Screenshots of purchase pages on Walmart’s e-commerce platform showing shipping options to Illinois were not enough to confer specific personal jurisdiction over defendants in a Schedule A trademark case. There was no evidence of an actual sale to Illinois residents, written confirmation of sales with an Illinois shipping address, or shipping confirmation to an Illinois address. Therefore, the case was dismissed for lack of jurisdiction.
The plaintiff claimed ownership of trademarks including LUCKY 13 used in connection with clothing and that the defendants were selling counterfeit LUCKY 13 products. But without evidence of sales to Illinois, its luck ran out when it sought default judgement against the defendants.
Case: Blue Sphere, Inc. v. Individuals, No. 25 CV 004715, 2025 U.S. Dist. LEXIS 176670 (N.D. Ill. Sep. 10, 2025).