Eric Goldman, a law professor at Santa Clara University, has been tracking trademark litigation on e-commerce sites such as Amazon and Wish for some time. About a decade ago, he began noticing that certain plaintiffs firms in the Northern District of Illinois were bringing intellectual property lawsuits against e-commerce sellers in bulk.

Many copied and pasted hundreds of complaints at one time against unnamed defendants and leveraged ex parte temporary restraining orders, along with weak spots in the Federal Rules of Civil Procedure to extract settlements from online sellers.