On August 7, 2023, the United States Court of Appeals for the Seventh Circuit reversed in part a decision by the Northern District of Illinois, holding that an agreed forum selection clause applies only to the parties to the agreement and cannot be invoked by a co-defendant that did not have a similar agreement.  Nulogy Corp. v. Menasha Packaging Co., LLC, No. 22-1583, 2023 WL 5010784, at *1 (7th Cir. Aug. 7, 2023).  The Court reviewed the district court’s threshold determinations regarding the forum selection clause de novo.