Schedule A copyright case over animal illustrations: appearing sellers found misjoined, and one asset restraint capped at $38.48

The orders

Both orders are in Alison Friend v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 1:26-cv-05581 (N.D. Ill.), before Judge Charles P. Kocoras. Document 102, dated October 21, 2026, decides a motion to dismiss by lacemylife.com and favomens.com, which the order calls Magic Matrix. Document 103, dated October 22, 2026, decides the preliminary injunction motion against amoiss.com and its requests for dismissal.

The case

The plaintiff, Alison Friend, is an artist who the October 22 order says owns thirteen federal copyright registrations for her animal illustrations. She sued 34 defendants, alleged to be foreign entities selling products in connection with her illustrations through online stores, alleging violations of the reproduction, distribution, and public display rights under 17 U.S.C. 106. The court granted an ex parte TRO on May 15, 2026 and, on June 10, 2026, a preliminary injunction against all defendants but three, one of which was amoiss.com.

October 21: jurisdiction found, joinder rejected

The plaintiff produced invoices for purchases from lacemylife.com and favomens.com with Chicago shipping addresses and tracking information, and alleges that the two sites sold and shipped shirts bearing her illustrations to Chicago. Applying NBA Properties v. HANWJH, the court held that test purchases count because the sellers structured their online stores to take and ship Illinois orders, found a prima facie showing of specific jurisdiction, and denied the Rule 12(b)(2) motion. On Rule 20(a)(2), it held that unrelated defendants infringing the same works in the same way are not part of the same transaction or occurrence, and that sellers who appear and challenge joinder distinguish themselves from the rest of the defendants. It declined to dismiss and instead severed the claims, directing the Clerk to open a new case, Alison Friend v. lacemylife.com and favomens.com, assigned to Judge Kocoras and Magistrate Judge Jantz as a related case, with a new filing fee and a complaint limited to the allegations against those two defendants.

October 22: preliminary injunction with a capped asset restraint

The court granted the preliminary injunction motion against amoiss.com except to the extent it sought an overbroad asset restraint. It found a likelihood of success on the merits, which amoiss.com did not contest, and irreparable harm despite amoiss.com's sworn promise not to sell the accused shirt again. The account restrained under the TRO held $17,625.67; amoiss.com said it made $38.48 from the accused product and submitted store screenshots showing one sale. Holding that the plaintiff, as the moving party, had not identified amoiss.com's infringement proceeds with enough specificity to justify freezing the whole account, the court limited the restraint to $38.48 "for now." It allowed a later motion to modify the restraint if limited discovery uncovers evidence of additional profits, and ordered a revised proposed preliminary injunction order by October 30, 2026.

It rejected amoiss.com's service argument at this stage, holding that Rule 65(a) requires notice, which amoiss.com had because it appeared and opposed the motion; it said it would consider Hague Service Convention arguments under the Seventh Circuit's May 29, 2026 Kangol decision if raised in a motion to dismiss. It held amoiss.com improperly joined and said it will sever the claims against amoiss.com into a new case, with a new filing fee, but will first wait to see whether the parties can resolve the matter; their joint status report on that is due November 6, 2026.