The complaint

Katy Anne Lynch v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 1:26-cv-13508 (N.D. Ill., Eastern Division), was filed November 2, 2026. The complaint is Document 1 and runs 8 pages. The plaintiff is Katy Anne Lynch, who describes herself as a professional illustrator and visual artist who has created art for over fourteen years. The defendants are the partnerships and unincorporated associations identified on Schedule A, which is Document 2 and lists 25 defendants by store name. The complaint pleads jurisdiction under the Copyright Act, 17 U.S.C. 101 et seq., 28 U.S.C. 1338(a)-(b), and 28 U.S.C. 1331, venue under 28 U.S.C. 1391, and personal jurisdiction based on the defendants' alleged targeting of Illinois and, additionally, under Federal Rule of Civil Procedure 4(k)(2). (Compl. 1 to 3, paras. 1 to 3, 8.)

The work

The complaint asserts one registered work, which it calls the Katy Anne Work, under U.S. Copyright Registration No. VA 2-476-431, with the certificate attached as Exhibit 1. (Compl. 2, para. 5; 4, para. 10.) The certificate and the Copyright Office public catalog record both show a work titled "Heart of the sea," a 2-D artwork, with Katy Anne Lynch as author and copyright claimant, completed in 2016 and first published January 19, 2016, in the United Kingdom. The certificate shows an effective date of registration of October 21, 2025, and a registration decision date of January 17, 2026. The complaint alleges, upon information and belief, that the copyright has an effective date that predates the defendants' acts of infringement. (Compl. 2, para. 5.)

What the complaint alleges

The complaint alleges that the defendants created numerous internet stores designed to appear to sell authorized products based on the work, and that they sold and continue to sell unauthorized derivative products through online marketplace listings. It alleges that the defendants' stores offer shipping to the United States, including Illinois, and accept payment in U.S. dollars, and it alleges, on information and belief, that the defendants reside in the People's Republic of China or other foreign jurisdictions and have sold products bearing infringing versions of the work to Illinois residents. It alleges the stores share unique identifiers, such as design elements and similarities in the products offered, which it says suggest that the defendants' operations arise out of the same transaction, occurrence, or series of transactions or occurrences. (Compl. 1 to 6, paras. 2, 6 to 7, 11, 16, 20.)

Claims and relief requested

Count I pleads copyright infringement. It alleges that each defendant, without permission, violated the plaintiff's "exclusive rights of reproduction, distribution, and public display under the Copyright Act," citing 17 U.S.C. 106(1), (2), (3), and (5), and that the plaintiff is entitled to relief under 17 U.S.C. 504, to attorneys' fees and costs under 17 U.S.C. 505, and, under 17 U.S.C. 502 and 503, to an injunction and an order that each defendant destroy all unauthorized copies. (Compl. 5 to 6, paras. 17 to 22.)

The prayer asks for temporary, preliminary, and permanent injunctions restraining use of the work and colorable imitations of it in connection with unauthorized products, passing off, further infringement, shipping or disposing of unauthorized inventory, and use of or control over the defendant internet stores and marketplace accounts; a judgment that the defendants willfully infringed the registered copyright under 17 U.S.C. 501 and otherwise injured the plaintiff's business reputation and business; actual or statutory damages under 17 U.S.C. 504, at the plaintiff's election, in an amount to be determined at trial; reasonable attorneys' fees and costs; and other relief the court deems just and proper. (Compl. 7 to 8.)

On the docket

The case was assigned on November 2, 2026, to Judge John Robert Blakey, with Magistrate Judge Daniel P. McLaughlin designated, by direct assignment. On November 3, 2026, the clerk's office mailed the copyright report to the Register of Copyrights in Washington, D.C. (ECF No. 11).