approach that is fairly unique, but I wonder if other judges will start to adopt the approach.

Hong Kong Leyuzhen Technology Co. Ltd. v. Floerns, No. 1:24-cv-02939 (N.D. Ill. Dec. 31, 2025) (Kennelly, J.).

Judge Kennelly denied plaintiff’s Fed. R. Civ. P. 59(e) motion to reconsider an earlier summary judgment order that disposed of plaintiff’s copyright, Lanham Act, and state-law claims, emphasizing diligence and record consistency in post-judgment practice in this copyright dispute.

The Court previously held that no reasonable factfinder could find valid ownership of the photos at issue because plaintiff lacked the required written agreement for “work made for hire,” overcoming the registration presumption.

Plaintiff sought reconsideration with “newly discovered” evidence, including a declaration and a late-executed assignment. The Court held Rule 59(e) relief was unavailable because the evidence was discoverable with reasonable diligence before judgment and, in any event, the post-judgment assignment did not exist at the time of the ruling. The Court also noted plaintiff did not pursue Fed. R. Civ. P. 56(d) relief when ownership was squarely raised at summary judgment and highlighted inconsistencies between the new story and earlier interrogatory responses and briefing, which had described third-party studio photography and paid work outside the asserted employment structure.

Seasonal Specialties, LLC v. Holiday Designs, LLC, No. 1:23-cv-14008 (N.D. Ill. Dec. 22, 2025) (Kness, J.).

Judge Kness ruled on claim construction in a patent dispute over pre-lit Christmas tree lighting making clear the Court’s preference for plain and ordinary meaning where the intrinsic record resolved the parties’ disagreements without requiring any constructions. Applying Phillips and O2 Micro, the Court held no further construction was necessary for six disputed terms across two patents, including “an illumination element,” “a first switching circuit … a second switching circuit,” and “special lighting effect.” The court also rejected an indefiniteness challenge to “blinking” and “twinkling,” finding the Nautilus standard satisfied because a person of ordinary skill, informed by the claims and specification, would understand the scope with reasonable certainty. Of particular note, the Court held as follows:

  • Illumination Element – The Court concluded that the claim language itself—particularly the use of “said illumination element” in functional limitations—already required at least one element capable of performing all recited functions, rendering a reworded construction unnecessary.
  • First and Second Switching Circuits – The separation of first and second switching circuits coupled with their distinct roles as described in the claims and specification, made clear that two distinct circuits are required, even if implemented on the same board or package. And because the claims already delineate the transition from an initial steady-on state to “special lighting effects,” any further paraphrasing risked confusing rather than clarifying the jury.

The Court cited Vivid Techs. to avoid “an obligatory exercise in redundancy” and declined to add narrowing language absent lexicography or clear disavowal (Thorner). The Court also treated “blinking” and “twinkling” as examples of lighting sequences described in the specification, rejecting a § 112(b) indefiniteness argument for lack of “objective boundaries” where the intrinsic record adequately cabins meaning under Nautilus.