Hari Studios v. The Partnerships and Unincorporated Associations Identified On Schedule A

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [9] is denied without prejudice. The motion relies on authority pre-Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793 (7th Cir. 2026) for the premise that a plaintiff need not attempt Hague service before seeking relief under Rule 4(f)(3). Kangol holds otherwise: where the Convention applies, its methods are exclusive, and it prohibits e-mail service on Defendants in China. The only route to the requested relief is a finding under Article 1 that a Defendant's address is not known following reasonably diligent efforts, and this record does not permit that finding. The supporting declaration [9-2] describes the investigation in general terms and reports its results schedule-wide: addresses "in numerous instances" could not be confirmed, and "many Defendants" lacked verifiable locations, without identifying which Defendants, what addresses were found, or what any search returned. The investigation was also limited to online mapping services, which are insufficient on their own to establish that an address is not known. See Reebok Int'l Ltd., 26 C 10969, Dkt. # 19 (N.D. Ill. Sept. 14, 2026) (Durkin, J.) ("the results of searches using online mapping services (e.g., Google Maps, Baidu Maps, etc.) are insufficient to establish that an address 'is not known' for purposes of jurisdiction under the Hague Convention."); Chrome Hearts LLC, 26 C 7163, at Dkt. # 45 (N.D. Ill. Aug. 18, 2026) (Rowland, J.) ("plugging in a candidate address into Baidu Maps and observing if the search results listed the corresponding Defendant's Seller Alias or business entity name. assumes that each Defendant listed its seller / business name on Baidu Maps."). Any renewed motion must be supported by a declaration made under penalty of perjury detailing the specific, reasonably diligent efforts undertaken and the outcome of each effort, as to each Defendant, and for any Defendant as to whom the investigation returned an identifiable physical location, Plaintiff must explain what steps were taken to rule the address out (for example, courier or investigator confirmation that the premises do not exist, are incomplete or fictitious, or are occupied by an unrelated party, or another similarly reliable method). A conclusory statement that an address could not be verified tells the Court nothing. A status report is due 10/26/2026. Mailed notice

MOTION by Plaintiff Hari Studios for Electronic Service of Process