2025-cv-04015 AI分析
04/16/2025
MINUTE entry before the Honorable John Robert Blakey: Plaintiff has filed a complaint seeking to sue 199 separate defendants for infringement of two different copyrights. See [1]. But joinder of multiple defendants in a single copyright infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). Here, Plaintiff's complaint lumps all Defendants together and alleges, in a conclusory manner, that they "share unique identifiers, such as design elements and similarities of the unauthorized products offered for sale, establishing a logical relationship between them and suggesting that Defendants' illegal operations arise out of the same transaction, occurrence, or series of transactions or occurrences." [1] at 7, 10, 14. But the conclusion does not necessarily follow the alleged facts; it is equally possible that each online retailer set up shop in the same or similar manner. See, e.g., Estee Lauder Cosms. Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182, 188-89 (N.D. Ill. 2020). Plaintiff also alleges that "the Infringing Products for sale in the Defendant Internet Stores bear similarities and indicia of being related to one another, suggesting that the Infringing Products were manufactured by and come from a common source and that, upon information and belief, Defendants are interrelated." Id. 31. This allegation remains conclusory and unsupported, and the Court need not accept it. As a result, the Court finds that Plaintiff has failed to allege facts to support the joinder of all 199 Defendants in this case and this dismisses the complaint [1] without prejudice. If Plaintiff can, consistent with its obligations under Rule 11, amend its pleading to allege facts to support joinder, it may do so by 5/9/25. If Plaintiff elects to amend, it should also bolster its allegations concerning personal jurisdiction as to each Defendant. Plaintiff alleges that "this Court may properly exercise personal jurisdiction over Defendants since each of the Defendants directly targets consumers in the United States, including Illinois, through at least the fully interactive commercial internet stores operating under the Defendant aliases and/or the online marketplace accounts identified in Schedule A attached hereto." [1] 2. But the mere maintenance of a website accessible in Illinois remains insufficient to confer personal jurisdiction. See, e.g., Am. Bridal & Prom Indus. Ass'n, Inc. v. The Partnerships & Unincorporated Associations Identified on Schedule A, 192 F. Supp. 3d 924, 93435 (N.D. Ill. 2016) (simply alleging the existence of purported counterfeiting via an interactive website is not enough, by itself, to confer personal jurisdiction); Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796, 803 (7th Cir. 2014) ("Having an interactive website. should not open a defendant up to personal jurisdiction in every spot on the planet where that interactive website is accessible."); Rubik's Brand, Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 20-CV-5338, 2021 WL 825668, at *3 (N.D. Ill. Mar. 4, 2021) (screenshot evidence showing that an order could be placed by an Illinoisan, "amounts to nothing more than maintaining an interactive website that is accessible in Illinois," and "that alone cannot confer personal jurisdiction."). Mailed notice. 翻译
04/14/2025
CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. 翻译
04/14/2025
CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 3). 翻译
04/14/2025
COMPLAINT filed by GJL Holding Company LLC; Filing fee $ 405, receipt number AILNDC-23344772. 翻译
附件:
1:Exhibit 4
2:Exhibit 3
3:Exhibit 2
4:Exhibit 1
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