2026-cv-04394 AI分析
05/27/2026
MINUTE entry before the Honorable John Robert Blakey: In response to the Court's concerns about personal jurisdiction, Plaintiffs filed an amended complaint, 13, 14. But the allegations still fail to support the exercise of personal jurisdiction. Although a "defendant's deliberate and continuous exploitation of the market in a forum state, accomplished through its website as well as through other contacts with the state, can be sufficient to establish specific personal jurisdiction," uBID, Inc. v. The GoDaddy Group, Inc., 623 F.3d 421 (7th Cir. 2010), Plaintiffs do not claim such exploitation. Instead, they allege that "the defendant has sold one or more automotive relay switches bearing counterfeit versions of Plaintiffs' federally registered trademark to residents of Illinois by accepting payment for an infringing product, fulfilling the order for that product and intentionally shipping said order to an address in Illinois. Defendant sold a 5-piece set of automotive relay switches to a customer with an address located in the Northern District of Illinois on November 28, 2025 and agreed to ship the product to the same address between December 23, 2025 and January 6, 2026. Further, the Defendant Internet Store remains active and the infringing product which was sold to the Northern District of Illinois remains listed for sale." 13 at paragraphs 2, 12. See also 13 at paragraph 5 ("This Court has personal jurisdiction over the Defendant, in that the Defendant has sold a counterfeit product in Illinois and in this Judicial District"). A single sale, or even a few sales, does not show deliberate and continuous exploitation of the Illinois market, and, "if having an interactive website were enough in situations like this one, there is no limiting principlea plaintiff could sue everywhere. Such a result would violate the principles on which Walden and Daimler rest. Having an 'interactive website' (which hardly rules out anything in 2014 [and less in 2026]) should not open a defendant up to personal jurisdiction in every spot on the planet where that interactive website is accessible. To hold otherwise would offend 'traditional notions of fair play and substantial justice.'" Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796, 803 (7th Cir. 2014) (quoting Int'l Shoe Co. v. State of Wash., Off. of Unemployment Comp. & Placement, 326 U.S. 310, 316 (1945)). As a result, the Court dismisses the amended complaint 13 for lack of personal jurisdiction. Additionally, because it appears that further amendment would be futile, the Court dismisses this case. See, e.g., Selyutin v. Bd. of Directors of Skokie Gardens Condo. Ass'n, 818 F. App'x 535, 538 (7th Cir. 2020) (recognizing that a plaintiff's failure to remedy deficiencies can justify a ruling that further amendment would be futile, making dismissal appropriate). The pending motion for leave to file under seal 8 is denied as moot. Civil case terminated. Mailed notice. 翻译
05/22/2026
AMENDED complaint by Robert Bosch GmbH, Robert Bosch LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto 翻译
附件：
1:(Exhibit 1)
04/27/2026
MINUTE entry before the Honorable John Robert Blakey: Plaintiffs here sue a business entity which, "upon information and belief, resides primarily in the People's Republic of China or another foreign jurisdiction" and "conducts business throughout the United States, including within Illinois" "through the operation of a fully interactive commercial website and online marketplace operating under the Defendant Internet Store." 1 12. Plaintiffs allege that personal jurisdiction exists here because "Defendant is reaching out to do business with Illinois residents by operating one or more commercial, interactive Internet Store through which Illinois residents can purchase an automotive relay switch bearing counterfeit versions of Plaintiffs' BOSCH trademark." 1 2. But the mere maintenance of a website remains insufficient to establish personal jurisdiction. See, e.g., 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."). A defendant's "deliberate and continuous exploitation of the market in a forum state, accomplished through its website as well as through other contacts with the state, can be sufficient to establish specific personal jurisdiction." See, e.g., uBID, Inc. v. The GoDaddy Group, Inc., 623 F.3d 421 (7th Cir. 2010). But Plaintiffs' allegations do not support an inference of such exploitation and contacts. Although they allege in a conclusory fashion that Defendant "conducts significant business in Illinois," 1 5, the factual predicate for that conclusion appears to be that "Defendant sold a 5 piece set of automotive relay switches to a customer with an address located in the Northern District of Illinois on November 28, 2025 and agreed to ship the product to the same address between December 23, 2025 and January 6, 2026." Id. 2. Plaintiffs do not allege other facts to support an inference that Defendant has deliberately and continuously exploited the market in Illinois. As the Seventh Circuit cautioned in Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., "if having an interactive website were enough in situations like this one, there is no limiting principlea plaintiff could sue everywhere. Such a result would violate the principles on which Walden and Daimler rest. Having an 'interactive website' (which hardly rules out anything in 2014 [and less in 2026]) should not open a defendant up to personal jurisdiction in every spot on the planet where that interactive website is accessible. To hold otherwise would offend 'traditional notions of fair play and substantial justice.'" 751 F.3d 796, 803 (7th Cir. 2014) (quoting Int'l Shoe Co. v. State of Wash., Off. of Unemployment Comp. & Placement, 326 U.S. 310, 316 (1945)). If Plaintiffs can, consistent with their obligations under Rule 11, amend their complaint to alleges facts to support the exercise of personal jurisdiction, they may do so by 5/22/26. If Plaintiffs decline to amend, the Court will dismiss this case. The initial complaint 1 is dismissed. Mailed notice. 翻译
04/20/2026
CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2). 翻译
04/20/2026
NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Robert Bosch GmbH, Robert Bosch LLC 翻译
04/20/2026
MOTION by Plaintiffs Robert Bosch GmbH, Robert Bosch LLC to seal document Plaintiff's Motion for Leave to File Under Seal 翻译
04/20/2026
ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Elizabeth Aubree Miller 翻译
04/20/2026
ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Robert Payton Mcmurray 翻译
04/20/2026
ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by William Benjamin Kalbac 翻译
04/20/2026
ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Michael A. Hierl 翻译
04/20/2026
COMPLAINT filed by Robert Bosch GmbH, Robert Bosch LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-25000627. 翻译
附件：
1:(Exhibit 1)
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