Web-Based Personal Jurisdiction in Schedule A Cases Requires at Least One Completed Sale into Illinois

Hublot SA v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 26 C 4668, (N.D. Ill. May 18, 2026) (Kendall, C.J.).

Chief Judge Kendall, in this Schedule A case, dismissed plaintiff Hublot’s complaint without prejudice for lack of personal jurisdiction pursuant to Fed. R. Civ. P. 12(b)(2). The Court had previously denied Hublot’s ex parte TRO motion based on the Seventh Circuit’s decision in Liu v. Monthly, 170 F.4th 1090 (7th Cir. 2026), and afforded Hublot an opportunity to supplement its jurisdictional showing. Hublot’s supplemental filing relied only on vague assertions of interactive communications, transaction-oriented conduct, and willingness to ship, without any evidence of a completed sale into Illinois. The Court held that under Liu and Curry v. Revolution Labs., 949 F.3d 385 (7th Cir. 2020), operating an interactive website accessible in Illinois is insufficient to establish specific personal jurisdiction. A plaintiff must demonstrate at least one completed sale into the forum state. The Court granted Hublot leave to amend within two weeks to demonstrate jurisdiction or face dismissal with prejudice and unsealing of the record.