HARI STUDIOS v. THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 4 is granted. Plaintiff's motion for temporary restraining order 5 and for electronic service of process 7 are denied without prejudice for the following reasons. First, upon the review of the plaintiff's submissions, the Court sua sponte raises the proprietary of joinder of almost 100 defendants in this case. See, e.g. Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D.Ill. 2020). By 10/30/26, plaintiff shall file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. In the alternative, plaintiff has leave to file an amended complaint with a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Estee Lauder, 334 F.R.D. at 189. Moreover, plaintiff's motion for electronic service of process is otherwise deficient in light of the Seventh Circuit's ruling in Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793 (7th Cir. 2026). In Kangol, the Seventh Circuit held that the Hague Service Convention "prohibits service by email in China." Id. at 795. The Court acknowledged, however, that the Convention does not apply if the defendant's address is unknown. Id. at799. "[C]ourts handling Schedule A cases typically require plaintiffs to make "'reasonably diligent efforts to ascertain and verify [the] defendant's mailing address' before deeming the defendant's address unknown." Id., quoting NBA Props., Inc. v. P'ships and Unincorporated Ass'ns Identified in Schedule "A", 549 F. Supp. 3d 790, 796 (N.D.Ill. 2021). Here, plaintiff has not made a proper showing that it has made reasonably diligent efforts to ascertain and verify each defendants' mailing address. Indeed, plaintiff's counsel's declaration in support of such efforts includes only conclusory and generic assertions. (See e.g., Dckt. #7-2 at 1-2 ("In my experience and knowledge of trademark and intellectual property infringement investigations and case law, even if a purported address is provided on an e-commerce store, there is a substantial likelihood that it is not a legitimate, monitored location.") & 2 ("An investigation of the e-commerce stores operating under Seller Aliases identified in Schedule A to the Complaint revealed that few, if any, provide a physical address on the ecommerce store."). These "bare assertions regarding the reliability of Defendant[s]' publicly available address[es] are not a substitute for actual diligence." NBA Props., 549 F.Supp.3d at 796. As such, if plaintiff ultimately files a renewed motion for electronic service after the issue of joinder is resolved, it must include the specific, diligent efforts taken to determine the physical address (and the outcome of those efforts) as to each defendant. Tracking status hearing set for 11/23/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice