United States Court of Appeals For the Seventh Circuit ____________________ No. 22-2691 W. JAMES MAC NAUGHTON, Plaintiff-Appellant, v. ASHER VENTURES, LLC, et al., Defendants-Appellees. ____________________

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:17-cv-4050 — Martha M. Pacold, Judge. ____________________

ARGUED MAY 17, 2023 — DECIDED AUGUST 3, 2023 ____________________

Before RIPPLE, SCUDDER, and LEE, Circuit Judges. LEE, Circuit Judge. William James Mac Naughton, a New Jersey attorney, represented Shai Harmelech and his com- pany, USA Satellite & Cable, in a lawsuit filed by the Russian Media Group (“RMG”) against them in 2006 (the “RMG Ac- tion”). Mac Naughton stopped representing Harmelech and USA Satellite after they failed to pay his legal fees. The RMG Action eventually settled, and the settlement agreement was converted to a judgment (the