Not a Real Holding Company Inc. v. HX JLK

MINUTE entry before the Honorable LaShonda A. Hunt: The Court has reviewed Plaintiff's amended complaint [9], which includes additional factual allegations and largely resolves its joinder and personal jurisdiction concerns at this time. The Clerk's office is directed, forthwith, to unseal the document(s) filed at [2], and to update the caption to reflect that the Defendant in this case is " HX JLK". By 11/3/26, Plaintiffs are ordered to file a status report proposing next steps in this case, if no other appropriate relief has been sought by that date. Mailed notice (gel,)

AMENDED complaint by Not a Real Holding Company Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. Plaintiff's motion for leave to file under seal [5] is denied. Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the names of defendants or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, 794 F. Supp. 3d 543, 552 (N.D. Ill. 2025) (Kness, J.). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000). The Clerk of Court is directed to unseal the document filed at [2]. Upon review of the copyright and trademark infringement complaint [1] and other filings, the Court questions whether Plaintiff has sufficiently alleged personal jurisdiction over the defendants. To adequately plead personal jurisdiction, Plaintiff must sufficiently allege that the defendants actually sold the allegedly infringing product to a customer in Illinois. See Liu v. Monthly, 170 F.4th 1090, 1093-94 (7th Cir. 2026) (citing Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020)). Plaintiff's complaint alleges sales in this district, but those allegations are conclusory and Plaintiff did not provide proof of actual sales in this district. See id. (remanding with instructions to dismiss for lack of personal jurisdiction because plaintiff had not provided screenshot evidence of actual sales in Illinois). The Court also questions whether Plaintiff has established sufficient grounds for joinder of all 80 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule A,No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 80 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. Accordingly, by 10/29/26, Plaintiff must file must file proof of actual sales in Illinois and either a memorandum explaining why joinder is proper or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity. Failure to do so will result in the amended complaint being dismissed without prejudice and this case being closed. Mailed notice

CIVIL Cover Sheet (Quezada Hastings, Sofia)

SEALED DOCUMENT by Plaintiff Not a Real Holding Company Inc. Schedule A to Complaint (Quezada Hastings, Sofia)

COMPLAINT filed by Not a Real Holding Company Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-25762430.

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Karyn L. Bass Ehler. Case assignment: Random assignment. (Civil Category 2).