By Wallace Feng
Recently, the United States Court of Appeals for the Seventh Circuit ruled in Liu v. Monthly that a defendant’s operation of an online store is not enough by itself to confer specific personal jurisdiction over that defendant. See 170 F.4th 1090 (7th Cir. 2026).
In rendering the ruling, the Seventh Circuit vacated a default judgement issued by the Northern District Cour to Illinois in a Schedule A Defendant (“SAD”) case against a multitude of e-commerce seller defendants that did not timely respond to the plaintiff’s complaint of trademark infringement. When the defendants did appear in the case months after the entry of the default judgment, they moved to vacate the judgment for lack of jurisdiction in Illinois.[1] The district court denied that motion and maintained the default judgment, leading to an appeal of the decision.[2]
On appeal, the Seventh Circuit noted that although the defendants owned online stores accessible to Illinois residents, there was no evidence that the defendants had sold infringing products to Illinois.[3] As a result, the record did not establish that the defendants had purposefully availed themselves to the benefits of the forum state necessary to satisfy personal jurisdiction.[4] Because there was no jurisdiction over the defendants, the Seventh Circuit further reasoned that there was no basis for the default judgment.[5]
Given that Liu was made in the context of a SAD matter, plaintiffs and defendants in SAD cases should consider the implications of Liu.
Leydig, Voit & Mayer, Ltd. and its team of skilled intellectual property attorneys have extensive experience in litigating SAD cases, including issues of personal jurisdiction.
[1] 170 F.4th at 1092–93.
[2] Id.
[3] Id. at 1093–94.
[4] Id.
[5] Id.
