Sued in a Schedule A Case? Your Accounts Are Frozen. Here Is What to Do.
¿Le congelaron los fondos por una demanda «Schedule A»? Envíenos el aviso y los documentos; le atendemos en español.
Most sellers learn they have been sued when Amazon, eBay, Walmart, Temu, or a payment processor freezes their payouts. By then a federal court has already entered an order against a long, sealed list of storefronts, and the time to respond may already be running. The freeze is not a judgment. Courts are now looking much harder at these cases, and several defenses are working.
Bringing a counterfeiting case instead?Counterfeiting Claims →
- Calendar the deadline. Find the date you were served (or the date on the letter) and count the days: generally 21 in federal court, 20 in Florida state court.
- Preserve documents. Keep listings, ads, sales and sourcing records, emails, and messages. Do not delete posts or products; see Preservation Notices.
- Notify your insurer. Many business policies cover "personal and advertising injury." Give prompt written notice and send the complaint.
- Do not contact the plaintiff or its lawyers, and do not change your branding, listings, or website until you have advice.
- Find the case and the judge. Use the platform notice, PACER, or the plaintiff's service email to get the case number, court, and assigned judge, then check that judge's standing order.
- Read the order and follow it. A TRO usually bars selling the accused products and moving restrained funds. Comply while you challenge it.
- Send us the papers. Upload the complaint or demand; we review it the same business day after a conflict check.
A sealed list, a secret order, and a freeze you learn about last
"Schedule A" is not a law. It is the name of the exhibit where a brand owner lists the storefronts it is suing, often by the hundred. The procedure is built so that sellers find out only after their money is locked.
The brand owner files one complaint in federal court, usually for trademark counterfeiting and infringement under the Lanham Act, sometimes for copyright or design patent infringement. Instead of naming each seller in the caption, it attaches a list of store names, seller IDs, and marketplace links. It asks the court to seal that list so the sellers cannot see the case coming and move their money.
At the same time it asks for an ex parte temporary restraining order: an order granted without notice to you. Rule 65(b) allows that only on specific facts showing immediate and irreparable harm before the other side can be heard, and a TRO expires after no more than 14 days unless the court extends it for good cause or you consent (Fed. R. Civ. P. 65(b)(2)). The order usually bars sales of the accused products and directs Amazon, eBay, Walmart, Temu, PayPal, and other platforms and payment processors to restrain the accounts of every listed seller.
The platforms comply first and explain later. That is why most sellers learn of the case from a payout hold or an account notice, not from a court. Only then does the plaintiff serve the papers, usually by email or by posting them on a website, using permission the court gave under Fed. R. Civ. P. 4(f)(3), which allows service abroad "by other means not prohibited by international agreement, as the court orders."
Next comes a motion to convert the TRO into a preliminary injunction that keeps the freeze in place for the life of the case. Sellers who do not appear are defaulted. The plaintiff then asks for statutory damages, which for counterfeiting run from $1,000 to $200,000 per counterfeit mark per type of goods, and up to $2,000,000 if the use was willful (15 U.S.C. § 1117(c)). The judgment typically asks the court to order the platforms to transfer the restrained funds to the plaintiff.
Most of these cases are filed in the Northern District of Illinois in Chicago. Others are filed in Florida, New York, New Jersey, Pennsylvania, and elsewhere. From the brand owner's side, we describe the same model on Counterfeiting Claims.
Words you will see in the papers
- Schedule A: the sealed list of defendants. Your store name is on it.
- TRO: the first, short order that freezes accounts without notice.
- Preliminary injunction: the longer order that keeps the freeze until judgment.
- Asset restraint: the freeze on your marketplace and payment balances.
- Electronic service: how the court let the plaintiff deliver the complaint to you.
- Default: what happens if you do not respond in time.
- Before filingTest buys and screenshotsThe brand collects listing captures and, in better cases, completed purchases.
- Day 0Sealed complaintOne case, a long Schedule A, and a motion to seal.
- Day 1–5Ex parte TROGranted without notice; a bond is posted under Rule 65(c).
- Days laterPlatforms freezePayouts stop; listings may come down. This is when you find out.
- After the freezeEmail servicePapers arrive by email or a service website link.
- ~2–4 weeksPreliminary injunctionThe freeze is extended for the life of the case.
- Weeks to monthsDefault or settlementNon-appearing sellers are defaulted; funds may be transferred.
Timing varies by court and judge; the labels above describe a common sequence, not a rule.
Find the case, count the days, keep the records, and stay off the phone
Four things matter in the first days. None of them requires you to admit anything or to pay anything.
Get the case number and court
You cannot respond to a case you cannot identify. There are three usual routes:
- The platform notice. Amazon, eBay, Walmart, Temu, and payment processors usually cite the case number, the court, or the plaintiff's law firm when they restrain an account. Save the notice and any email from the platform's legal team.
- PACER. The federal courts' PACER Case Locator searches every district. Because the Schedule A list is often sealed at first, your store name may not appear; search by the brand owner's name instead. PACER charges $0.10 per page, capped at $3 per document, and waives fees for anyone who spends $30 or less in a quarter.
- The plaintiff's service email or website. If the court allowed electronic service, the plaintiff's email or service website link usually carries the complaint, the order, and the case number. Open it, save it, and note the date it was sent.
Count from service, not from the freeze
In federal court a defendant must answer or move within 21 days after being served (Fed. R. Civ. P. 12(a)(1)(A)(i)). Where the court authorized email service, the clock usually starts on the date the plaintiff sent the email or posted the papers, which may be days before you saw them. The docket's certificate of service shows the date the plaintiff claims.
Two other dates matter: the date the TRO expires and the date of the preliminary injunction hearing. You can ask the court to dissolve or modify a TRO on two days' notice to the plaintiff (Fed. R. Civ. P. 65(b)(4)). If the deadline is close, we can ask for an extension; courts often grant a reasonable first request, but you should never assume it.
Save the sales data before the platform hides it
Your best evidence lives in the marketplace back office, and restricted accounts sometimes lose access to reports. Download now:
- Order reports for the accused listing: units, dates, prices, and ship-to states
- The full listing history, including photos, titles, and ASIN or item IDs
- Supplier invoices, purchase orders, and any authorization from the brand
- Payout statements and the restrained balance on the freeze date
- Your business registration and physical address records
Do not delete listings, messages, or files. See Preservation Notices.
Let counsel make the first contact
Plaintiffs' firms in these cases often send a settlement figure by email and invite sellers to reply directly. Anything you write can be used as an admission of sales, of knowledge, or of contacts with the forum. Sellers who negotiate alone often agree to pay without knowing whether they have a jurisdiction, joinder, or evidence defense, and without terms that actually release the funds.
There is also a practical rule: in federal court a company may appear only through a licensed lawyer (Rowland v. California Men's Colony, 506 U.S. 194 (1993)). A filing by a company owner is likely to be disregarded.
Seven questions that shape your options
Answer these with your sales data in front of you. The answers tell us which defenses are realistic and whether settlement, a motion, or both make sense.
If yes, go straight to what can still be done after a default. Speed matters more than anything else on this page.
If not, the case against you may rest on a mistaken listing match. That supports a motion to dissolve the freeze as to you and, sometimes, a claim on the bond.
Reselling genuine goods bought from the brand or an authorized source is generally not counterfeiting. Invoices that trace the goods back to the brand matter more than any argument.
If your order reports show no sales into that state, personal jurisdiction is a serious question. If there was even one completed sale there, the defense is much weaker in the Seventh Circuit.
If so, a motion to narrow the freeze to the amount connected to the accused listings may free most of the balance while the case continues.
If you are an independent seller with no common owner, supplier, or payee, misjoinder is a strong argument in many courts, and some judges raise it on their own.
Two federal appeals courts now hold that email service in mainland China violates the Hague Service Convention where the Convention applies. That can defeat service and any default built on it.
Six arguments courts are accepting in Schedule A cases
None of these is automatic, and results vary by judge. Each depends on facts we can usually prove from your own records.
Improper joinder of unrelated sellers
Rule 20 lets a plaintiff sue defendants together only if the claims arise "out of the same transaction, occurrence, or series of transactions or occurrences" and share a common question (Fed. R. Civ. P. 20(a)(2)). Selling similar knockoffs of the same brand is not enough. Northern District of Illinois judges have repeatedly held that boilerplate allegations of an "interrelated group of counterfeiters" fail, and several now raise joinder on their own. In March 2026, in Collectanea J. Ltd. v. Partnerships and Unincorporated Associations Identified on Schedule "A", No. 25 C 4839 (N.D. Ill.), Judge Kocoras dissolved a preliminary injunction covering 252 sellers for misjoinder and required an amended complaint naming only defendants tied together by specific facts. Misjoined sellers may be dropped or severed into their own cases.
Fed. R. Civ. P. 20, 21Lack of personal jurisdiction
The plaintiff must show the court has power over you, seller by seller. In NBA Properties, Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022), an online store plus a completed sale shipped to Illinois was enough. In Liu v. Monthly, No. 25-2074 (7th Cir. Mar. 31, 2026), the court vacated a Schedule A default judgment because the record showed only checkout-page screenshots, not completed Illinois purchases; a website that is merely accessible in the state does not count. Courts in the district have continued to find one real sale into Illinois sufficient, so this defense turns on your order reports. Raise it in your first filing: it is waived if left out (Fed. R. Civ. P. 12(h)(1)).
Fed. R. Civ. P. 12(b)(2)A freeze bigger than the profits at issue
Federal courts generally cannot freeze assets just to secure a future money judgment (Grupo Mexicano de Desarrollo, S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999)). Freezes in counterfeiting cases rest on the plaintiff's request for an equitable accounting of the defendant's profits, which is why the Eleventh Circuit allowed one in Levi Strauss & Co. v. Sunrise Int'l Trading Inc., 51 F.3d 982 (11th Cir. 1995), and the Seventh Circuit applies the same limit (CSC Holdings, Inc. v. Redisi, 309 F.3d 988 (7th Cir. 2002)). If the plaintiff really seeks statutory damages, a legal remedy, the basis for a freeze weakens; in Eicher Motors (N.D. Ill. Aug. 8, 2025), Judge Kness refused a prejudgment freeze on that ground. Courts have also limited freezes to amounts tied to each defendant's accused sales and released the balances of sellers with no accused sales. Expect the burden to be on you to show which funds are not proceeds of the accused listings, which is why your sales data matters.
15 U.S.C. § 1117(a)An inadequate bond
A court may issue a TRO or preliminary injunction only if the plaintiff gives security "in an amount that the court considers proper to pay the costs and damages sustained by any party found to have been wrongfully enjoined or restrained" (Fed. R. Civ. P. 65(c)). Plaintiffs have often posted a single nominal bond for hundreds of sellers. Some judges now set a floor: Judge Durkin's published procedures presumptively require $1,000 per defendant in counterfeit product cases. A seller can ask the court to raise the bond to match the real harm of the freeze. If the restraint is later found wrongful, the bond is the usual source of recovery; in Bright Head, LLC v. Schedule A, No. 24 C 13410 (N.D. Ill. Feb. 13, 2026), the court held a dissolved TRO was wrongful but required detailed proof of lost profits.
Fed. R. Civ. P. 65(c)Thin evidence that the listing was counterfeit
A counterfeit is "a spurious mark which is identical with, or substantially indistinguishable from, a registered mark" (15 U.S.C. § 1127). Statutory damages under § 1117(c) apply only to counterfeits. Many Schedule A complaints rest on screenshots, keyword matches, or a product photo, with no test purchase and no inspection of the goods. If your product used no brand mark, used the word only to describe compatibility, or was genuine, say so with evidence. In Collectanea, eBay's review found that more than half of 50 sellers it checked had never sold an accused product.
15 U.S.C. § 1127Improper email service on sellers in China
China is a party to the Hague Service Convention and has objected to service through postal channels. In Smart Study Co. v. Shenzhenshixindajixieyouxiangongsi, 164 F.4th 164 (2d Cir. 2025), and Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., No. 25-2205 (7th Cir. May 29, 2026), the courts held that the Convention does not permit email service on defendants in mainland China. The Convention does not apply if the defendant's address could not be found with reasonable diligence, so the fight is often over what the plaintiff did to find you. Improper service can undermine a default and the judgment built on it.
Fed. R. Civ. P. 4(f)Where a seller has a defense on the merits, the general infringement defenses also apply; see Trademark Infringement Defense.
What judges have changed since 2025
The law here is moving month to month and differs from judge to judge, even within one courthouse. This is where things stand as of October 2026; we check the assigned judge's current standing order in every case.
| When | Court | What happened | Why it matters to a seller |
|---|---|---|---|
| July 2025 | N.D. Ill., Judge Gottschall | Standing order: counsel must be ready to show cause why joinder of many defendants complies with Rule 20(a)(2), and must show reasonable diligence in finding mailing addresses before email service | Joinder and service are tested at the start, not just when a seller objects |
| Aug. 8, 2025 | N.D. Ill., Judge Kness | Eicher Motors: TRO denied; prejudgment ex parte asset freezes rejected where no real equitable claim is pursued | Supports motions to dissolve or narrow a freeze |
| Sept. 25, 2025 | D.N.J., Chief Judge Bumb | Standing Order 2025-04: one defendant, or a group under the same operator, per complaint; no routine ex parte TROs or asset freezes; particularized showing before alternative service, including Hague compliance | Multi-seller complaints are sharply limited in that district |
| Dec. 18, 2025 | 2d Cir. | Smart Study: email service on mainland China defendants with known addresses not permitted | Service challenges for sellers in China |
| Mar. 31, 2026 | 7th Cir. | Liu v. Monthly: default judgment vacated; no proof of completed Illinois sales | Defaults can be undone where jurisdiction was never shown |
| Mar. 31, 2026 | N.D. Ill., Judge Kocoras | Collectanea: preliminary injunction dissolved as to all 252 sellers for misjoinder | The freeze falls with the joinder |
| Apr. 4, 2026 | N.D. Ill., Judge Gettleman | Standing order: joinder and personal-jurisdiction memo within two weeks of filing; Hague memo for foreign defendants before default | Plaintiffs must justify each seller early |
| May 29, 2026 | 7th Cir. | Kangol: the Hague Convention bars email service in mainland China; remanded on whether the address was unknown | Binding in the Northern District of Illinois |
| Current | N.D. Ill., Judge Durkin | Presumptive bond of $1,000 per defendant in counterfeit product cases; TRO declarations must state that each defendant sold to an Illinois customer | Larger bonds and a sale-based jurisdiction showing |
Other judges in the district use their own standing orders, and some still grant TROs and freezes on the traditional model. A ruling in one case does not bind another judge. Sources are listed at the end of this page.
How to judge a settlement demand against the frozen amount
Most Schedule A cases end in a default or a settlement. A settlement can be the right business decision, but only if you know what you are buying and how the money gets released.
The first demand is often a round number sent by email within days of the freeze. It is usually set with the frozen balance in mind, not your actual sales of the accused product. That does not make it wrong, but it means the figure needs testing against four things:
- Your real exposure on the merits. How many accused units you sold, of which listings, and for how much. Whether the goods carried the mark at all. Whether you have a jurisdiction, joinder, service, or evidence defense.
- Your exposure if you lose or default. Statutory damages for counterfeiting start at $1,000 per counterfeit mark per type of goods and can go far higher (15 U.S.C. § 1117(c)). Default judgments often award much more than a seller's sales. That risk is real, and it is why ignoring the case is the worst option.
- What a motion could free up. If a motion to narrow the freeze could release most of the balance, the pressure to pay the demand drops.
- The cost and time of contesting. A frozen account cannot fund inventory, and the case may run for months. We give you an estimate before you decide.
For a closer look at how money remedies are calculated, see Damages Evaluations and Responding to a Demand Letter.
Settlement math: an illustration
Illustrative only. These numbers are invented to show the method. They are not typical figures, and they do not predict any result.
| Frozen balance across all products | $24,000 |
| Accused listing: 38 units at $15 | $570 revenue |
| Plaintiff's first demand | $9,500 |
| Demand as share of frozen balance | 40% |
| Demand as multiple of accused revenue | ~16.7× |
| Returned to you if you pay the demand | $14,500 |
| Freed while the case continues, if a court narrows the freeze to accused revenue | $23,430 |
| Statutory floor if liability is found (one mark, one type of goods) | $1,000 |
Read together: the demand far exceeds the accused sales, but a loss or default could cost more than the demand. The answer depends on the defenses in your file, not on the numbers alone.
What the agreement should say
Who is released, and from what: all listings and all marks, or only those in the complaint. Whether payment comes out of the frozen balance. When and how the plaintiff will act to release the rest. Whether there is any admission. What you must stop selling.
Dismissal or consent judgment
Many settlements end with a voluntary dismissal of the seller. Some plaintiffs ask for a consent judgment: a court order, entered with your agreement, that usually includes a permanent injunction and sometimes a money figure. A consent judgment binds you going forward and is public, so its wording matters as much as the price.
Getting the funds released
Platforms act on court orders or on the plaintiff's written instruction under the order's terms. The usual path is a signed agreement, a filing that dismisses you or modifies the restraint as to your accounts, notice to the platform, and the platform's own release process. Timing varies by platform. We follow each step through, but no lawyer can promise when a platform will act.
If a default or default judgment has already been entered
A default is serious, but it is not always the end. The tools differ depending on whether only the clerk's "entry of default" has happened or a final default judgment has been entered.
| Question | Entry of default only | Final default judgment |
|---|---|---|
| Rule | Fed. R. Civ. P. 55(c): the court "may set aside an entry of default for good cause" | Fed. R. Civ. P. 55(c) and 60(b): relief from a final judgment on listed grounds |
| What you show | In the Seventh Circuit: good cause for the default, quick action to correct it, and a meritorious defense (Cracco v. Vitran Express, Inc., No. 07-3827 (7th Cir. Mar. 17, 2009)) | A Rule 60(b) ground: excusable neglect, fraud or misconduct, a void judgment (for example, no personal jurisdiction or invalid service), or another reason justifying relief |
| Time limit | None fixed, but delay counts against you | "Within a reasonable time," and for excusable neglect, new evidence, or fraud, no more than one year (Fed. R. Civ. P. 60(c)(1)) |
| Void judgments | Not applicable | The reasonable-time limit applies even when the judgment is claimed to be void (Coney Island Auto Parts Unlimited, Inc. v. Burton, U.S. Jan. 20, 2026) |
| Recent example | Many courts prefer decisions on the merits when a seller acts quickly | Liu v. Monthly (7th Cir. 2026): default judgment vacated for lack of personal jurisdiction; Kangol (7th Cir. 2026): denial of a motion to vacate reversed over email service in China |
◆ marks rows where the two situations differ in the rule that applies.
Practical points: if the funds have not yet been transferred, the first goal is usually to keep them where they are while the motion is decided. If they have been transferred, recovery is harder and may depend on the judgment being vacated. In either case, the motion must be supported by evidence, typically a sworn declaration with your sales records, address history, and the dates you learned of the case. Waiting to see what happens is the most expensive choice.
Most Schedule A cases are filed outside Florida
The Northern District of Illinois in Chicago handles the largest share. The Southern District of Florida also sees many, especially design-patent cases. Others are filed in New York, New Jersey, Pennsylvania, and elsewhere.
Northern District of Illinois
Robert Thornburg is admitted in Illinois and to the U.S. District Court for the Northern District of Illinois and the Seventh Circuit, which hears appeals from that court. We check the assigned judge's standing order on day one, because the rules on joinder, bonds, and service differ by courtroom.
Southern, Middle, and Northern Districts
Our attorneys are admitted in the Florida federal districts. Appeals go to the Eleventh Circuit, whose Levi Strauss decision on equitable asset freezes frames any challenge to a freeze there.
Other federal courts
In courts where none of our attorneys is admitted, we generally seek admission pro hac vice for the case, where the court's rules permit it, and work with local counsel where the court requires one. Rules differ by district, and we tell you at the outset what that will involve.
Marketplace and e-commerce disputes are led by James Leahy; Lanham Act litigation by Robert Thornburg. Florida local-counsel work for other firms is described on Local Counsel.
We work with sellers in Spanish
Si una plataforma congeló sus fondos por una demanda "Schedule A" en Estados Unidos, podemos revisar los documentos y explicarle sus opciones en español. Envíenos el aviso de la plataforma y cualquier correo con documentos judiciales. El plazo para responder suele contarse desde la fecha del correo, no desde la fecha en que usted lo vio.
Our attorneys work in English and Spanish. Many sellers in Latin America sell into the United States through U.S. marketplaces, and the papers arrive in English. Court papers, supplier records, and messages in other languages, including Chinese and Portuguese, are handled through qualified translators. Translations that will be filed with the court are prepared and certified as the court requires.
For sellers outside the United States
- A U.S. court can freeze your U.S. marketplace balance even if you have never visited the United States
- Your deadline runs on U.S. court time; time zones do not extend it
- Your company must appear through a U.S. lawyer admitted in that court or pro hac vice
- Have your business license and address records ready; they can matter to service and jurisdiction
Five most common mistakes sellers make in Schedule A cases
Waiting for the platform to fix it
Marketplaces generally will not release funds restrained by a court order without a further order or the plaintiff's instruction. Support tickets do not stop the court's clock.
Rule 12(a)Treat the platform notice as a court deadline and find the case the same day.
Answering without raising jurisdiction or service
Defenses of personal jurisdiction and service are waived if they are left out of the first motion or answer. Some sellers have lost them by filing a short answer on their own.
Rule 12(h)(1)Decide on every threshold defense before anything is filed.
Paying the first demand by email
Paying without a written agreement that dismisses you and directs the release of your funds can leave you paying and still frozen.
SettlementNever pay until the release mechanics are in the signed terms.
Moving money or relisting the product
The TRO binds parties who have actual notice of it. Opening a new storefront to sell the same item, or trying to move restrained funds, can lead to contempt and undercuts every equitable argument you have.
Rule 65(d)Comply with the order while you challenge it.
Losing the sales records
Narrowing a freeze, proving no sales into the forum, and showing the goods were genuine all depend on order data. Restricted accounts can lose access to reports.
EvidenceExport everything now, including ship-to states and supplier invoices.
How we handle a Schedule A defense
The order of work is set by the deadline and by the money that is frozen.
- Same dayIdentify the caseCourt, judge, case number, deadline, and the judge's standing order.
- Days 1–3Pull your dataAccused sales, ship-to states, frozen balance, supplier records.
- Days 2–5Choose the defensesJoinder, jurisdiction, service, freeze scope, bond, evidence.
- Before the deadlineAppear and moveAppearance, motion to dismiss or sever, motion to dissolve or narrow the freeze.
- In parallelTest the demandCounteroffer or decline, with release terms written in.
- Through releaseClose it outDismissal or consent judgment, notice to the platform, follow-up until funds move.
Defending is not only saying no
A defense can change the balance of a case. These are the tools we consider at the start, because some must be raised with the answer.
Damages on the injunction bond
If the restraint is found wrongful, the bond posted under Rule 65(c) is the usual source of compensation. Courts require real proof of lost profits, so we document the harm from the first day of the freeze.
Fed. R. Civ. P. 65(c)Attorney's fees in exceptional cases
The Lanham Act allows fees in exceptional cases. Northern District of Illinois judges have also awarded fees, including as sanctions, to sellers who were wrongly restrained or sued where there was no personal jurisdiction.
15 U.S.C. § 1117(a)Severance and dismissal
A misjoinder motion can split the case, end the shared freeze, and force the plaintiff to justify a claim against you alone, with its own filing fee and its own evidence.
Fed. R. Civ. P. 21Challenge the registration
Where the asserted mark is generic, abandoned, or was obtained by fraud, a court can order the registration cancelled in the same case.
15 U.S.C. § 1119Frequently asked questions
Why did Amazon (or eBay, Walmart, Temu, PayPal) freeze my account without telling me why?
In a Schedule A case the court orders the platforms to restrain the listed sellers' accounts before the sellers are told about the case. The platform is following a court order. Its notice usually names the case number, the court, or the plaintiff's law firm. Save it and send it to us.
When is my deadline to respond?
In federal court, generally 21 days after service. If the court allowed service by email or website posting, service usually happened on the date the plaintiff sent the email or posted the papers, which may be before you noticed. Check the docket's certificate of service, and treat the earliest possible date as your deadline until a lawyer confirms it.
Can I just pay the plaintiff and get my money back?
Many cases do settle. But payment without a signed agreement that dismisses you and requires the plaintiff to act to release your funds can leave you paying and still frozen. Before paying, test the demand against your sales, your defenses, and what a motion to narrow the freeze could release. See settlement.
I never sold the product they are complaining about. What now?
That is a strong fact. It supports a motion to dissolve the freeze as to you and may support a claim against the plaintiff's bond if the restraint is found wrongful. Export your full order history for the accused listing, or proof that no such listing existed, before access is limited.
I am in China. Was email service valid?
As of October 2026, the Second and Seventh Circuits hold that the Hague Service Convention does not permit email service on defendants in mainland China. The Convention does not apply if your address could not be found with reasonable diligence, so the answer depends on what the plaintiff knew and did. Raise service in your first filing or it may be waived.
Can I represent my company myself?
No. In federal court a company may appear only through a licensed lawyer (Rowland v. California Men's Colony, 506 U.S. 194 (1993)). An individual may appear for himself or herself, but the defenses in these cases are technical and easy to waive.
A default judgment was already entered. Is it too late?
Not necessarily. A final default judgment can be challenged under Rule 60(b), including as void for lack of personal jurisdiction or improper service, but the motion must be made within a reasonable time, and some grounds have a one-year limit. Move as soon as you learn of the judgment. See defaults.
The case is in Chicago. Do I need a Chicago lawyer?
You need counsel admitted in that court. Robert Thornburg is admitted to the Northern District of Illinois and the Seventh Circuit. In other districts we generally appear pro hac vice where the rules permit and work with local counsel where the court requires one.
Will a Schedule A case affect my seller account permanently?
A court restraint is separate from the platform's own policies, and platforms decide account standing under their own terms. A dismissal or settlement ends the court restraint, but it does not control what a platform does under its seller agreement. Keep records of the case outcome to support any appeal to the platform.
Upload the court papers or freeze notice
Send the platform's freeze notice, any email or link with court papers, and, if you have them, your order report for the accused listing and the frozen balance. Tell us where your business is located. We review uploads the same business day after a conflict check. Spanish is welcome.
- Identification of the case, judge, deadline, and standing order
- Motions to sever, dismiss, and dissolve or narrow the freeze
- Bond, service, and jurisdiction challenges
- Settlement terms written to release the funds
Prefer to talk first? Call or email, or message us on WhatsApp. Atendemos en español.
- Collectanea J. Ltd. v. Schedule A, No. 25 C 4839 (N.D. Ill. Mar. 31, 2026): PI dissolved as to 252 defendants (Chicago IP Litigation)
- Collectanea J. Ltd., No. 1:25-cv-04839 (N.D. Ill.), docket filing confirming caption and judge
- Liu v. Monthly, No. 25-2074 (7th Cir. Mar. 31, 2026), opinion
- Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., No. 25-2205 (7th Cir. May 29, 2026), opinion
- Reed Smith, After Smart Study: Smart Study Co. v. Shenzhenshixindajixieyouxiangongsi, 164 F.4th 164 (2d Cir. 2025)
- N.D. Ill., Judge Gottschall, Standing Schedule A Order (July 2025)
- N.D. Ill., Judge Gettleman, Schedule A Standing Order (Apr. 4, 2026)
- N.D. Ill., Judge Durkin, case procedures (counterfeit product cases; $1,000 per defendant bond)
- Potomac Law Group, Schedule A under fire (Eicher Motors; D.N.J. Chief Judge Bumb order; bonds; fee awards)
- Archer & Greiner, D.N.J. Standing Order 2025-04 requires Schedule A plaintiffs to bring their A game
- Mondaq, The splintering of the Schedule A litigation regime (Grupo Mexicano, CSC Holdings, joinder, S.D. Fla. volume)
- Levi Strauss & Co. v. Sunrise Int'l Trading Inc., 51 F.3d 982 (11th Cir. 1995)
- Bright Head, LLC v. Schedule A, No. 24 C 13410 (N.D. Ill. Feb. 13, 2026): TRO bond damages (Chicago IP Litigation)
- Coney Island Auto Parts Unlimited, Inc. v. Burton, No. 24-808 (U.S. Jan. 20, 2026)
- Federal Rules of Civil Procedure 20, 55 and 60 (text)
- Federal Rule of Civil Procedure 65 (text)
- Federal Rules of Civil Procedure, as amended to Dec. 1, 2025 (House Judiciary Committee print), Rule 4(f)
- Cracco v. Vitran Express, Inc., No. 07-3827 (7th Cir. 2009)
- Rowland v. California Men's Colony, 506 U.S. 194 (1993)
- NBA Properties, Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022) (commentary)
- Chicago IP Litigation, Oct. 2026 posts: Stussy (single Amazon sale to Illinois, June 2026); Chrome Hearts (severance, May 2026)
- PACER pricing: how fees work
General information, not legal advice for your situation. Statutes, rules, and fees as of October 2026. Last reviewed October 28, 2026.