Liu v. Monthly

Federal 7th Circuit Court
Civil Court
Personal Jurisdiction
Citation
Case Number: 
No. 25-2074
Decision Date: 
March 31, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Vacated and remanded.
Judge: 
KIRSCH

Plaintiff filed multiple lawsuits against online vendors for allegedly infringing on her registered trademark. The defendants failed to appear in district court and the court entered default judgment against them. Defendants eventually appeared and moved to vacate the default judgment, arguing that the district court lacked personal jurisdiction. The district court denied the motion and defendants appealed. The Seventh Circuit found that the district court erred in finding that the defendants sold products to state residents and that the remaining facts were insufficient to support a finding of personal jurisdiction. (ROVNER and MALDONADO, concurring)