Judge Virginia M. Kendall

To satisfy Federal Rule of Civil Procedure 20 warranting joinder of the Schedule A defendants, the declaration must provide specific, non-conclusory, non-speculative facts showing that plaintiff's claims against each defendant arise from the same transaction or series of transactions and share common questions of law or fact. It must also identify non-conclusory, non-speculative facts linking defendants through a common scheme or interrelated conduct (e.g., shared identifiers, materially identical listings or products, common sources or fulfillment, coordinated platform activity, geographic and logistical overlap, or temporal proximity) sufficient to satisfy Rule 20. Merely alleging that multiple defendants infringe the same intellectual property in similar ways is insufficient and will be rejected.

Plaintiff’s attorney of record shall file a single signed declaration under penalty of perjury sufficient to satisfy the following conditions: a. Ex Parte Relief: i. To obtain the extraordinary and drastic remedy of an ex parte temporary restraining order, the declaration must satisfy Federal Rule of Civil Procedure 65(b)(1), including by identifying: (a) each defendants’ sale or offer for sale of the allegedly infringing product(s) within the past two months; (b) the ongoing and immediate harm to plaintiff (e.g., recent listings, transactions, or consumer confusion); (c) a factual link between each defendant and the challenged conduct; and (d) facts supporting plaintiff’s position that notice would likely result in concealment, transfer, or destruction of evidence or assets.

In addition to satisfying the Federal Rules of Civil Procedure, to warrant entry of default and default judgment, plaintiff's attorney of record shall file a single signed declaration under penalty of perjury certifying that all defendants were: (a) served; (b) provided notice of the motion for entry of default or default judgment through the same channels authorized for service; and (c) given a reasonable opportunity to appear and respond within the time permitted by the Court's order. The declaration shall further indicate whether any defendants subject to the motion have responded.

All proposed orders must be in strict compliance with this Court’s standing order on “Submitting a Proposed Order, Agreed or Otherwise, for Electronic Entry by the Judge.” Any proposed order with drafting or proofreading errors will be summarily rejected. See Pow! Entm’t, LLC v. Defs. Identified on Sched. A, 2020 WL 5076715 (N.D. Ill. Aug. 26, 2020), reconsideration denied and subsequent proposed default judgment rejected, 2020 WL 8455479 (N.D. Ill. Dec. 7, 2020).

Settlement conferences are more likely to be productive if the parties have previously exchanged demands and offers and have made a good faith effort to settle the case on their own. Accordingly, at least fourteen (14) days before the settlement conference, the plaintiff shall submit a written itemization of damages and a settlement demand to the defendant.

Parties with ultimate settlement authority must be personally present at the settlement conference, unless otherwise ordered by the Court. This means that if a party is an individual, that individual must personally attend; if a party is a corporation or governmental entity, a representative of the corporation or governmental entity who is authorized to negotiate and who has full settlement authority must personally attend; if a party requires approval by an insurer to settle, then a representative of the insurer who is authorized to negotiate and who

Plaintiff’s attorney of record shall file a single signed declaration under penalty of perjury sufficient to satisfy the following conditions: a. Ex Parte Relief: i. To obtain the extraordinary and drastic remedy of an ex parte temporary restraining order, the declaration must satisfy Federal Rule of Civil Procedure 65(b)(1), including by identifying: (a) each defendants’ sale or offer for sale of the allegedly infringing product(s) within the past two months; (b) the ongoing and immediate harm to plaintiff (e.g., recent listings, transactions, or consumer confusion); (c) a factual link between each defendant and the challenged conduct; and (d) facts supporting plaintiff’s position that notice would likely result in concealment, transfer, or destruction of evidence or assets. b. Joinder: i. To satisfy Federal Rule of Civil Procedure 20 warranting joinder of the Schedule A defendants, the declaration must provide specific, non-conclusory facts showing that plaintiff’s claims against each defendant arise from the same transaction or series of transactions and share common questions of law or fact. It must also identify facts linking defendants through a common scheme or interrelated conduct (e.g., shared identifiers, materially identical listings or products, common sources or fulfillment, coordinated platform activity, geographic and logistical overlap, or temporal proximity) sufficient to satisfy Rule 20. c. Personal Jurisdiction: i. The declaration must show that this Court has personal jurisdiction over each defendant—screenshots of websites no longer suffice. Liu v. Monthly, 170 F.4th 1090, 1093 (7th Cir. 2026) (“In the context of Schedule A litigation, a defendant’s operation of an online store accessible in the forum state, combined with completed sales in the forum state, has been found sufficient to subject that defendant to personal jurisdiction. . . . However, when assessing a defendant’s online contacts with a forum, we have cautioned that merely operating a website, even a highly interactive website, that is accessible from, but does not target, the forum state is not enough to sustain jurisdiction.”) (cleaned up).

In addition to satisfying the Federal Rules of Civil Procedure, to warrant entry of default and default judgment, plaintiff’s attorney of record shall file a single signed declaration under penalty of perjury certifying that all defendants were: (a) served; (b) provided notice of the motion for entry of default or default judgment through the same channels authorized for service; and (c) given a reasonable opportunity to appear and respond within the time permitted by the Court’s order. The declaration shall further indicate whether any defendants subject to the motion have responded.

To satisfy Federal Rule of Civil Procedure 20 warranting joinder of the Schedule A defendants, the declaration must provide specific, non- conclusory, non-speculative facts showing that plaintiff’s claims against each defendant arise from the same transaction or series of transactions and share common questions of law or fact. It must also identify non-conclusory, non- speculative facts linking defendants through a common scheme or interrelated conduct (e.g., shared identifiers, materially identical listings or products, common sources or fulfillment, coordinated platform activity, geographic and logistical overlap, or temporal proximity) sufficient to satisfy Rule 20.

To obtain the extraordinary and drastic remedy of an ex parte temporary restraining order, the declaration must satisfy Federal Rule of Civil Procedure 65(b)(1), including by identifying: (a) each defendants' sale or offer for sale of the allegedly infringing product(s) within the past two months; (b) the ongoing and immediate harm to plaintiff (e.g., recent listings, transactions, or consumer confusion); (c) a factual link between each defendant and the challenged conduct; and (d) facts supporting plaintiff's position that notice would likely result in concealment, transfer, or destruction of evidence or assets.

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.

In addition to satisfying the Federal Rules of Civil Procedure, to warrant entry of default and default judgment, plaintiff's attorney of record shall file a single signed declaration under penalty of perjury certifying that all defendants were: (a) served; (b) provided notice of the motion for entry of default or default judgment through the same channels authorized for service; and (c) given a reasonable opportunity to appear and respond within the time permitted by the Court's order. The declaration shall further indicate whether any defendants subject to the motion have responded.

Any motion contending that the Hague Convention does not apply must be accompanied by a declaration under penalty of perjury attesting to the specific facts showing how an exception applies. If that motion is based on defendants' unknown addresses, the plaintiff must first undertake diligent efforts to ascertain and verify the defendants' addresses prior to filing its motion.