Avanti Press sues Schedule A sellers over greeting card images

The complaint

Avanti Press, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 1:26-cv-12262 (N.D. Ill.), was filed October 6, 2026. The complaint is Document 1, with the registration certificates attached as Exhibit 1, and the original Schedule A is Document 2. The complaint is signed by Keith A. Vogt of Keith A. Vogt PLLC in North Miami Beach, Florida, and six attorneys of JiangIP LLC in Chicago filed appearances for Avanti Press the same day. The case is assigned to Judge April M. Perry, with Magistrate Judge Karyn L. Bass Ehler designated. The complaint pleads jurisdiction under the Copyright Act and 28 U.S.C. 1331 and 1338 and venue under 28 U.S.C. 1391.

The parties and the works

The complaint describes Avanti Press as a greeting card publisher that makes humor cards with photography and imagery, often of animals, and says it prints its cards in the United States. It pleads ten registrations, VA 1-805-892, VA 2-455-555, VA 1-997-525, VA 1-843-169, VA 2-152-744, VA 2-098-723, VA 1-843-136, VA 2-468-855, VA 1-794-652 and VA 2-190-184, and alleges that Avanti Press owns them. It alleges, on information and belief, that the registrations predate the defendants' infringement.

What it alleges

The complaint alleges that the defendants are individuals and businesses that, on information and belief, reside in China or other foreign jurisdictions and run online stores designed to look like authorized sellers of Avanti Press products. It alleges the stores target Illinois, accept U.S. dollars and, on information and belief, have sold infringing products to Illinois residents. It alleges the stores share unique identifiers, such as design elements and similarities among the products offered, that it says suggest the defendants' operations arise out of the same transaction, occurrence, or series of transactions or occurrences.

Count I alleges that each defendant, without permission, sold pirated derivative works of the Avanti Press works through online marketplace listings, violating the exclusive rights of reproduction, distribution and public display, citing 17 U.S.C. 106(1), (2), (3) and (5), and seeks relief under 17 U.S.C. 502 through 505.

Relief sought

The complaint asks for temporary, preliminary and permanent injunctions barring use of the works and control of the defendant stores, a judgment of willful infringement under 17 U.S.C. 501, actual or statutory damages under 17 U.S.C. 504 at Avanti Press's election, and attorney's fees and costs.

Joinder and service orders

On October 8, 2026, Judge Perry directed Avanti Press to file the court's Schedule A Template within 14 days and, on the court's own motion, raised whether joining 200 defendants in one action is proper under Federal Rule of Civil Procedure 20(a)(2), citing Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020), and the court's opinion in Zaful v. Schedule A Defs., No. 24-cv-11111 (N.D. Ill. Jan. 10, 2025). The order gave Avanti Press until October 22, 2026 to file a supplemental memorandum explaining why each defendant is properly joined to all of the others or, in the alternative, an amended complaint with a smaller subset of defendants and a supporting memorandum. The same day, Avanti Press filed an amended Schedule A listing one defendant.

Avanti Press filed the Schedule A Template on October 23, 2026. It lists the defendant as a business operating a Temu store, with China as its country, and lists two other Schedule A cases Avanti Press filed in the Northern District of Illinois on October 6, 2026, Nos. 26-cv-12214 and 26-cv-12237. On October 26, 2026, noting that the defendant appears to be a Chinese corporation, the court directed Avanti Press to file a status report by November 16, 2026 on how it plans to serve the defendant in light of the Seventh Circuit's decision in Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., No. 25-2205 (7th Cir. May 29, 2026). The order says any request for electronic service must comply with Kangol and be supported by sworn affidavits and legal authority so the court can decide whether Avanti Press made reasonably diligent efforts to ascertain and verify the defendant's address.