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.

Dao Health v. Shenzhen Lutejiacheng Technology Co., Ltd., No. 23 C 4885 (N.D. Ill. Dec. 12, 2025) (Durkin, J.)

Judge Durkin construed seven disputed terms across three patents involving a hands-free breast milk collection device and a related valve, rejecting indefiniteness challenges and clarifying several scope disputes in this patent matter.

Of particular note, the Court held as follows:

  • “External suction source” – Construed with reference to the reservoir, not the bra. The pump must be external to the reservoir’s internal volume but need not be external to the bra. The Court relied on the claim’s juxtaposition of “within” (for the adaptor) and “external” (for the suction source), harmonized with the specification and prosecution history.
  • “A reduced volume … formed within said drip tube” – Not indefinite. The drip tube constitutes a reduced volume within the reservoir that can be closed via a valve to generate vacuum. The Court found the physical configuration coherent and comprehensible to a POSITA.
  • “A valve assembly” – Construed as “an assembly of multiple parts forming a valve,” consistent with the specification’s description of multiple components (e.g., valve body, valve cap, valve flap) and embodiments including overflow chamber and baffle or an alternative bladder design.
  • “A valve assembly disposed between and surrounded by the adaptor and the reservoir” – Given its plain meaning, “between” and “surrounded by” are not contradictory.
  • Distal-end aperture – The phrase “a distal end of said drip tube having an aperture adjacent the distal end” carries its plain meaning; no need to add “structure” to force a closed-end reading.
  • Functional “cyclical application and relief” and antecedent issues – The Court treated “said” before “vacuum pressure” and “cycle portion” as typographical errors; read in light of the specification, a POSITA would understand the pump supplies the alternating vacuum.
  • “Through said interior chamber” – Any antecedent issue resolved by context from claim 2 and the surrounding claim language; sufficiently definite.

Collectively, the Court favored text-anchored, specification-consistent readings and was reluctant to find indefiniteness where a POSITA could readily understand the claims in context.

Dao Health v. Shenzhen Lutejiacheng Technology Co., Ltd., No. 23 C 4885 (N.D. Ill. Dec. 2, 2025) (Durkin, J.)

Judge Durkin denied Shenzhen’s motion to amend to add inequitable conduct counterclaims, holding the proposed amendments were futile for failure to plead but-for materiality and specific intent under the Federal Circuit’s tightened Therasense standard.

Shenzhen alleged omissions relating to inventorship for earlier patents and a certification issue for a later patent. The Court found no plausible allegations that the Patent Office would not have issued the patents but for the alleged misconduct. The proposed claims focused on purported pecuniary motives and presentation issues, not but-for materiality as Therasense requires.

Fendi S.R.L. v. Schedule A Defendants, No. 25 C 14553, (N.D. Ill. Dec. 8, 2025) (Coleman, J.)

Judge Coleman dismissed Fendi’s Schedule A trademark/copyright complaint without prejudice for lack of specific personal jurisdiction and improper joinder after the Court raised the issues sua sponte.

While not reaching the merits of Lanham Act or copyright claims, the Court’s jurisdictional and joinder holdings have immediate significance for Schedule A litigation. The Court reiterated that operating an interactive website alone does not suffice; plaintiffs typically must show at least one Illinois sale and shipment or equivalent purposeful availment tied to the forum.

Joinder also faced heightened scrutiny. Alleging common infringement of the same marks is insufficient to join disparate sellers. Even a “unified sales script” theory failed without concrete, non-conclusory facts tying defendants’ conduct into the same transaction or occurrence or series thereof.

On April 17, 2026, from 12:00 p.m. to 1:00 p.m., the Asian American Bar Association of Chicago (AABA Chicago) in collaboration with the U.S. District Court for the Northern District of Illinois, will host a complimentary webinar focusing on federal motion practice. 

This special program, part of the Sidebar with Judge Kim series, will feature an engaging discussion moderated by Judge Kim and an outstanding panel of Federal Judges including Hon. Manish Shah, Hon. LaShonda Hunt, and Hon. Heather McShain.

This event offers attendees a unique opportunity to learn from experienced judges and gain a deeper understanding of motion practice.  To register, click here.