Schedule A Personal Jurisdiction Requires Evidence of Completed Forum Sales, Not Mere “Ship-to-Illinois” Website Screenshots

1. Introduction

Yinnv Liu v. Monthly, et al. is a Seventh Circuit decision addressing a recurring threshold issue in “Schedule A” intellectual-property enforcement suits: when a federal court in Illinois may exercise specific personal jurisdiction over numerous foreign online sellers who operate storefronts on large e-commerce platforms.

The plaintiff, Yinnv Liu, owns a registered trademark for three stylized Chinese characters and sued hundreds of foreign entities (including the appellants, a group of China-based vendors operating on Walmart.com) for alleged Lanham Act violations. The defendants did not appear initially, and the district court entered default judgment, finding personal jurisdiction based largely on the court’s belief that the defendants had sold infringing products to Illinois residents and, in any event, operated U.S.-accessible stores offering U.S. shipping.

After appearing months later, the defendants moved under Federal Rule of Civil Procedure 60(b) to vacate the default judgment, arguing the judgment was void for lack of personal jurisdiction (and also challenging service). The district court denied the motion. On appeal—despite Liu’s failure to appear—the Seventh Circuit vacated and ordered dismissal for want of jurisdiction.

2. Summary of the Opinion

The Seventh Circuit held that the district court’s personal-jurisdiction finding rested on a clearly erroneous factual premise: the record contained no evidence of completed sales to Illinois customers. The screenshots relied upon showed only that a customer could place an order with an Illinois shipping address (i.e., a checkout page), not that an order was actually completed.

Without evidence of Illinois sales, the remaining contacts—operating online storefronts accessible in the United States and offering shipping to the United States—were insufficient as a matter of law under Seventh Circuit precedent. The court therefore vacated the default judgment and remanded with instructions to dismiss for lack of personal jurisdiction, without reaching the service-of-process arguments.

3. Analysis

A. Precedents Cited

Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851 (7th Cir. 2011)

This case supplies the appellate lens for Rule 60(b) challenges asserting that a judgment is void for lack of jurisdiction. The Seventh Circuit reiterated the key point quoted in the opinion: review is “less deferential” because “no court has the discretion to refuse to vacate [a] judgment once it recognizes its lack of jurisdiction.” That principle matters procedurally: if personal jurisdiction is absent, finality interests yield, and vacatur is mandatory.

Philos Techs., Inc. v. Philos & D, Inc., 802 F.3d 905 (7th Cir. 2015)

The 2015 Philos Techs. decision structures the standard of review and burdens: de novo review for the legal existence of personal jurisdiction, clear-error review for related factual findings, and the rule that the defendant bears the burden of proving lack of personal jurisdiction. In Liu, that framework allowed the panel to correct the district court’s core factual premise (Illinois sales) and then apply precedent to the legal question (whether the remaining contacts suffice).

NBA Props., Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022)

NBA Props. is the Seventh Circuit’s central Schedule A personal-jurisdiction guidepost. The Liu panel used it for:

• The doctrinal path for federal-question cases: when the federal statute (here, the Lanham Act) does not provide a nationwide service/personal-jurisdiction rule, courts look to the forum state’s long-arm statute (Illinois), which is coextensive with due process under 735 Ill. Comp. Stat. 5/2-209(c).
• The three-part due process test for specific personal jurisdiction (purposeful direction/availment; injury arising out of forum-related contacts; and fairness).
• The Schedule A context: an online store accessible in the forum, combined with completed forum sales, can be sufficient—while mere accessibility is not.

In other words, NBA Props. does not eliminate the need for concrete forum contacts; it identifies the type of evidence that commonly satisfies due process in these cases: actual sales into the forum (or comparably strong targeted conduct).

Curry v. Revolution Lab'ys, LLC, 949 F.3d 385 (7th Cir. 2020)

Curry provides the limiting principle: merely “operat[ing] a website, even a highly interactive website, that is accessible from, but does not target, the forum state” is not enough. The Liu panel treated Curry as controlling on the key legal issue once Illinois sales were removed from the analysis: a seller cannot be “haled into court” just because its site is accessible and technically able to accept orders for shipment to the forum.

The opinion’s move is doctrinally important: it treats “ability to ship” evidence as falling on the wrong side of Curry’s line absent proof of actual in-forum transactions or other forum-targeting conduct.

Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir. 2014)

The court cited Advanced Tactical to reinforce that even an “interactive website capable of accepting orders” does not, by itself, establish purposeful direction toward the forum. This citation strengthens the opinion’s treatment of the screenshots: a checkout page with an Illinois address shows interactivity and capability, but not constitutionally meaningful targeting or forum-directed activity in the absence of completed sales (or other stronger indicia).

B. Legal Reasoning

The court’s reasoning proceeds in two steps—one factual, one legal:

1. Factual correction (clear error): The district court found Illinois sales based on screenshots that showed a product in a cart/checkout flow with a Chicago shipping address and a total price. The Seventh Circuit held this proves only that an Illinois shipment was possible, not that a purchase occurred. The plaintiff’s own TRO motion described the screenshots as showing products “offered for sale” to Illinois residents, underscoring the absence of proof of completed transactions.
2. Legal consequence (de novo): Once Illinois sales are removed, the remaining asserted contacts are: (a) storefronts accessible in the United States and (b) shipping offered to the United States. Under Curry and Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., those contacts do not show purposeful forum direction/availment. Therefore, specific personal jurisdiction fails, making the default judgment void and requiring vacatur.

The panel also emphasized that, given the jurisdictional defect, it did not need to reach service-of-process issues. That sequencing reflects the hierarchy of threshold questions: without personal jurisdiction, the court cannot proceed to merits-adjacent enforcement.

C. Impact

This decision is likely to have immediate effects on Schedule A practice in the Northern District of Illinois and beyond:

• Evidence standard for “sales” in the forum: Plaintiffs relying on e-commerce screenshots will need proof of completed in-forum transactions (or other comparably persuasive evidence of forum targeting), not merely a checkout page or “can ship to Illinois” demonstration.
• Default judgments are vulnerable when jurisdictional facts are thin: Foreign online sellers who default (often due to practical barriers) may later move to vacate; courts must vacate if jurisdiction is absent, and Liu underscores that the presence of a default does not relax due process requirements.
• Constraining forum shopping in mass online IP enforcement: By rejecting “U.S.-accessible + U.S. shipping” as a basis for Illinois jurisdiction, the opinion limits the ability to consolidate global online-seller disputes in a single preferred forum absent concrete Illinois-directed conduct.
• Platform-based selling remains actionable, but not everywhere: The opinion does not insulate sellers who actually transact with Illinois consumers; rather, it clarifies that jurisdiction must be tied to real forum contacts, consistent with due process.

4. Complex Concepts Simplified

• Schedule A case: A lawsuit naming many defendants (often foreign online sellers) identified in an attached schedule rather than fully listed in the complaint, typically used in IP enforcement against alleged counterfeiters.
• Default judgment: A binding judgment entered because a defendant did not appear or defend. It can be undone if the judgment is “void,” including for lack of personal jurisdiction.
• Personal jurisdiction: The court’s power to require a defendant to litigate in that court. For specific jurisdiction, the defendant must have purposeful, forum-connected conduct related to the claim.
• Specific vs. general jurisdiction: General jurisdiction is “all-purpose” (typically where a defendant is at home). Specific jurisdiction is “case-linked” and depends on suit-related contacts with the forum. The parties agreed general jurisdiction was not available.
• Purposeful direction/availment: The defendant must intentionally engage with the forum (e.g., selling into the forum), not merely operate a website that happens to be reachable there.
• Clear error vs. de novo review: “Clear error” is deferential review of facts; “de novo” is non-deferential review of legal conclusions. Here, the factual error (no proof of Illinois sales) drove the legal result (no jurisdiction).

5. Conclusion

Yinnv Liu v. Monthly reinforces a concrete, evidence-driven rule for Schedule A litigation in the Seventh Circuit: personal jurisdiction in Illinois cannot rest on screenshots showing only that an online seller is capable of shipping to Illinois. Without proof of completed Illinois transactions (or other conduct showing forum targeting), a U.S.-accessible, interactive storefront and U.S. shipping options do not satisfy due process. The ruling both tightens the evidentiary showing needed to secure and preserve default judgments against foreign online sellers and clarifies that constitutional jurisdictional limits remain fully operative in mass online IP enforcement.