Blue Sphere, Inc. v. The Individuals, et al., No. 25 CV 004715, (N.D. Ill. Sept. 10, 2025) (Coleman, J.).

Judge Coleman dismissed this Schedule A trademark case for lack of personal jurisdiction, finding that plaintiff Blue Sphere failed to establish that defendants sold any counterfeit Lucky 13 products to Illinois residents. The Court held that screenshots of Walmart.com listings showing Illinois addresses, without proof of actual sales or shipments, were insufficient to establish the purposeful availment required for specific personal jurisdiction.

Blue Sphere alleged that defendants sold counterfeit versions of its Lucky 13 trademarks through Walmart’s e-commerce platform. However, the only evidence submitted consisted of screenshots showing purchase pages with Illinois addresses. There was no confirmation of any actual purchases from or shipments to Illinois. The Court emphasized that allegations “on information and belief” that products had been sold to Illinois consumers, without supporting evidence, could not satisfy the purposeful availment prong of the personal jurisdiction analysis.

The Court distinguished this case from others in the Northern District where personal jurisdiction was found, noting those cases involved evidence of actual sales, written confirmations with Illinois shipping addresses, or proof of shipment to Illinois customers. Without such evidence, merely operating an interactive website accessible in Illinois is insufficient to confer personal jurisdiction over foreign defendants.

Having found no personal jurisdiction, the Court dismissed the complaint and struck the motion for default judgment as moot.