Tee Turtle LLC v. Schedule A Does, No. 25 C 2910, Slip Op. (N.D. Ill. Oct. 9, 2025) (Coleman, J.)
Judge Coleman denied default judgment and dismissed Tee Turtle’s Schedule A case for lack of personal jurisdiction pursuant to Fed. R. Civ. P. 12(b)(2) after the plaintiff failed to offer evidence of even a single completed Illinois sale, shipment, or order confirmation, despite screenshots showing product listings and the ability to ship to an Illinois address in this copyright case. The decision underscores an increasingly consistent Northern District trend: for online marketplace defendants, a purchase into Illinois—or similarly concrete sales evidence—remains the most reliable jurisdictional anchor.
Key IP Rulings and Implications. Although Tee Turtle asserted Lanham Act and Copyright Act claims, the Court did not reach the merits because it did not have jurisdiction. In Schedule A cases involving foreign online sellers, plaintiffs cannot rely on “on information and belief” allegations or shopping-cart screenshots alone. The Court stressed the defendant-focused nature of specific jurisdiction and the need for evidence connecting the alleged infringement to Illinois. Practically, this means that plaintiffs should be ready to provide authenticated proof of an Illinois transaction—order confirmation, shipment data, and/or delivery records—to avoid early dismissal. The case is part of a line of decisions making clear that bare screenshots are insufficient when they do not reflect an actual sale into the forum. A test purchase likely would have solved these issues, although there is no guarantee of that.
Strategic Takeaways. For plaintiffs, invest early in test purchases and record trails that show order confirmations and shipments delivered to Illinois customers. Anticipate that screenshots of product pages with an Illinois address field will not suffice. For defendants, a clean record—no Illinois sales—paired with a prompt jurisdictional challenge can short-circuit default motions and asset restraints. Counsel should also expect courts to scrutinize affidavit support and to deny default judgment where jurisdiction is not clearly established on the record.