Lachman v. Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by Daniel Lachman; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-25061258.

Exhibit Exhibit 1

SEALED DOCUMENT by Plaintiff Daniel Lachman Schedule A to Complaint

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Daniel Lachman by David Lee Gulbransen, Jr

MOTION by Plaintiff Daniel Lachman to seal document sealed document[2]

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 3).

MAILED copyright report to Registrar, Washington DC

MOTION by Plaintiff Daniel Lachman for temporary restraining order

MEMORANDUM by Daniel Lachman in support of motion for temporary restraining order[7]

Declaration Declaration of David Gulbransen

Declaration Declaration of Plaintiff

Exhibit Exhibit 1

SEALED DOCUMENT by Plaintiff Daniel Lachman Exhibit 2 to Declaration of Plaintiff

Exhibit Exhibit 2 (Part 2 of 4)

Exhibit Exhibit 2 (Part 3 of 4)

(Exhibit Exhibit 2 (Part 4 of 4))

MOTION by Plaintiff Daniel Lachman to seal document sealed document[9]

MOTION by Plaintiff Daniel Lachman for leave to file excess pages

NOTICE of Motion by David Lee Gulbransen, Jr for presentment of motion for temporary restraining order[7], motion for leave to file excess pages[11], motion to seal document[10], motion to seal document[5] before Honorable Edmond E. Chang on 5/19/2026 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: (1.) The Plaintiff's motion [11] for extra pages is granted. Given the goal of asset restraint, the motions [5] [10] to file under seal are granted. (2.) On review of the complaint, Schedule A, and the TRO brief, the TRO motion [15] is denied without prejudice. First, the Court raises the propriety of joinder of the 8 Defendants, R. 2. The Plaintiff shall review the opinion in Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182, 18789 (N.D. Ill. 2020) (trademark case, but applicable to copyright), and file a memorandum addressing the propriety of joinder by 05/29/2026. In lieu of the memorandum, by the same deadline, the Plaintiff may file an amended complaint with (a) one defendant or (b) a subset of the defendants along with a memo explaining why joinder of those defendants is proper. (3.) No prima facie case for personal jurisdiction has been established. The contention that availability to Illinois is enough, R. 8 at 5-6, would establish prima facie jurisdiction anywhere in the country. Having said that, for purposes of granting expedited discovery, it would be appropriate to allow the Plaintiff to obtain information on personal jurisdiction. Under Liu v. Monthly, 170 F.4th 1090, 109394(7th Cir. 2026), the Plaintiff must be able to show at least one sale of an infringing product into Illinois to establish personal jurisdiction. If the early discovery does not reveal a sale of an infringing product into Illinois, then personal jurisdiction will not be established. The Court raises this issue on its own given the ex parte, non-adversarial presentation at this stage of the case. Federal courts must carefully review filings when presented by just one side in an ex parte setting. See American Can Co. v. Mansukhani, 742 F.2d 314, 325 (7th Cir. 1984) (explaining that courts must "carefully consider" the need for TROs given the ex parte context); In re Grand Jury Proceedings of Special April 2002 Grand Jury, 347 F.3d 197, 205 (7th Cir. 2003) (explaining that the court had "conducted a careful in camera and ex parte review" of the record). The Plaintiff may file a motion for early discovery (a subset of the current TRO motion) by 05/29/2026. (4.) To track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 06/05/2026 at 8:30 a.m. Mailed notice.