Northern District of Illinois Service and Proof of Service Rules

Third parties not named in the complaint cannot be named in active concert with defendants unless active concert is proven and they receive advance notice and opportunity to be heard.

Source text: Third parties not named in the complaint (e.g., Amazon, eBay, DHgate) cannot be named as in active concert or participation with the defendants unless their active concert or participation is proven and they receive advance notice and an opportunity to be heard before the Court enters any order against them. See Fed. R. Civ. P. 65(d)(2); Lake Shore Asset Mgmt. Ltd. v. Commodity Futures Trading Comm’n., 511 F.3d 762 (7th Cir. 2007).

Serving Chinese entities via email is prohibited under the Hague Service Convention.

Source text: Serving Chinese entities via email is not permitted. Id. at *6 (the Hague Service Convention "prohibits service by email in China")

Notice of Designation for deposition testimony must be served within 14 days of transcript delivery, or on-record designation is waived.

Source text: Within 14 days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record identifying the specific portions of the transcript that are designated Confidential Information, and thereafter those portions identified in the Notice of Designation must be protected under the terms of this Order. The failure to serve a timely Notice of Designation waives any designation of deposition testimony as Confidential Information that was made on the record of the deposition, unless the Court orders otherwise.

Notice of Designation for deposition testimony must be served within the presumptive confidentiality period, or all designation is waived.

Source text: Within this time period, a party may serve a Notice of Designation to all parties of record as to specific portions of the testimony that are designated Confidential Information, and thereafter only those portions identified in the Notice of Designation shall be protected by the terms of this Order. The failure to serve a timely Notice of Designation shall waive any designation of testimony taken in that deposition as Confidential Information, unless the Court orders otherwise.

Receiving party must notify designating party in writing within 3 business days of subpoena/order to disclose Confidential Information.

Source text: If a receiving party is served with a subpoena or an order issued in other litigation that compels the disclosure of any material or document designated in this action as Confidential Information, the receiving party must notify the designating party in writing immediately and in no event more than 3 business days after

Receiving party must immediately provide written notice to the subpoena or court order issuer that requested material is subject to the protective order.

Source text: The receiving party also must immediately inform in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material the subpoena or order seeks is the subject of this Order.

Receiving party must promptly deliver a copy of the protective order to the party who issued the subpoena or court order.

Source text: The receiving party must also deliver a copy of this Order promptly to the party in the other action that caused the subpoena or order to issue.

Parties must exchange settlement letters with opposing counsel prior to the settlement conference.

Source text: Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it.

A Notice of Designation must be served to all parties of record within 14 days after deposition transcript delivery to preserve confidential designation, with failure to do so waiving the designation unless the Court orders otherwise.

Source text: Within 14 days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record identifying the specific portions of the transcript that are designated Confidential Information, and thereafter those portions identified in the Notice of Designation must be protected under the terms of this Order. The failure to serve a timely Notice of Designation waives any designation of deposition testimony as Confidential Information that was made on the record of the deposition, unless the Court orders otherwise.

A Notice of Designation must be served to all parties of record within the applicable time period (14 days after transcript delivery or 60 days after testimony) to designate specific confidential portions of deposition testimony, with failure to do so waiving the designation unless the Court orders otherwise.

Source text: Within this time period, a party may serve a Notice of Designation to all parties of record as to specific portions of the testimony that are designated Confidential Information, and thereafter only those portions identified in the Notice of Designation shall be protected by the terms of this Order. The failure to serve a timely Notice of Designation shall waive any designation of testimony taken in that deposition as Confidential Information, unless the Court orders otherwise.

Receiving party served with subpoena to disclose Confidential Information must notify designating party in writing within 3 business days.

Source text: If a receiving party is served with a subpoena or an order issued in other litigation that compels the disclosure of any material or document designated in this action as Confidential Information, the receiving party must notify the designating party in writing immediately and in no event more than 3 business days after

Designating party must respond to confidentiality designation challenge within 5 business days.

Source text: The designating party must respond to the challenge within 5 business days.