Collectanea J. Limited v. The Partnerships and Unincorporated Associations Identified on Schedule "A"

Summary

The court granted nonparty eBay Inc.’s motion for relief from or modification of a preliminary injunction in a trademark and copyright infringement action involving 252 online seller defendants. The court held that eBay had standing to challenge the injunction’s obligations imposed on it, found the defendants improperly joined under Federal Rule of Civil Procedure 20, and dissolved the preliminary injunction as to all defendants. The plaintiff was ordered to file an amended complaint, amended Schedule A, and joinder memorandum by April 30, 2026.

Holdings

1. A nonparty bound by affirmative obligations in an injunction must have an opportunity to challenge those obligations; eBay therefore had standing to contest the portions of the preliminary injunction that directly affected its own interests.
2. A nonparty lacks standing to raise a joinder objection on behalf of named defendants whose rights, rather than the nonparty's own rights, are directly implicated.
3. The defendants were improperly joined because the complaint did not plausibly allege that their claims arose from the same transaction, occurrence, or series of transactions or occurrences, and shared infringement characteristics alone did not establish the required substantial evidentiary overlap.
4. The preliminary injunction had to be dissolved because Collectanea failed to carry its burden of showing imminent irreparable harm as to the improperly joined defendants, and the collective injunction and asset freeze could not remain in place while the case was restructured.

Questions Presented

1. Whether nonparty eBay had standing to challenge portions of the preliminary injunction that imposed affirmative duties on eBay.
2. Whether eBay could challenge joinder on behalf of the named defendants.
3. Whether the 252 defendants were properly joined under Federal Rule of Civil Procedure 20(a)(2).
4. Whether Collectanea established imminent irreparable harm sufficient to maintain the preliminary injunction.
5. Whether the preliminary injunction and collective asset freeze should be dissolved or modified.

Disposition

other