What was filed

The complaint is Document 1 in No. 1:26-cv-12494, U.S. District Court for the Northern District of Illinois, Eastern Division, filed October 12, 2026 (51 pages). The plaintiff is Philips North America LLC, a Delaware company based in Andover, Massachusetts. The defendants are John W. Jordan II, also known as Jay Jordan; Reagan P. Hogerty; and JHP Management, Inc., a Delaware corporation based in Chicago, Illinois. Counsel for Philips is Reed Smith LLP. Philips demands a jury trial. The complaint says the case is related to Philips North America LLC v. Global Medical Imaging, LLC, No. 1:21-cv-03615 (N.D. Ill.). (Compl. pp. 1, 4 to 5, 50 to 51.)

What the complaint alleges

The complaint alleges that Philips imaging systems run copyrighted Philips software protected by access controls, including user-specific access codes, hardware keys, and machine-specific controls that enable only licensed features. It alleges that Jordan and Hogerty led an effort to acquire and consolidate service companies under Jordan Health Products, LLC, later rebranded Avante Health Solutions, that used methods to bypass those controls, including a key generator that Global Medical Imaging, LLC (GMI) used to enable Techadmin, Superuser, and First Responder access on Philips ultrasound systems. It alleges GMI kept using the key generator through February 2024. (Compl. paras. 1 to 2, 18 to 21, 30, 34 to 35, 39; pp. 1 to 2, 6 to 7, 9, 11 to 12.)

It alleges that Jordan and Hogerty caused the operating companies to take on $72,500,000 in loans, leaving them undercapitalized, and that JHP Management received at least $1.9 million from them in the 90 days before they filed for bankruptcy in In re Jordan Health Products I, Inc., No. 1:24-bk-12271 (Bankr. D. Del. Oct. 8, 2024). It says Philips learned of the defendants' roles from bankruptcy filings it obtained in October and November 2024 and from documents it first obtained in April and May 2025 from AHS Acquisition Holdings, LLC, which acquired the operating businesses out of bankruptcy. (Compl. paras. 2 to 4, 57, 66; pp. 2 to 4, 18, 22.)

Counts and relief

Count I alleges that GMI, Ultra Solutions, LLC, and Transtate Equipment Company, Inc. circumvented Philips access controls in violation of 17 U.S.C. 1201(a)(1) and trafficked in circumvention tools in violation of 17 U.S.C. 1201(a)(2), and that each defendant is vicariously liable because it had the right and ability to stop or limit that conduct and profited from it. It seeks relief under 17 U.S.C. 1203, including increased damages under 17 U.S.C. 1203(c)(4) based on alleged repeat violations by Transtate after an earlier judgment. Count II alleges vicarious liability for violations of 17 U.S.C. 1202(a) and 1202(b) on two theories: that the terms in a Philips ultrasound "licensed options file" are copyright management information under 17 U.S.C. 1202(c)(6) and that GMI and Ultra Solutions altered them to enable unlicensed features; and that Transtate used FDService to alter the terms stored in the "registry file" of Philips Allura systems to reach unlicensed field service software. It alleges, on information and belief, that each defendant had a direct financial interest in that conduct and the right and ability to supervise it or to stop or limit it. Count III alleges civil conspiracy to commit fraud and engage in unfair competition, and Count IV alleges unfair competition. (Compl. paras. 70 to 159; pp. 26 to 48.)

The prayer asks for judgment of vicarious liability under 17 U.S.C. 1201(a)(1), 1201(a)(2), and 1202 and liability for fraud and conspiracy, plus statutory damages, disgorgement, lost profits and license fees, attorneys' fees and costs under 17 U.S.C. 505, and exemplary and punitive damages. (Compl. pp. 48 to 50.)