Robert Bosch GmbH et al v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. The Court has reviewed plaintiff's filings and orders as follows. Plaintiff's motion for leave to file under seal 8 and to file excess pages 15 are granted. Plaintiff's ex parte motion for temporary restraining order, including a request for electronic service of process 16 is denied without prejudice for the following reasons. First, the Court notes that plaintiff has presented evidence of completed purchases of the allegedly infringing products to customers in Illinois as to the defendant listed in Schedule A. (Dckt. #18 at 7). See Liu v. Monthly, 170 F.4th 1090 (7th Cir. 2026). However, plaintiff's motion is denied in light of the Seventh Circuit's opinion in Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793 (7th Cir. 2026). In Kangol, the Seventh Circuit held that the Hague Service Convention "prohibits service by email in China." Kangol, 177 F.4th at 801. The Court acknowledged, however, that the Convention does not apply if the defendant's address is unknown. Id. At 799. "[C]ourts handling Schedule A cases typically require plaintiffs to make 'reasonably diligent efforts to ascertain and verify [the] defendant's mailing address' before deeming the defendant's address unknown." Id., quoting NBA Props., Inc. v. P'ships and Unincorporated Ass'ns Identified in Schedule "A", 549 F.Supp.3d 790, 796 (N.D.Ill. 2021). Here, plaintiff has not made a proper showing that it has made reasonably diligent efforts to ascertain and verify defendant's mailing address. Indeed, plaintiff's declaration in support of such efforts includes only conclusory and generic assertions regarding the defendant. (See Dckt. #11-1 at 6) ("Counterfeiters such as Defendant often go to great lengths to conceal their identities and often use multiple fictitious names and addresses to register and operate their massive network of Internet Stores."). These "bare assertions" regarding the reliability of defendant's publicly available address is "not a substitute for actual diligence." NBA Props., 549 F.Supp.3d at 796. As such, if plaintiff ultimately files a renewed motion, including a request for electronic service, plaintiff must outline the specific, diligent efforts taken to determine the physical address (and the outcome of those efforts) as to defendant. Any such renewed motion shall be filed no later than 7/31/26. Tracking status hearing set for 8/28/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice