While Schedule A e-commerce trademark infringement complaints continue to surge in the Northern District of Illinois, a new development is bucking the trend’s trajectory. This new pattern, however, is not in filings, but dismissals.

Emoji Company, a particularly litigious plaintiff favoring the Schedule A defendant model, represented by Michael Hierl, Robert Mcmurray and William Kalbac of Hughes Socol Piers Resnick & Dym in Chicago, has dismissed 13 of their 14 pending cases cases this year, which is “highly unusual,” according to a defense attorney in one such legal action. Neither Hierl, Mcmuray or Kalbac responded to request for comment.