2026-cv-03956

COMPLAINT filed by Lando Norris; Jury Demand. Filing fee $ 405, receipt number AILNDC-24958133.

Exhibit A

(Civil Cover Sheet)(Quezada Hastings, Sofia)

SEALED DOCUMENT by Plaintiff Lando Norris Schedule A to Complaint (Quezada Hastings, Sofia)

ATTORNEY Appearance for Plaintiff Lando Norris by Sofia Quezada Hastings (Quezada Hastings, Sofia)

MOTION by Plaintiff Lando Norris to seal Certain Documents (Quezada Hastings, Sofia)

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2).

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 John Robert Blakey: Plaintiff seeks to sue 181 separate defendants in this trademark infringement suit, [1], [2]. Joinder of multiple defendants in a single action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). The initial complaint lumps all Defendants together and alleges, in a conclusory manner, that "the e-commerce stores operating under the Seller Aliases often share unique identifiers, such as templates with common design elements that intentionally omit any contact information or other information for identifying Defendants or other Seller Aliases they operate or use. E-commerce stores operating under the Seller Aliases include other notable common features such as use of the same registration patterns, accepted payment methods, check-out methods, keywords, advertising tactics, similarities in price and quantities, the same incorrect grammar and misspellings, and/or the use of the same text and images. Additionally, Unauthorized Norris Products for sale by the Seller Aliases bear similar irregularities and indicia of being counterfeit to one another, suggesting that the Unauthorized Norris Products were manufactured by and come from a common source and that Defendants are interrelated." [1] 55. The allegations remain conclusory and fail to support the joinder of 181 defendants here. Nor does Plaintiff's submission support the exercise of personal jurisdiction over the identified defendants. Plaintiff alleges that personal jurisdiction remains proper as to all defendants because they "transacted business relative to the claims made within the State of Illinois and within this District and because Defendants purposefully availed themselves of the benefits and privileges of conducting business activities within the State of Illinois and within this District." [1] 17. But that allegation also remains conclusory and need not be accepted. Plaintiff also alleges that defendants "utilize online retail accounts to promote and offer to sell the Unauthorized Norris Products in Illinois and to Illinois residents, have sold the Unauthorized Norris Products to one or more customers in Illinois, and provide for the shipment of the Unauthorized Norris Products to customers in Illinois." Id. 18. But the mere maintenance of a website, even a fully interactive website accessible in Illinois, remains insufficient. 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."). Moreover, Plaintiff's test buys cannot by themselves support the exercise of personal jurisdiction. See, e.g., Walden v. Fiore, 571 U.S. 277, 285 (2014) ("the plaintiff cannot be the only link between the defendant and the forum"); Expeditee LLC v. Entities Listed on Exhibit 1, No. 21 C 6440, 2022 WL 1556381, at *4 (N.D. Ill. May 17, 2022) ("Plaintiff claims that, as part of its preliminary investigation, it purchased infringing products from the Moving Defendants that the Moving Defendants shipped to Chicago. Such sales on their own are insufficient for the purposes of personal jurisdiction, for Plaintiff has not identified evidence of any transactions involving an allegedly counterfeit product between the Moving Defendants and Illinois customers, other than the 'test buys.'"). For these reasons, the Court dismisses Plaintiff's complaint [1]. If Plaintiff can, consistent with its obligations under Rule 11, amend its complaint to allege facts to support the joinder of 181 separate defendants in this single action and the exercise of personal jurisdiction over each identified defendant, it may do so by 5/6/26. If Plaintiff declines to amend, the Court will dismiss this case. The Court denies as moot Plaintiff's motion to seal [4]. Mailed notice.