Glimpse LLC v. John Doe

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed plaintiff's motion for electronic service of process [19] and supplemental filings. If the Hague Service Convention applies, then service by email is improper because the Convention prohibits service by email in China. Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co. 177 F.4th 793, 801 (7th Cir. 2026). However, the Hague Service Convention does not apply if a defendant's address is not known. "District courts 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. at 799 (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)). Courts only consider efforts taken by a plaintiff before seeking leave for electronic service, and not efforts taken after a court order inquiring about the motion. See Erchonia Corp. LLC v. P'ships and Unincorporated Ass'ns Identified on Schedule A, 2026 WL 2354633, at *3 (N.D. Ill. Aug. 6, 2026); Deckers Outdoor Corp. v. A AO, 2026 WL 1802901, at *5 (N.D. Ill. June 23, 2026). Plaintiff's submissions do not reflect a reasonably diligent effort to ascertain and verify the defendant's address. Instead, the submitted declaration lists that an agent went to the publicly listed address but did not search for the company's registered business address or attempt a test mailing. Accordingly, plaintiff's motion for electronic service of process [19] and motion for temporary restraining order [15] are denied without prejudice. Plaintiff's motion to seal [20] and motion for leave to file excess pages [14] are granted. A status report is due on 11/10/2026. Mailed notice

法院批准TRO

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for temporary restraining order [15] and plaintiff's motion for leave to file excess pages [14] are entered and continued. The Court raises whether alternative service of process is appropriate given the Seventh Circuit's recent decision in Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793 (7th Cir. 2026). By 9/21/2026, plaintiff shall file a status report detailing what efforts plaintiff has taken to determine defendant's address. To the extent Plaintiff is arguing that the Hague Convention does not apply in this case, that argument must be supported with legal authority and sworn declarations of fact establishing reasonable diligence. Mailed notice

法院批准TRO

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for leave to file under seal [5] is granted in part and denied in part. Plaintiff is granted leave to file a motion for ex parte temporary restraining order and its accompanying memorandum and exhibits under seal. Plaintiff's motion is denied in all other respects. "There is insufficient evidence. that Schedule A defendants are taking advantage of the case-tracking option to such an extent that it is materially impeding brand owners' enforcement efforts." XYZ Corp. v. Partn. & Unincorporated Ass'ns Identified on Schedule A, 2022 WL 180151, at *2 (N.D. Ill. Jan. 20, 2022). Accordingly, by 8/19/2026, plaintiff shall file an amended unredacted complaint. Further, upon review of the complaint, the Court advises Plaintiff that no motion for an ex parte temporary restraining order should be filed in this matter without counsel first evaluating whether a restraint of assets would capture more than sales from the allegedly infringing products. A court cannot impose an asset restraint "simply to establish a fund from which a later award of money damages can be satisfied." See Banister v. Firestone, No. 17 C 8940, 2018 WL 4224444, at *9 (N.D. Ill. Sept. 5, 2018); see also Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025). Mailed notice

法院批准TRO