LifePro Fitness LLC

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed Plaintiff's memorandum on joinder [7] and determines, within its discretion, that plaintiff has failed to satisfy its burden to show that joinder of 64 defendants is proper in this matter under Fed. R. Civ. P. 20(a)(2). See Este Lauder Cosms. Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, 334 F.R.D. 182, 185 (N.D. Ill. Jan. 27, 2020) (noting that "[plaintiff] bears the burden of demonstrating that joinder is proper"). In evaluating the appropriateness of joinder, the Court assesses whether a logical relationship exists between defendants through actual evidentiary overlap, not coincidence. Id. Overall, plaintiff's arguments fall short of establishing a logical relationship among the defendants. While plaintiff proposes dividing the defendants into groups and severing them into multiple cases, the Court is not persuaded that any one defendant's infringement is linked to the next defendant's infringement sufficient to show they are part of the same transaction, occurrence, or series of transactions or occurrences as required by Rule 20. Similarities between websites, prices, sales tactics, and unauthorized products do not suggest a logical relationship between defendants. Art Ask Agency v. Individuals, Corps., Ltd. Liab. Cos., P'ships, & Unincorporated Ass'ns Identified on Schedule "A", 2021 WL 5493226, at *2 (N.D. Ill. Nov. 23, 2021). Further a claim that defendants infringed on its trademark in the same way does not sufficiently link one defendant to another. Roadget Bus. Pte. Ltd. v. Individuals, Corps., Ltd. Liab. Companies, P'ships, & Unincorporated Ass'ns Identified on Schedule A Hereto, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) ("Courts in this district generally agree that alleging that multiple defendants have infringed on the same copyright in the same way does not create the substantial evidentiary overlap required to find a similar transaction or occurrence."). Even if the Court were mistaken in its joinder analysis, the Court exercises its discretion to not permit joinder in this case. See Dorsey v. Varga, 55 F.4th 1094, 1103 (7th Cir. 2022). Joining this many defendants in one case simply will not promote judicial economy. See Este Lauder, 334 F.R.D. at 189 ("[P]resenting dozens or hundreds of defendants in one lawsuit actually undermines judicial economy, because this Court must evaluate the evidence submitted in support of liability and, eventually, damages. That is especially true in the ex parte setting of a temporary restraining order, as well as for default-judgment motions."); Art Ask Agency, 2021 WL 5493226, at *3 (noting that "joinder in this case may yield significant financial benefits to [plaintiff] at the judiciary's expense."). Accordingly, the Court dismisses defendant Nos. 2-64 without prejudice. The case will proceed against defendant No. 1. Accordingly, plaintiff's motion for temporary restraining order [3] is denied without prejudice. Plaintiff's motion to seal [2] is granted. Plaintiff is granted leave to file an amended complaint in accordance with this Order by 11/10/2026. Mailed notice

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