Currently, the Northern District of Illinois judges do not apply consistent standards for SAD Scheme joinder. Some judges still permit the joinder of dozens or hundreds of seemingly unrelated defendants in a single case; other judges essentially make SAD Scheme joinder impossible. When SAD Scheme plaintiffs file their complaints, they don’t know in advance how the randomly assigned judge will respond to naming a cornucopia of unrelated defendants.

The plaintiffs’ short-term solution has been to start with the whole enchilada of defendants and, if the assigned judge will scrutinize joinder, immediately voluntarily dismiss all but one of the defendants. I’ll call this the “spray-and-pray” approach to naming SAD Scheme defendants.

Then, after narrowing the initial complaint to one defendant, the plaintiff can resue the voluntarily dropped defendants in a new bulk lawsuit. I’ll call this the “serial spray-and-pray” approach (SSP for short?). Depending on what disclosures the plaintiff makes about the dropped-and-resued defendants and how courts handle assignments of related cases, the sequential complaint may go back into the random judicial assignment process. With luck, the plaintiff will draw a new judge who’s more permissive about joinder and the plaintiff can proceed with an old-school SAD Scheme.

This week, Judge Blakey called out the Greer Burns & Crain law firm for serial spraying-and-praying. He summarizes: “In this case, Plaintiff has attempted to join defendants it has already thrice conceded (twice before Judge Alexakis and once before Judge Chang) may not properly be joined in one suit.”

Judge Blakey treats serial spraying-and-praying as impermissible judge-shopping (emphasis added):

repeatedly naming the exact same group or subgroup of defendants in new cases until a case is assigned to a judge the Plaintiff believes to be hospitable to Plaintiff’s own theory of joinder constitutes a willful abuse of the judicial process. If Plaintiff had a good faith factual and legal basis to join these defendants, it could have pressed its position in any of the prior cases before the assigned judge (and appealed in due course if appropriate), but it declined to do so. Instead, when challenged, Plaintiff cut and ran, then filed new suit, seeking to join the same parties based upon the same allegations. That strategy not only constitutes an egregious form of forum shopping, it also consumes scarce judicial resources, as Plaintiff asks judge after judge to make the same exact determination, hoping for a more favorable outcome.

Harsh words. So how did Judge Blakey punish Greer Burns for its willful abuse and egregious forum-shopping that wasted the time of multiple judges? He dismissed the lawsuit with prejudice and….

…and that’s it. If you were expecting more punishment, then you haven’t been paying close attention to the consistently anemic consequences that judges impose for bogus and abusive SAD Scheme practices. With virtually no real downsides to serial spraying-and-praying, what are the odds that this “sanction” will prompt Greer Burns or other law firms to improve their practices? 👌

At minimum, I think every time a judge calls out lawyers for a “willful abuse of the judicial process,” a referral to the state bar should follow as a matter of course. There needs to be some real accountability somewhere.

Case Citation: Marshall Amplification PLC v. Xingrunshangmao, 1:25-cv-13829 (N.D. Ill. Jan. 12, 2026)

Prior Blog Posts on the SAD Scheme

• Schedule A: Ten Notable Developments in 2025 (Guest Blog Post)
• Second Circuit Rejects Email Service on Chinese Defendants in Baby Shark SAD Scheme Case
• 11th Circuit Sidesteps the SAD Scheme’s Problems–Ain Jeem v. Schedule A
• Another Shill Article Tries to Normalize the SAD Scheme
• Court Sanctions Plaintiff’s Lawyer for Unverified Claims That the Defendant Was Hiding–Guangzhou Youlan Technology Co. Ltd. v. Onbrill World
• SAD Scheme Cases Are a Cesspool of IP Owner Overreaches–Nike v. Quanzhou Yiyi Shoe Industry
• District of New Jersey Adopts SAD Scheme Standing Order
• Court “Sanctions” SAD Scheme Judge Shopping—Crimpit v. Schedule A Defendants
• Chicago-Kent SAD Scheme Symposium TOMORROW
• Amicus Brief Urges Seventh Circuit to Award Attorneys’ Fees in SAD Scheme Case–Louis Poulsen v. Lightzey
• Court Rejects Schedule A Claims Against Sellers of Compatible Parts/Accessories (Cross-Post)
• Judge Kness: the SAD Scheme “Should No Longer Be Perpetuated in Its Present Form”–Eicher Motors v. Schedule A Defendants
• SAD Scheme Lawyers Sanctioned for Judge-Shopping–Dongguan Deego v. Schedule A
• Judge Ranjan Cracks Down on SAD Scheme Cases
• Because the SAD Scheme Disregards Due Process, Errors Inevitably Ensue–Modlily v. Funlingo
• SAD Scheme-Style Case Falls Apart When the Defendant Appears in Court—King Spider v. Pandabuy
• Serial Copyright Plaintiff Lacks Standing to Enforce Third-Party Copyrights–Viral DRM v 7News
• Another N.D. Ill. Judge Balks at SAD Scheme Joinder–Zaful v. Schedule A Defendants
• Judge Rejects SAD Scheme Joinder–Toyota v. Schedule A Defendants
• Another Judge Balks at SAD Scheme Joinder–Xie v. Annex A
• Will Judges Become More Skeptical of Joinder in SAD Scheme Cases?–Dongguan Juyuan v. Schedule A
• SAD Scheme Leads to Another Massively Disproportionate Asset Freeze–Powell v. Schedule A
• Misjoinder Dooms SAD Scheme Patent Case–Wang v. Schedule A Defendants
• Judge Hammers SEC for Lying to Get an Ex Parte TRO–SEC v. Digital Licensing
• Judge Reconsiders SAD Scheme Ruling Against Online Marketplaces–Squishmallows v. Alibaba
• N.D. Cal. Judge Pushes Back on Copyright SAD Scheme Cases–Viral DRM v. YouTube Schedule A Defendants
• A Judge Enumerates a SAD Scheme Plaintiff’s Multiple Abuses, But Still Won’t Award Sanctions–Jiangsu Huari Webbing Leather v. Schedule A Defendants
• Why Online Marketplaces Don’t Do More to Combat the SAD Scheme–Squishmallows v. Alibaba
• SAD Scheme Cases Are Always Troubling–Betty’s Best v. Schedule A Defendants
• Judge Pushes Back on SAD Scheme Sealing Requests
• Roblox Sanctioned for SAD Scheme Abuse–Roblox v. Schedule A Defendants
• Now Available: the Published Version of My SAD Scheme Article
• In a SAD Scheme Case, Court Rejects Injunction Over “Emoji” Trademark
• Schedule A (SAD Scheme) Plaintiff Sanctioned for “Fraud on the Court”–Xped v. Respect the Look
• My Comments to the USPTO About the SAD Scheme and Anticounterfeiting/Antipiracy Efforts
• My New Article on Abusive “Schedule A” IP Lawsuits Will Likely Leave You Angry
• If the Word “Emoji” is a Protectable Trademark, What Happens Next?–Emoji GmbH v. Schedule A Defendants
• My Declaration Identifying Emoji Co. GmbH as a Possible Trademark Troll