Robert Bosch LLC v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified On Schedule A Hereto

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's ex parte motion to extend the temporary restraining order 39 is granted. The Temporary Restraining Order is extended to 8/5/2026. No appearance necessary on 7/21/2026. Mailed notice.

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MINUTE entry before the Honorable Sharon Johnson Coleman: Upon review, the Court rules that Plaintiff's second amended complaint 31, together with Plaintiff's other recent filings, successfully establishes that this Court has personal jurisdiction over Defendant. See Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *2 (7th Cir. Mar. 31, 2026). The Court therefore resumes its consideration of Plaintiff's pending motions for a temporary restraining order 26 and for expedited discover 28. Both motions are granted; specific orders for each motion will follow. Mailed notice.

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MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 6/30/2026. Following Plaintiff's oral presentation of its motions for a temporary restraining order 26 and for expedited discovery 28, the Court finds that Plaintiff's amended complaint still has not established personal jurisdiction because it does not show evidence of products shipped into Illinois. The Seventh Circuit has held that personal jurisdiction over a Section A defendant typically requires evidence of "completed sales in the forum state." Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *2 (7th Cir. Mar. 31, 2026). Plaintiff has shown evidence of a purchase on Amazon, and counsel orally represented that the product has been shipped, but without a completed delivery that does not constitute a completed sale and therefore does not suffice to establish personal jurisdiction. See Uniform Commercial Code § 2-401(2) (title typically does not pass to a buyer until seller completes performance, including delivery of goods). As this Court wrote in a companion case, Bosch v. Schedule A Defendants, 26-cv-03027, "personal jurisdiction in a Section A case generally cannot be established where the plaintiff 'has not provided proof. that Defendants have actually sold goods to Illinois residents and shipped those goods into Illinois.'" Dkt. 30 at *2 (N.D. Ill. April 17, 2026) (quoting Fendi S.R.L. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 25-CV-14553, 2025 WL 3514467, at *2 (N.D. Ill. Dec. 8, 2025) (Coleman, J.)); accord Manchester United Football Club Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 24-CV-5692, 2024 WL 5202272, at *3 (N.D. Ill. Dec. 23, 2024) (Chang, J.). Here, Plaintiff has not shown evidence of an allegedly infringing product entering Illinois and therefore has not shown evidence of a completed sale to an Illinois resident, so personal jurisdiction has not been established. The Court continues Plaintiff's motions [26, 28] and directs Plaintiff to either file a second amended complaint or else a supplement containing evidence sufficient to establish personal jurisdiction over Defendant. The Court will resume consideration of Plaintiff's motions if and when personal jurisdiction has been established. Plaintiff's amended ex parte motion for entry of a temporary restraining order, including a temporary injunction and a temporary asset restraint 26 and amended motion for expedited discovery 28 are entered and continued. Plaintiff's previous motions 16 and 19 are stricken as moot. Mailed notice.

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