Page 11 - Kattison Avenue Newsletter - Spring 2026 - Issue 16

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targeted, venue-specific relief obtained after tours began and on website screenshots, reinforcing limits on the theory that a
injury was “concrete and ongoing” was necessary. Specificity seller’s willingness to ship to Illinois, without proof of actual
and certainty are key, even if the offenders are unidentified John sales, is sufficient to establish jurisdiction. See Liu v. Monthly, 170
Does. F.4th 1090 (7th Cir. 2026).
District of New Jersey: A New Hotbed for With the game changing in Illinois, plaintiffs have altered their
Schedule A Litigation pattern of play, instead filing cases in New Jersey.

With the World Cup Final taking place in New Jersey, a In September 2025, District of New Jersey Chief District Judge
jurisdiction that is no stranger to Schedule A litigation, John Doe Renee Marie Bumb issued Standing Order 2025-4 (Order)
is sure to be outside MetLife Stadium for the match. in response to the “uptick” in Schedule A cases filed in the
jurisdiction. The Order sets a strict set of rules to curb abuse
Historically, the Northern District of Illinois has been the
of the Schedule A scheme, striking a balance that lays out a
favored jurisdiction for filing Schedule A cases, with the court
mechanism for mark owners to utilize the Schedule A scheme
even offering a “Schedule A Template” on its website. However,
with boundaries, while curbing due process concerns.
the last year has shown judges in the Northern District of Illinois
are growing increasingly skeptical of the Schedule A litigation Judge Bumb’s Order puts personal jurisdiction at the forefront
model, with one judge pausing his Schedule A docket and another of the inquiry, with the main concern being the targeting of large
openly challenging plaintiffs’ generalized allegations and joinder swaths of online sellers. Judge Bumb reasons, “[t]he law is well-
practices. On March 9, the Seventh Circuit issued a ruling settled that simply being an online seller on Amazon isn’t enough
rejecting personal jurisdiction in a Schedule A case based solely … [a] plaintiff cannot create personal jurisdiction by ordering a

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