Seventh Circuit Limits Email Service to Chinese SAD Scheme Defendants–Kangol v. Hangzhou Silk

There have been thousands of SAD Scheme cases in the Northern District of Illinois, but this extensive litigation activity has produced only a small handful of Seventh Circuit opinions. This lack of appellate review has played a major role in perpetuating the SAD Scheme. District court judges have repeatedly found ways to rationalize bogus arguments from plaintiffs (often because no defendant was around to correct them), even dicey arguments that seemed unlikely to survive an appeal. I and other SAD Scheme critics have long suspected that most key principles of the SAD Scheme would fail once reviewed by appellate courts–if only we could find a way to get the cases there. This case is an example of that phenomenon. Many hundreds, or likely thousands, of Northern District of Illinois cases have authorized email service of process on Chinese defendants, collectively affecting tens or possibly hundreds of thousands of defendants. When the issue of email service to Chinese defendants…