Link to Fendi S.R.L. v. Schedule A Defendants, No. 25 C 14553, (N.D. Ill. Dec. 8, 2025) (Coleman, J.) Fendi S.R.L. v. Schedule A Defendants, No. 25 C 14553, (N.D. Ill. Dec. 8, 2025) (Coleman, J.)
Judge Coleman dismissed Fendi’s Schedule A trademark/copyright complaint without prejudice for lack of specific personal jurisdiction and improper joinder after the Court raised the issues sua sponte.
While not reaching the merits of Lanham Act or copyright claims, the Court’s jurisdictional and joinder holdings have immediate significance for Schedule A litigation. The Court reiterated that operating an interactive website alone does not suffice; plaintiffs typically must show at least one Illinois sale and shipment or equivalent purposeful availment tied to the forum.
Joinder also faced heightened scrutiny. Alleging common infringement of the same marks is insufficient to join disparate sellers. Even a “unified sales script” theory failed without concrete, non-conclusory facts tying defendants’ conduct into the same transaction or occurrence or series thereof.