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Illinois Recording Laws (2026): All-Party Consent Rules

Independently fact-checkedEditor-reviewedLaw current as of August 22, 2026By Recording Law Editorial TeamReviewed September 23, 202613 min read

Independently fact-checked against primary sources (last audited August 22, 2026). · Reviewed by the RecordingLaw editorial team. · Law checked current as of August 22, 2026. · 21 primary sources cited on this page. How we verify our legal content

Illinois Recording Laws (2026): All-Party Consent Rules

Illinois requires all-party consent before recording a private conversation under 720 ILCS 5/14-2. The law's pivotal word is "surreptitiously": secretly recording a private conversation where participants have a reasonable expectation of privacy is a felony, but openly recording a conversation you take part in does not meet the elements of the offense. Illegal recording is both a criminal felony and grounds for a civil lawsuit.

Illinois recording law at a glance

QuestionAnswer
Consent ruleAll-party consent required for private conversations
Main statute720 ILCS 5/14-2 (eff. Dec. 30, 2014, P.A. 098-1142)
When is recording illegal?Surreptitious recording of a conversation where participants reasonably expect privacy, without all-party consent
Criminal penalty (first offense)Class 4 felony: 1 to 3 years, up to $25,000 fine
Criminal penalty (subsequent offense)Class 3 felony: 2 to 5 years, up to $25,000 fine
Civil penaltyActual damages, punitive damages, injunctive relief, attorney fees (720 ILCS 5/14-6)
Hidden cameras / video voyeurismClass 4 felony (720 ILCS 5/26-4); Class 3 felony if victim is under 18 or offender is a registered sex offender
Recording police in publicPermitted and First Amendment-protected (ACLU v. Alvarez; 720 ILCS 5/14-2(e))

For a deeper explanation of any row, see the in-depth guides below.

Illinois audio recorder and headphones resting on a stack of legal documents

Recording in-person conversations in Illinois

Illinois is an all-party consent state, but the statute is more targeted than that label suggests. Under 720 ILCS 5/14-2, a person commits eavesdropping when they use an eavesdropping device "in a surreptitious manner, for the purpose of overhearing, transmitting, or recording all or any part of any private conversation" without the consent of all parties.

Two elements must both be present. First, the recording must be made surreptitiously: hidden, concealed, or done without the knowledge of the other participants. Second, the target must be a "private conversation," defined in 720 ILCS 5/14-1(d) as an oral communication where at least one party intended privacy and circumstances objectively justified that expectation.

If the recording is open, the surreptitious element is absent and no violation occurs. If the conversation is held in public, with no reasonable expectation of privacy, the private-conversation element is absent and no violation occurs. Both conditions must be satisfied for the statute to apply.

How Illinois arrived here: People v. Melongo and People v. Clark

Illinois's prior eavesdropping statute covered any conversation without consent, including fully public exchanges. On March 20, 2014, the Illinois Supreme Court unanimously struck down that version as unconstitutionally overbroad in a pair of companion rulings decided the same day, People v. Melongo, 2014 IL 114852, and People v. Clark, 2014 IL 115776, ruling that criminalizing the recording of public conversations violated the First Amendment. Melongo arose after a woman was prosecuted for recording phone calls with an administrator in the Cook County Court Reporter's Office and posting the recordings online; Clark arose from a recorded conversation with a judge and an attorney. Governor Quinn signed Senate Bill 1342 (P.A. 098-1142) in December 2014; the Act took effect on becoming law on December 30, 2014, creating the current framework: all-party consent remains the rule for private conversations, but the "surreptitiously" element and the privacy anchor were added to cure the constitutional defect.

What counts as a private conversation

Private conversations include a discussion in a closed office, a phone call between two people, a whispered exchange in a restaurant, a therapy session, or a meeting in a private home. Conversations that are not private include a speech at a public meeting, a loud argument on a sidewalk audible to passersby, officer commands during a public arrest, and statements at any proceeding open under the Illinois Open Meetings Act, 5 ILCS 120.

Public officials performing their official duties have no reasonable expectation of privacy in those duties. That is the statutory foundation for recording government officials in public, entirely separate from the First Amendment analysis addressed below.

The fear-of-crime exception

720 ILCS 5/14-3(i) allows a party to record without all-party consent when they have reasonable suspicion that another party is committing, has committed, or is about to commit a crime against the recording party or a household member. The exception requires both a subjective belief and an objective reasonableness standard, and is available only to private individuals, not law enforcement agents.

Recording phone calls in Illinois

Phone calls are private conversations under 720 ILCS 5/14-1(d): parties ordinarily expect calls to remain between themselves. All-party consent is therefore required before recording any telephone conversation, whether landline, cell, or VoIP.

The safest practice is to announce at the start of the call that you are recording and obtain verbal agreement before the substantive conversation begins. Courts generally treat continued participation after a clear, unambiguous announcement as implied consent. If any party objects, stop recording immediately.

When a call crosses state lines, the stricter law applies. Illinois's all-party consent requirement binds the Illinois party regardless of the other state's standard. If you cannot confirm all parties' locations, obtain consent from everyone on the call.

Our recording consent checker can help you compare Illinois's rule with the other party's state before a multi-state call.

For detailed rules on business call recording and AI transcription tools that may trigger BIPA, see the Illinois Phone Call Recording Laws spoke page.

Illinois dome security camera in the corner of an office ceiling

Hidden cameras, doorbells, and nanny cams

Video recording on your own property is generally lawful, subject to the placement rules discussed below. The key boundary is the expectation of privacy.

Authorized placement

Outdoor security cameras pointed at your own property, doorbell cameras covering a shared driveway or public sidewalk, and nanny cams in living areas where no privacy expectation exists are all lawful without consent from visitors. Illinois does not require advance notice for cameras on your own property in areas where people have no reasonable expectation of privacy.

Prohibited placement

720 ILCS 5/26-4 makes it a Class 4 felony to knowingly make a video recording or transmit live video of another person without consent in a restroom, tanning bed facility, locker room, changing room, or hotel bedroom, or to record another person in their residence without consent. The offense escalates to a Class 3 felony if the victim is under 18 or if the offender is a registered sex offender.

The audio caveat

A camera with a microphone that captures private conversations triggers the eavesdropping statute, 720 ILCS 5/14-2, on top of the voyeurism statute. A nanny cam recording conversations in a home is recording a private conversation where all parties have a reasonable expectation of privacy: all-party consent is required for the audio portion.

For additional guidance on camera placement and BIPA liability, see Illinois Security Camera Laws and Illinois Voyeurism and Hidden Camera Laws.

Penalties for illegal recording in Illinois

Criminal penalties for eavesdropping are set in 720 ILCS 5/14-4 (P.A. 098-1142, eff. Dec. 30, 2014):

OffenseClassPrison termMax fine
Basic eavesdropping, first offenseClass 4 felony1 to 3 years$25,000
Basic eavesdropping, subsequent offenseClass 3 felony2 to 5 years$25,000
Eavesdropping on law enforcement / state's attorney / AG / judge, first offenseClass 3 felony2 to 5 years$25,000
Eavesdropping on law enforcement / state's attorney / AG / judge, subsequent offenseClass 2 felony3 to 7 years$25,000
Corporate defendantSame classesSame prison termsUp to $50,000

Civil liability

In addition to criminal prosecution, the victim of illegal eavesdropping may sue under 720 ILCS 5/14-6 for injunctive relief, actual damages, punitive damages, and attorney fees and costs. Third parties who aided, abetted, or knowingly permitted the eavesdropping (including landlords, building operators, and carriers) are also subject to actual and punitive damages.

Illinois glass-walled conference room with figures behind translucent doors

Recording the police in Illinois

Illinois offers two independent layers of protection for openly recording police in public, making it one of the strongest positions in the country on this issue.

Constitutional protection: ACLU v. Alvarez

The Seventh Circuit Court of Appeals held in ACLU of Illinois v. Alvarez, 679 F.3d 583 (7th Cir. 2012), that the First Amendment protects the right to openly record police officers performing their duties in public places. Illinois is within the Seventh Circuit, making this ruling directly controlling precedent. Any attempt to re-criminalize open recording of police in public would face a First Amendment challenge under Alvarez.

Statutory codification

After Alvarez, Illinois added an explicit statutory exemption at 720 ILCS 5/14-2(e) (P.A. 99-352, eff. Jan. 1, 2016), providing that nothing in the eavesdropping article prohibits a person who is not a law enforcement officer from recording a law enforcement officer performing official duties in a public place or in circumstances with no reasonable expectation of privacy, though an officer may take reasonable action to maintain safety and control of the scene. The companion provision at 720 ILCS 5/26-4 tracks the same logic for video.

The recording must be open. Surreptitious recording of police communications without authorization remains subject to the enhanced penalties under 720 ILCS 5/14-4. Recording law enforcement radio or secured communications is not protected.

Practical guidance: record openly with your device visible, stay in a location where you have a lawful right to be, and do not interfere with officers' duties. See Illinois Laws on Recording Police for a full analysis.

Special topics in Illinois

Biometric Information Privacy Act (BIPA)

Illinois's Biometric Information Privacy Act, 740 ILCS 14, requires written consent before collecting, using, or storing biometric identifiers such as voiceprints, fingerprints, and facial geometry scans. Any recording tool that generates these identifiers from Illinois participants triggers BIPA obligations independently of the eavesdropping statute. BIPA provides a private right of action with statutory damages of $1,000 per negligent violation and $5,000 per reckless or intentional violation, with no requirement to prove actual harm. Class action exposure can be substantial: the $51.75 million Clearview AI settlement in 2025 illustrated the scale of liability for large-scale collection without proper consent.

Cruz v. Fireflies.AI Corp., No. 3:25-cv-03399-SEM-DJQ (filed December 2025), alleged that an AI meeting assistant's speaker-recognition feature collected voiceprints without BIPA-compliant written consent from non-account-holder participants. The plaintiff voluntarily dismissed the case without prejudice on March 11, 2026, so it is no longer pending. A complaint is an allegation, not a court ruling, so the case remains useful as an illustration of the BIPA theory plaintiffs are testing against AI meeting tools operating in Illinois, not as a decided legal standard.

Workplace recording: NLRB standards

Employer no-recording policies in Illinois are subject to federal labor law scrutiny under the Stericycle standard. In Stericycle, Inc. and Teamsters Local 628, 372 NLRB No. 113 (Aug. 2, 2023), the NLRB held that a challenged rule is presumptively unlawful if it has a reasonable tendency to chill employees from exercising their Section 7 rights, evaluated from the perspective of an economically dependent employee. Blanket no-recording policies that sweep in employees documenting unsafe conditions or discussing wages may be found presumptively unlawful.

NLRB Acting General Counsel William B. Cowen issued GC Memorandum 25-07 (June 25, 2025), directing regional offices to treat surreptitious recording of collective bargaining sessions as a per se violation of the duty to bargain in good faith under NLRA Sections 8(a)(5) and 8(b)(3). Separately, such recording also violates 720 ILCS 5/14-2 under state law. GC Memo 25-07 is prosecutorial guidance, not binding precedent. See Illinois Workplace Recording Laws for the full analysis.

HIPAA and FERPA overlays

Healthcare providers face a dual-consent obligation: the HIPAA Privacy Rule (45 CFR 164.502 and 164.508) governs the content of patient communications, while 720 ILCS 5/14-2 governs the act of recording. Both must be satisfied. Educational institutions face the same dual structure under FERPA (20 U.S.C. 1232g; 34 CFR Part 99): recordings that capture identifiable student information are education records requiring separate written consent, on top of the all-party consent requirement. See Illinois Medical Recording Laws and Illinois School Recording Laws.

Federal overlay (ECPA, FCC, CFPB)

Federal law applies alongside Illinois's stricter state standard, not in place of it. FCC Declaratory Ruling 24-17 (Feb. 8, 2024) extended TCPA prior-express-consent requirements to AI-generated voice-cloning calls: Illinois's all-party consent standard is stricter and controls for intrastate recordings. The FCC's One-to-One Consent Rule was vacated by the Eleventh Circuit in Insurance Marketing Coalition v. FCC, No. 24-10277 (Jan. 24, 2025), and the FCC accepted that ruling nationwide. 47 CFR 64.501 sets a federal beep-tone floor for carrier recordings of interstate calls; Illinois's standard supersedes it for private intrastate recordings. CFPB Regulation F (12 CFR 1006.100(b)) requires debt collectors to retain call recordings for three years: Illinois all-party consent must be obtained before any such recording is made.

Illinois wooden gavel on a sound block on a judge bench
  • Aug. 15, 2025: P.A. 104-0171 (HB1278) amended the Victims' Economic Security and Safety Act (VESSA), 820 ILCS 180, to prohibit employer retaliation against employees who use employer-issued devices to record crimes of violence against themselves or a family member. This is an employer-retaliation prohibition only: it does not amend 720 ILCS 5/14-2 or change consent requirements.
  • Nov. 21, 2025 (enrolled; effectively dead): HB1836 would have permitted the Attorney General to authorize one-party-consent eavesdropping in felony investigations. The Governor's 60-day deadline to act passed approximately January 20, 2026, with no Public Act number assigned. HB1836 does not change Illinois recording law.
  • Apr. 11, 2025 (stalled): SB1796 would have exempted body-camera recordings from the eavesdropping statute and adjusted destruction timelines. Re-referred to Assignments on April 11, 2025: it did not advance from committee and has not been enacted.
  • Dec. 2025 (voluntarily dismissed Mar. 2026): Cruz v. Fireflies.AI Corp. filed as a BIPA class action targeting AI meeting-assistant speaker-recognition. The plaintiff voluntarily dismissed the case without prejudice on March 11, 2026, before any ruling on the merits.

Illinois recording laws in depth

By type of recording

By place or relationship

For a national comparison, see the United States Recording Laws hub and the guide to one-party vs. all-party consent states.

More Illinois laws

This article is general legal information, not legal advice. Recording laws change and apply differently to each situation. For advice about your situation, consult a licensed Illinois attorney.

More Illinois Laws

Frequently Asked Questions

Is Illinois a one-party or two-party consent state?

Neither label fits precisely. Illinois requires all-party consent under 720 ILCS 5/14-2, but only for conversations where participants have a reasonable expectation of privacy. Conversations with public officials on duty, or in public spaces where no privacy expectation exists, can be recorded without consent. The 'two-party consent' label is commonly used but technically imprecise: the law covers all parties, not just two.

Can I record a phone call in Illinois?

Only with the consent of all parties to the call. Phone calls are treated as private conversations under 720 ILCS 5/14-1(d) because participants ordinarily expect them to remain between themselves. Recording without consent is a Class 4 felony for a first offense. The safest approach is to announce you are recording at the start of the call and obtain verbal agreement from everyone before continuing.

Can I secretly record someone if I think they are committing a crime?

Yes, under the fear-of-crime exception at 720 ILCS 5/14-3(i). A party to a conversation may record without all-party consent if they have reasonable suspicion that another party is committing, is about to commit, or has committed a crime against the recording party or a household member. Both a subjective belief and an objective reasonableness standard are required. This exception is available to private individuals, not law enforcement.

What is the penalty for illegal recording in Illinois?

Under 720 ILCS 5/14-4, a first-offense eavesdropping violation is a Class 4 felony (1 to 3 years in prison, up to $25,000 fine). A subsequent offense is a Class 3 felony (2 to 5 years). Secretly recording a law enforcement officer, state's attorney, or judge is a Class 3 felony for a first offense (2 to 5 years) and a Class 2 felony for a subsequent offense (3 to 7 years).

Can I record police in Illinois?

Yes. The Seventh Circuit held in ACLU v. Alvarez, 679 F.3d 583 (7th Cir. 2012), that openly recording police performing public duties is protected by the First Amendment. Illinois codified this right at 720 ILCS 5/14-2(e) (P.A. 99-352, eff. Jan. 1, 2016). Alvarez involved open recording, and the injunction the court ordered covered openly recording officers on duty in public places, though the court said it was not suggesting the First Amendment protects only open recording. Record openly and do not interfere with officers' duties.

Are Ring doorbells and nanny cams legal in Illinois?

Yes, for video coverage of areas where people have no reasonable expectation of privacy (your doorstep, driveway, or exterior). Cameras placed to record in restrooms, locker rooms, changing rooms, or other private areas are a Class 4 felony under 720 ILCS 5/26-4. Nanny cams with active microphones recording private home conversations also trigger the all-party consent requirement under 720 ILCS 5/14-2 for any audio they capture.

Can I record my boss or an HR meeting in Illinois?

Probably not without consent. A private meeting in a closed office is a 'private conversation' under 720 ILCS 5/14-1(d), and secretly recording it is a Class 4 felony. If you have reasonable suspicion your employer is about to commit a crime against you (such as threats or harassment), the fear-of-crime exception at 720 ILCS 5/14-3(i) may apply. Consult an attorney before recording workplace conversations without consent.

Does BIPA apply to AI meeting recorders used with Illinois participants?

Potentially yes. BIPA (740 ILCS 14) requires written consent before collecting biometric identifiers such as voiceprints. Cruz v. Fireflies.AI Corp. (filed December 2025) alleged that an AI meeting assistant's speaker-recognition feature collected voiceprints without BIPA-compliant consent, but the plaintiff voluntarily dismissed the case without prejudice on March 11, 2026, so it is no longer active. Organizations using AI meeting tools with Illinois participants should still confirm whether the tool generates voiceprints and whether BIPA-compliant consent has been obtained.

Updates

Corrected the descriptions of People v. Melongo and ACLU v. Alvarez to match what the opinions actually say about who was recorded and what the Seventh Circuit decided.

Corrected the effective date of P.A. 98-1142 to December 30, 2014 (it took effect on becoming law, not January 1, 2015) everywhere it appeared, repaired five broken or misrouted links to the Illinois Compiled Statutes and the Biometric Information Privacy Act, and confirmed the Cruz v. Fireflies.AI docket was voluntarily dismissed on March 11, 2026.

Corrected the citation for Illinois's statutory right to record on-duty police: the page previously pointed to 720 ILCS 5/14-3(i) (which is actually the unrelated fear-of-crime recording exception); the real police-recording exemption is 720 ILCS 5/14-2(e). Also fixed the fear-of-crime exception's own citation, which had been mislabeled 14-3(h), and replaced a dead Open Meetings Act citation link.

Independently fact-checked against the cited primary sources; governing law re-checked for recent changes

Governing law re-checked for recent changes

Reviewed and approved by an editor

Restructured page per recording-redo template spec: condensed 5,500-word dense article to readable format with short paragraphs; added AEO lede, at-a-glance table, and in-depth index; split consent-rule, phone-call, hidden-camera, and police sections; consolidated special-topics (BIPA, NLRB/Stericycle, HIPAA/FERPA, federal overlay) into tight subsections; added attorney fees to civil-remedy list (720 ILCS 5/14-6); confirmed penalty classes, consent elements, and HB1836 dead-bill status against primary sources; preserved all statute citations; refreshed FAQ with 8 questions; updated hero and inline images.

Corrected penalty classifications to current 720 ILCS 5/14-4 (P.A. 98-1142, eff. Dec. 30, 2014): basic eavesdropping is a Class 4 felony (1-3 years) for a first offense and Class 3 felony (2-5 years) for a subsequent offense; eavesdropping on law enforcement is a Class 3 felony (2-5 years) for a first offense and Class 2 felony (3-7 years) for a subsequent offense. Updated lede, KeyTakeaways, summary table, Penalties section and table, and FAQ answers accordingly.

Refreshed per post-Clark dossier. Added Federal Law Overlay section (FCC 24-17, FCC One-to-One vacatur, 47 CFR 64.501, DOJ JM 9-7.302, CFPB Reg F). Added Special Contexts section (HIPAA dual-consent, FERPA dual-consent, BIPA, Cruz v. Fireflies.AI pending litigation). Added Current Developments 2025-2026 section (P.A. 104-0171 VESSA amendment, HB1836 effectively dead, SB1796 stalled). Added 12-spoke Topic Index. Corrected penalty framing to Class 2 felony / up to 5 years per 720 ILCS 5/14-4. Corrected fear-of-crime citation to 14-3(h). Fixed broken link markup from prior AI wearables section. Title and meta rewrite per dossier proposal. Word count expanded from 3,387 to approximately 5,500 words.

Refreshed per post-Clark dossier. Added Federal Law Overlay section (FCC 24-17, FCC One-to-One vacatur, 47 CFR 64.501, DOJ JM 9-7.302, CFPB Reg F). Added Special Contexts section (HIPAA dual-consent, FERPA dual-consent, BIPA, Cruz v. Fireflies.AI pending litigation). Added Current Developments 2025-2026 section (P.A. 104-0171 VESSA amendment, HB1836 effectively dead, SB1796 stalled). Added 12-spoke Topic Index.

Added wearable recording device guidance covering AI voice recorders (Plaud), smart glasses (Meta Ray-Bans), and Illinois BIPA biometric privacy implications.

Previous version published with post-Clark statutory analysis and police recording section.

Sources and References

  1. 720 ILCS 5/14-2(a)(1) (eff. Dec. 30, 2014, P.A. 098-1142)(ilga.gov).gov
  2. 720 ILCS 5/14-1(d) (eff. Dec. 30, 2014, P.A. 098-1142)(ilga.gov).gov
  3. ACLU of Illinois v. Alvarez, 679 F.3d 583 (7th Cir. 2012)(rcfp.org)
  4. Illinois P.A. 104-0171 (HB1278), amending 820 ILCS 180/ (VESSA), eff. Aug. 15, 2025(hinshawlaw.com)
  5. Illinois HB1836, 104th General Assembly (2025-2026), enrolled Nov. 21, 2025(ilga.gov).gov
  6. Illinois SB1796, 104th General Assembly (2025-2026), re-referred Apr. 11, 2025(ilga.gov).gov
  7. Cruz v. Fireflies.AI Corp., No. 3:25-cv-03399-SEM-DJQ (filed Dec. 18, 2025) (voluntarily dismissed without prejudice Mar. 11, 2026)(commlawgroup.com)
  8. FCC 24-17, Declaratory Ruling, CG Docket No. 23-362 (Feb. 8, 2024)(fcc.gov).gov
  9. FCC Second Report and Order, CG Docket No. 21-402; Insurance Marketing Coalition v. FCC, No. 24-10277 (11th Cir. Jan. 24, 2025) (vacating rule), mandate issued Apr. 30, 2025(wiley.law)
  10. 47 C.F.R. § 64.501(ecfr.gov).gov
  11. DOJ Justice Manual § 9-7.302; Attorney General Memorandum (May 30, 2002)(justice.gov).gov
  12. Stericycle, Inc. and Teamsters Local 628, 372 NLRB No. 113 (Aug. 2, 2023)(kutakrock.com)
  13. NLRB GC Memo 25-07 (June 25, 2025)(nlrb.gov).gov
  14. 12 CFR § 1006.100(b) (CFPB Regulation F)(consumerfinance.gov).gov
  15. 45 CFR § 164.502; HHS OCR, HIPAA Privacy Rule Summary (hhs.gov); HHS OCR Guidance on Audio-Only Telehealth (2022)(hhs.gov).gov
  16. FERPA, 20 U.S.C. § 1232g; 34 CFR §§ 99.3, 99.30; USDOE Student Privacy Policy Office guidance (studentprivacy.ed.gov)(studentprivacy.ed.gov).gov
  17. 720 ILCS 5/14-3, Exemptions from eavesdropping prohibition(ilga.gov).gov
  18. 720 ILCS 5/14-4, Penalties for eavesdropping (P.A. 098-1142, eff. Dec. 30, 2014)(ilga.gov).gov
  19. 720 ILCS 5/14-6, Civil remedies for eavesdropping(ilga.gov).gov
  20. 720 ILCS 5/26-4, Unauthorized video recording and live video transmission(ilga.gov).gov
  21. ACLU of Illinois v. Alvarez, 679 F.3d 583 (7th Cir. 2012)(courtlistener.com)
  22. People v. Clark, 2014 IL 115776 (Ill. Sup. Ct. 2014) (striking down prior eavesdropping statute)(courtlistener.com)
  23. Illinois P.A. 098-1142 (SB 1342), creating current 720 ILCS 5/14-2 (eff. Dec. 30, 2014)(ilga.gov).gov
  24. Illinois P.A. 104-0171 (HB1278), amending 820 ILCS 180 (VESSA), eff. Aug. 15, 2025(ilga.gov).gov
  25. Illinois HB1836, 104th General Assembly (2025-2026), enrolled Nov. 21, 2025 (effectively dead; no PA number assigned)(ilga.gov).gov
  26. 740 ILCS 14, Illinois Biometric Information Privacy Act (BIPA)(ilga.gov).gov
  27. Stericycle, Inc. and Teamsters Local 628, 372 NLRB No. 113 (Aug. 2, 2023)(nlrb.gov).gov
  28. 5 ILCS 120, Illinois Open Meetings Act(ilga.gov).gov
  29. Cruz v. Fireflies.AI Corp., No. 3:25-cv-03399 (C.D. Ill.) (filed Dec. 18, 2025; voluntarily dismissed without prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i), case terminated Mar. 11, 2026)(courtlistener.com)
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