Natsoft Corporation and Updraft, LLC v. Hexaware Technologies Limited, et al.., No. 25 CV 11517, (N.D. Ill. June 9, 2026) (Shah, J.).

Judge Shah granted defendant Hexaware’s Fed. R. Civ. P. 12(b)(6) motion to dismiss, holding all nine asserted patents ineligible under 35 U.S.C. § 101 and the Alice Corp. v. CLS Bank International framework, in this action brought by Natsoft and Updraft, affiliated companies that together developed tools for automated extraction of software “business rules,” automated testing, and automated modernization of legacy software (at a claimed cost exceeding $100 million over five to six years of development). Hexaware competes with products called Amaze, RapidX, and Tensai that use generative AI for similar modernization services. The complaint also alleged state-law claims for breach of contract, unjust enrichment, and intentional interference arising from a proof-of-concept relationship that broke down between the parties.

Of particular interest, the Court held:

  • First Family (Seven Patents), Alice Step One: The patents automate the traditional four-step software development process (requirements, architecture, design, code generation) that previously involved manual steps prone to error. The Court found that automating mental or manual processes is a “quintessential ‘do it on a computer’” abstract idea. Plaintiffs failed to articulate what distinguished their technique from a computer’s ordinary capabilities, despite a 66-page specification with 61 figures.
  • First Family, Alice Step Two: The Court found no inventive concept. Plaintiffs’ “verification tools” and “verification feedback” were not described with enough specificity to be more than a “result-oriented” black box,. The Court noted that efficiency gains do not make an abstract idea less abstract.
  • Second Family (Two Patents): The Court also held these patents to be “do it on a computer” inventions, claiming a “method for execution by a computing device” that analyzes, groups, tests, and reprograms code. At step two, the claimed ability to generate “meaningfulness” feedback was not inventive because the specification never defined “meaningfulness” or the threshold for triggering an adjustment. It was the kind of process that can be performed in the human mind.
  • State-Law Claims Dismissed Without Prejudice: With all patent claims dismissed as ineligible, the Court declined to exercise supplemental jurisdiction over the remaining state-law claims (breach of contract, unjust enrichment, tortious interference) and dismissed them without prejudice. Patent claims were dismissed with prejudice as incurable, but plaintiffs were given until June 24, 2026 to file an amended complaint limited to a new Defend Trade Secrets Act claim plus the state-law claims.

On Wednesday, November 4, 2026, from 11:30 a.m. to 1:00 p.m., the Federal Bar Association Chicago Chapter will present “Artificial Intelligence at Work: Corporate Policies, Legal Risks & the Role of In-House Counsel.” Kirkland & Ellis LLP is sponsoring and hosting the program at 333 West Wolf Point Plaza, Chicago.

The moderated panel will explore how corporations, law firms, and courts use and manage AI, with practical examples of its applications, governing policies, and shortcomings. Topics will include confidentiality, privilege, data security, supervision, and professional responsibility.

Program speakers include:

  • Hon. Andrea R. Wood, U.S. District Judge, Northern District of Illinois (Moderator)
  • Mark Schneider, Partner, Kirkland & Ellis LLP
  • Aaron Weinzierl, Senior Managing Counsel, IP, Transactions, and AI, United Airlines
  • Angela Crawford, Founder, Crawford & Associates PLLC
  • Kristofer Swanson, Executive Director, Global Investigations & Dispute Resolution, Hilco Global

The program is open to FBA members and nonmembers, and lunch will be provided. Attendees will receive 1.0 hour of Illinois CLE credit, pending approval. A photo ID is required to enter the building.  Click here to register for the event.

On November 5, 2026, at 3:00 p.m., the Settlement Assistance Program Committee of the U.S. District Court for the Northern District and Chicago Lawyers’ Committee for Civil Rights will host a CLE program and celebration marking the Settlement Assistance Program’s (SAP) 20th anniversary. The event will be held at the Everett McKinley Dirksen United States Courthouse, 219 South Dearborn Street, Ceremonial Courtroom, 25th Floor, Chicago, Illinois.

The program will include:

3:00 p.m. –  Ethical Considerations When Representing a Party for Settlement Purposes Only: Presented by Professor Wendy J. Muchman of Northwestern Pritzker Law. One hour of ethics CLE credit is available.

4:00 p.m. –  20th Anniversary Celebration and Attorney Volunteer Recognition: Featuring Chief Judge Virginia Kendall and Retired Magistrate Judge Morton Denlow. A reception with light refreshments will immediately follow.

The event is sponsored by the Federal Bar Association, Seventh Circuit Bar Association, and Northern District of Illinois Court Historical Association.

Please RSVP by Friday, October 30, 2026, at https://tinyurl.com/SAP20Celebration.

On Thursday, November 5, 2026 from 3:00 p.m. to 5:00 p.m. the Settlement Assistance Program Committee of the U.S. District Court for the Northern District of Illinois and the Chicago Lawyers’ Committee for Civil Rights invite you to commemorate the Settlement Assistance Program’s 20th anniversary.

The event is sponsored by the Federal Bar Association Chicago Chapter, the Seventh Circuit Bar Association, and the Northern District of Illinois Court Historical Association.  The celebration will take place in the Ceremonial Courtroom on the 25th floor of the Everett McKinley Dirksen United States Courthouse, 219 South Dearborn Street, Chicago.

The program begins at 3:00 p.m. with a CLE presentation, “Ethical Considerations When Representing a Party for Settlement Purposes Only,” followed at 4:00 p.m. by the anniversary celebration and attorney volunteer recognition. A reception with light refreshments will follow.

Settlement Assistance Program Speakers include:

Attendance is free and open to FBA members and nonmembers.  The program offers one hour of Ethics CLE credit, pending approval. Please RSVP by Friday, October 30, and remember to bring a photo ID for courthouse entry.

Endurance Warranty Services, LLC v. Nationwide AutoProtect, LLC, No. 26 C 3622, (N.D. Ill. June 7, 2026) (Kennelly, J.).

Judge Kennelly granted plaintiff Endurance Warranty Services’ motion for a preliminary injunction (PI) in this Lanham Act case alleging that direct competitor Nationwide AutoProtect posed as Endurance via deceptive websites and telephone calls and directly contacted Endurance customers with false accusations to induce them to cancel their Endurance contracts and switch to Nationwide. The Court held an expedited PI hearing at which Endurance presented testimony and exhibits. Nationwide called no witnesses.

Of particular interest, the Court held:

  • False Advertising: Endurance introduced evidence of numerous customer reports of calls in which callers, reasonably inferred to be acting for Nationwide, since they tried to switch customers to Nationwide, falsely claimed Endurance was going out of business, had been “red flagged” by the government, was under DOJ investigation, or was a fraudulent business not paying claims. Call transcripts showed material deception on matters significant to a reasonable customer’s contract decision. The interstate telephone calls established the interstate-commerce nexus.
  • Trademark Infringement: Endurance submitted evidence of a Google banner ad appearing in searches for “Endurance” that identified Nationwide as “Endurance Car Warranty” and routed customers seeking Endurance’s customer service to Nationwide instead. The Court found this was sufficient evidence of likelihood of confusion and misappropriation of Endurance’s goodwill. Nationwide did not contest the validity of Endurance’s mark at this stage.
  • Irreparable Harm: The Court found it reasonable to infer that customers who did not personally contact Endurance about the misleading calls simply canceled their contracts. Both the deceptive calls and the false search ad created a significant, hard-to-quantify risk of goodwill impairment not compensable by money damages alone.
  • Balance of Harms and Public Interest: The balance favored Endurance. Nationwide did not even argue the balance of harms tipped against an injunction. The Lanham Act reflects a public policy favoring enforcement of valid trademarks and preventing deceptive advertising.

The Court directed Endurance to submit a draft injunction order.

Montway LLC v. Nexus AT LLC, et al., No. 25 C 13100, consolidated with SGT Auto Transport Corp. v. Nexus AT LLC, No. 26 C 1056, (N.D. Ill. June 2, 2026) (Kennelly, J.).

Judge Kennelly denied in part and granted in part defendants’ Fed. R. Civ. P. 12(b)(6) motions to dismiss in these two related lawsuits alleging a novel theory of Lanham Act liability: a “toxic backlink” SEO sabotage campaign. Plaintiffs Montway and SGT, competing auto-transport brokers with federally registered marks, alleged that defendant Nexus AT LLC (at the direction of its CEO Gokhan “George” Arkin) created toxic backlinks pointing to plaintiffs’ websites using misleading anchor text associated with unsavory content, including online casinos, steroids, payday loans, and CBD products, thereby confusing Google’s algorithm and falsely implying association between plaintiffs and those disreputable sites.

Of particular interest, the Court held:

  • False Advertising — Literal Falsity: The anchor text is literally false because it purports to lead to plaintiffs’ sites or services but actually redirects elsewhere. No separate showing of actual deception is required where the representation is literally false. The Court found the backlink scheme functions like negative advertising and is covered by the Lanham Act despite being a nontraditional advertising medium. The Court applied the Seventh Circuit’s rejection of a rigid four-factor “commercial advertising or promotion” test.
  • Trademark Infringement: Plaintiffs adequately pled likelihood of confusion. The backlinks and anchor text used plaintiffs’ actual marks (“Montway,” “sgtautotransport”), creating the impression of affiliation with untrustworthy spam sites. The Court noted that likelihood of confusion is a fact question generally unsuited to resolution at the Rule 12 stage, and rejected Nexus’s “sophisticated consumer” argument as a matter for discovery.
  • Dilution by Tarnishment: The marks were plausibly alleged as “famous” given long continuous use (Montway since 2007, SGT since 2014) and significant marketing expenditures. Connecting the marks to sexual and illegal-activity-adjacent sites plausibly states a claim for tarnishment under 15 U.S.C. § 1125(c).
  • California UCL Claims Dismissed: The California Unfair Competition Law does not apply extraterritorially. Plaintiffs’ theory that they were injured in California because Google is headquartered there was rejected. Any injury was suffered where consumers searched and were redirected, not at Google’s headquarters.
  • Individual Liability: The claim against Arkin individually survived under 805 ILCS 180/10-10(a-5). Montway alleged Arkin personally decided to launch the campaign and directed another individual to execute it, which suffices without needing to pierce the corporate veil. A manager is personally liable for his own wrongful acts even when acting on the LLC’s behalf.

Stussy, Inc. v. The Partnerships & Unincorporated Associations Identified on Schedule A, No. 26 C 2870, (N.D. Ill. June 1, 2026) (Kendall, C.J.).

Chief Judge Kendall denied defendant NIOKIT’s motion to dismiss for lack of personal jurisdiction in this Schedule A trademark counterfeiting action. Stussy, the well-known streetwear brand, alleged that NIOKIT sold rugs on Amazon bearing a counterfeit version of Stussy’s federally registered “stylized billiard 8 ball” mark. Stussy’s investigator purchased one allegedly infringing rug from NIOKIT via Amazon. NIOKIT accepted the order and shipped the rug to Stussy’s attorney’s office in Chicago. Stussy obtained an ex parte temporary restraining order, then moved for a preliminary injunction (PI). NIOKIT moved to dismiss for lack of personal jurisdiction rather than opposing the PI motion (which was granted as unopposed).

Of particular interest, the Court held:

  • Purposeful Direction: NIOKIT structured its own online Amazon storefront to accept and ship orders to Illinois. That Stussy’s investigator placed the order did not matter. The focus is on NIOKIT’s conduct in filling the order and shipping to Illinois, not the customer’s motivation for buying. The Court found that NIOKIT “wants to have its cake and eat it too,” the benefit of a nationwide business model without any of the jurisdictional exposure.
  • NBA Properties Controls: The Court found the case “virtually identical” to NBA Properties, Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022), and rejected NIOKIT’s reliance on Third and Eighth Circuit authority as non-binding. The Court also rejected the “stream of commerce” framing. This was a direct-to-consumer sale, not a stream-of-commerce case.
  • No Bright-Line “More Than One Sale” Rule: The Court rejected any requirement that a plaintiff demonstrate more than a single sale to establish jurisdiction. Because the claim arose directly from the sale and shipment into Illinois, relatedness was satisfied.
  • Fair Play and Substantial Justice: NIOKIT’s complaints about its frozen Amazon account came too late. NIOKIT chose not to contest the PI motion. Illinois and Stussy both have strong interests in policing counterfeit goods sold to Illinois consumers. Because personal jurisdiction was proper under Fed. R. Civ. P. 4(k)(1) and the general due-process analysis, the Court did not reach the parties’ Rule 4(k)(2) arguments.

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.