Founder
On October 19, 2026, Judge Jorge Alonso of the Northern District of Illinois granted a motion to dismiss filed on behalf of my client in Imagination Products Corp. v. JY-Direct, No. 1:26-cv-00954. The court agreed that the plaintiff had not properly served this Schedule A defendant. The plaintiff had obtained permission to serve this store by email, bypassing the Hague Service Convention, on the theory that its address was “unknown.” Its only support was a declaration saying the listed address was an apartment building and that the defendant was “somewhere in China.” Applying the Seventh Circuit’s 2026 decision in Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., the court held that this was not the “reasonably diligent” effort required before a plaintiff may treat a foreign defendant’s address as unknown. Where a search turns up an identifiable physical location, the plaintiff must take further steps, such as sending an investigator there.
This ruling shows that Kangol has teeth: Schedule A plaintiffs can no longer rely on boilerplate “address unknown” declarations to skip formal international service, and defendants who were served this way before Kangol may have grounds to challenge it. We are proud of this result on behalf of our Schedule A defendant.