In a recent decision, the Northern District of Illinois denied a beauty salon’s motion to dismiss claims under the Trafficking Victims Protection Reauthorization Act (TVPRA), 18 U.S.C. §1595(a), the Trafficking Victims Protection Act of 2000 (TVPA), and various Illinois state law claims. The court found that the plaintiff plausibly alleged that the salon’s employee training program amounted to forced labor. The TVPA is a criminal statute.