2026-cv-03319

COMPLAINT filed by NextClimb Investments LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-24898802.

Exhibit 1 - Part 1

Exhibit 1 - Part 2

Exhibit 2

Exhibit 3

Exhibit 4

Schedule A

(Civil Cover Sheet)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by NextClimb Investments LLC

Notice of Claims Involving Trademarks by NextClimb Investments LLC

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category Two).

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.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff has filed a complaint alleging infringement by 34 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 19 and 20 is rarely appropriate in Schedule A cases. Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder at least 7 days before the filing of the motion for temporary restraining order. Alternatively, by the same date, Plaintiff may file an amended complaint and amended Schedule A reducing the number of defendants. However, if Plaintiff names multiple defendants, Plaintiff must show that joinder of those defendants is proper. The Court directs Plaintiff to this Court's standing order in Schedule A cases regarding joinder on the Court's website. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

Amended Complaint

Miscellaneous Relief

MINUTE entry before the Honorable Sharon Johnson Coleman: On review of Plaintiff's amended complaint [7], the Court observes that Plaintiff has not provided evidence that any Defendant has sold the allegedly infringing products to Illinois customers and shipped the products into Illinois. As the Seventh Circuit has recently affirmed, the Court cannot conclude that it has personal jurisdiction over a Schedule A defendant absent such information. Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *3 (7th Cir. Mar. 31, 2026). Screenshots showing a finalized order do not suffice under Liu. Additionally, Plaintiff has failed to file a memorandum supporting joinder, despite the Court's previous order [4]. The Court therefore dismisses Plaintiff's amended complaint without prejudice. Plaintiff may file a second amended complaint within 21 days if it can supply evidence sufficient to establish personal jurisdiction. Additionally, if Plaintiff's second amended complaint names multiple defendants, then Plaintiff must still file a memorandum support joinder. Plaintiff's pending motion for expedited discovery and electronic service [8] is stayed pending the resolution of Plaintiff's personal jurisdiction and joinder issues. No appearance necessary on 4/8/2026. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice. Plaintiff's motion for electronic service of process and expedited discovery [8] is stricken as moot. Civil case terminated. Mailed notice.