Winnie Rosaline Kan v. The Partnerships and Unincorporated Associations Identified on Schedule A

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 12 is granted. However, plaintiff's motion for leave to file excess pages 13 and motion for TRO 14 are denied without prejudice in light of the Seventh Circuit's opinion in Liu v. Monthly, 170 F.4th 1090 (7th Cir. 2026). In Liu, the Court vacated the district court's entry of default judgment because the "evidence upon which the district court relied for establishing personal jurisdiction showed only that it was possible to order the defendants' products and have them shipped to Illinois, not that such sales took place." Id. at 1093. Specifically, the evidence in Liu consisted "of screenshots of [defendant seller's] website showing the checkout page with the infringing product, a Chicago shipping address, and the estimated total, but not a completed purchase." Id. Relying on NBA Props., Inc. v. HANWJH, 46 F.4th 614, 620 (7th Cir. 2022) and Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020), the Seventh Circuit explained that such evidence was insufficient to establish personal jurisdiction. Here, plaintiff has submitted the same type of evidence, i.e., screenshots of defendants' website showing the checkout page, but not a completed purchase. (Dckt. #16-2). Accordingly, before this case may proceed, plaintiff must file either an amended complaint or a supplemental submission establishing a basis for personal jurisdiction as to each defendant. If an amended complaint or supplemental statement consistent with this order and Seventh Circuit precedent is not filed by 5/13/26, this action may be dismissed without prejudice for lack of personal jurisdiction. See Enduring Love Int'l Church v. Williams, No. 23-CV-1120-PP, 2024 WL 3553979, at *2 (E.D.Wis. July 26, 2024) ("Although sua sponte dismissal of claims for lack of personal jurisdiction is generally disfavored, district courts retain discretion to depart from that principle"). Tracking status hearing set for 6/22/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice