This case was last updated from U.S. District Courts on 07/23/2022 at 09:45:23 (UTC).

Allegiant Travel Company v. R2 Solutions LLC

Case Summary

On May 24, 2022, Allegiant Travel Company (“Allegiant” or “Plaintiff”), represented by Patrick H. Hicks and Kelsey Stegall of Littler Mendelson, P.C., Michael Oblon, Keith Davis and H. Albert Liou of Jones Day, filed an intellectual property lawsuit against R2 Solutions LLC (“R2” or “Defendant”), seeking declaratory relief for alleged non-infringement of U.S. patents. This case was filed in the U.S. District Court for the District of Nevada with Judges Cristina D. Silva and Brenda Weksler presiding. 

Plaintiff filed this action seeking declaratory judgment for the non-infringement of U.S. Patent Nos. 7,698,329 (“the ’329 Patent”); 8,190,610 (“the ’610 Patent”); 8,307,029 (“the ’029 Patent”); 8,527,623 (“the ’623 Patent”); 9,558,175 (“the ’175 Patent”); 10,176,272 (“the ’272 Patent”); and 8,341,157 (“the ’157 Patent”) (collectively, the “Patents-in-Suit”). 

The complaint stated that “Allegiant seeks this relief because Defendant R2 Solutions LLC (“R2”), has accused Allegiant of infringing the Patents-in-Suit and has engaged in a patent enforcement campaign resulting in 22 lawsuits. R2’s actions have placed a cloud over Allegiant and its technology platforms. Allegiant believes it is not infringing the Patents-in-Suit and therefore asks this Court to declare Allegiant’s legal rights so that Allegiant may be granted relief from the uncertainty regarding its rights caused by Defendant.”

Plaintiff alleged that “R2’s correspondence to Allegiant and its numerous patent lawsuits against other companies has placed Allegiant in reasonable apprehension of a lawsuit against Allegiant regarding the alleged infringement of R2’s patents.”

Plaintiff also alleged that “through its communications Allegiant’s officers, employees, and lawyers described above, as well as its extensive patent enforcement campaign against various companies implicating their websites and music applications with search functionality, mobile applications, data analytics platforms, and other information technology platforms, R2 has created a real and immediate controversy between Allegiant and R2 regarding the alleged infringement of R2’s patents by Allegiant’s technologies. Allegiant risks a lawsuit by continuing to use its technologies, including its www.allegiantair.com website, mobile application, and other information technology platforms.”

Plaintiff then alleged that “R2’s actions have thus created a substantial controversy of sufficient immediacy and reality regarding Allegiant’s use of its technologies to warrant the issuance of a declaratory judgment of non-infringement.”

The plaintiff presented seven claims for relief alleging non-infringement of the patents-in-suit. 

In the prayer for relief, Plaintiff requested a declaration that Allegiant is not infringing the patents-in-suit and for an award of the reasonable attorney’s fees, costs, and expenses incurred by Allegiant in this action.

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    2:22-CV-00828

  • Filing Date:

    05/24/2022

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Cristina D. Silva

Referral Judge

Brenda Weksler

 

Party Details

Plaintiff

Allegiant Travel Company

Defendant

R2 Solutions LLC

Attorney/Law Firm Details

Plaintiff Attorneys

H Albert Liou

Keith Bryan Davis

Kelsey Stegall

Michael Oblon

Patrick H. Hicks

Defendant Attorneys

Carder W. Brooks

Christopher G. Granaghan

Edward R Nelson, III

John Murphy

Joseph R Ganley

 

Court Documents

#27

(#27) MOTION to Seal Document, #26 Motion to Dismiss,,, by Defendant R2 Solutions LLC. Responses due by 7/28/2022. (Nelson, Edward) (Entered: 07/14/2022)

26 #5

Exhibit E (Public Version)

26 #4

Exhibit D (Public Version)

26 #3

Exhibit C (Public Version)

26 #2

Exhibit B (Public Version)

26 #1

Exhibit A (Public Version)

26 #26

Main Document

#25

(#25) CERTIFICATE of Interested Parties by R2 Solutions LLC that identifies all parties that have an interest in the outcome of this case. Corporate Parent Acacia Research Group LLC, Corporate Parent Acacia Research Corporation for R2 Solutions LLC added.. (Nelson, Edward) (Entered: 07/14/2022)

12 #12

Main Document

1 #12

Summons

1 #11

Exhibit I - U.S. Patent No. 8,341,157

1 #10

Exhibit H - U.S. Patent No. 10,176,272

1 #7

Exhibit E - U.S. Patent No. 8,307,029

1 #6

Exhibit D - U.S. Patent No. 8,190,610

1 #3

Exhibit A - Correspondence 2021 between R2 and Allegiant

1 #2

Index

1 #1

Civil Cover Sheet

1 #1

Main Document

33 More Documents Available
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Docket Entries

  • 07/14/2022
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  • Docket(#27) MOTION to Seal Document, #26 Motion to Dismiss,,, by Defendant R2 Solutions LLC. Responses due by 7/28/2022. (Nelson, Edward) (Entered: 07/14/2022)

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  • 07/14/2022
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  • Docket(#26) MOTION to Dismiss #1 Complaint,,, by Defendant R2 Solutions LLC. Responses due by 7/28/2022. Discovery Plan/Scheduling Order due by 8/28/2022. (Attachments: #1 Exhibit A (Public Version), #2 Exhibit B (Public Version), #3 Exhibit C (Public Version), #4 Exhibit D (Public Version), #5 Exhibit E (Public Version))(Nelson, Edward) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court. (Entered: 07/14/2022)

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  • 07/14/2022
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  • Docket(#25) CERTIFICATE of Interested Parties by R2 Solutions LLC that identifies all parties that have an interest in the outcome of this case. Corporate Parent Acacia Research Group LLC, Corporate Parent Acacia Research Corporation for R2 Solutions LLC added.. (Nelson, Edward) (Entered: 07/14/2022)

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  • 06/21/2022
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  • Docket(#24) ORDER granting #12 Unopposed Motion Re: #1 Complaint, R2 Solutions LLC answer due 7/16/2022. Signed by Magistrate Judge Brenda Weksler on 6/21/2022. (Copies have been distributed pursuant to the NEF - HAM) (Entered: 06/22/2022)

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  • 06/21/2022
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  • Docket(#23) ORDER granting #16 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Edward R Nelson, III for R2 Solutions LLC and approving Designation of Local Counsel Joseph R. Ganley. Signed by District Judge Cristina D. Silva on 6/21/2022. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website #www.pacer.gov(Copies have been distributed pursuant to the NEF - HAM) (Entered: 06/21/2022)

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  • 06/21/2022
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  • Docket(#22) ORDER granting #17 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Christopher Granaghan for R2 Solutions LLC and approving Designation of Local Counsel Joseph R. Ganley. Signed by District Judge Cristina D. Silva on 6/21/2022. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website #www.pacer.gov(Copies have been distributed pursuant to the NEF - HAM) (Entered: 06/21/2022)

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  • 06/21/2022
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  • Docket(#21) ORDER granting #18 Verified Petition for Permission to Practice Pro Hac Vice for Attorney John Murphy for R2 Solutions LLC and approving Designation of of Local Counsel Joseph R. Ganley. Signed by District Judge Cristina D. Silva on 6/21/2022. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website #www.pacer.gov(Copies have been distributed pursuant to the NEF - HAM) (Entered: 06/21/2022)

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  • 06/21/2022
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  • Docket(#20) ORDER granting #19 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Carder Brooks for R2 Solutions LLC and approving Designation of Local Counsel Joseph R. Ganley. Signed by District Judge Cristina D. Silva on 6/21/2022. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website #www.pacer.gov(Copies have been distributed pursuant to the NEF - HAM) (Entered: 06/21/2022)

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  • 06/20/2022
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  • Docket(#19) MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Carder W. Brooks and DESIGNATION of Local Counsel Joseph R. Ganley (Filing fee $ 250 receipt number ANVDC-6945137) by Defendant R2 Solutions LLC. (Ganley, Joseph) (Entered: 06/20/2022)

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  • 06/20/2022
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  • Docket(#18) MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by John P. Murphy and DESIGNATION of Local Counsel Joseph R. Ganley (Filing fee $ 250 receipt number ANVDC-6945136) by Defendant R2 Solutions LLC. (Ganley, Joseph) (Entered: 06/20/2022)

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9 More Docket Entries
  • 06/08/2022
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  • Docket(#8) MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Michael A. Oblon and DESIGNATION of Local Counsel Patrick Hicks (Filing fee $ 250 receipt number ANVDC-6932424) by Plaintiff Allegiant Travel Company. (Hicks, Patrick) (Entered: 06/08/2022)

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  • 06/08/2022
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  • Docket(#7) MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Keith B. Davis and DESIGNATION of Local Counsel Patrick Hicks (Filing fee $ 250 receipt number ANVDC-6932421) by Plaintiff Allegiant Travel Company. (Hicks, Patrick) (Entered: 06/08/2022)

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  • 06/01/2022
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  • Docket(#6) SUMMONS Returned Executed by Allegiant Travel Company re #4 Summons Issued. R2 Solutions LLC served on 5/26/2022. (Stegall, Kelsey) (Entered: 06/01/2022)

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  • 05/25/2022
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  • Docket(#5) CERTIFICATE of Interested Parties by Allegiant Travel Company that identifies all parties that have an interest in the outcome of this case. Other Affiliate Allegiant Air, LLC for Allegiant Travel Company added. (Hicks, Patrick) (Entered: 05/25/2022)

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  • 05/25/2022
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  • Docket(#4) SUMMONS ISSUED as to R2 Solutions LLC. (DRS) (Entered: 05/25/2022)

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  • 05/25/2022
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  • Docket(#3) AO 120 - REPORT on the filing or determination of an action regarding a patent or trademark. E-mailed to the US Patent and Trademark Office. (Attachments: #1 Complaint) (DRS) (Entered: 05/25/2022)

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  • 05/25/2022

  • DocketCase randomly assigned to District Judge Cristina D. Silva and Magistrate Judge Brenda Weksler. Nature of Suit: 830/835 Patent Case (DRS) (Entered: 05/25/2022)

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  • 05/25/2022

  • Docket(#2) NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Michael Oblon, Keith Davis, and H Albert Liou to comply with completion and filing of the Verified Petition and Designation of Local Counsel. For your convenience, click on the following link to obtain the form from the Court's website - #www.nvd.uscourts.gov. Upon approval of the Verified Petition, counsel is required to register for the Court's Case Management and Electronic Case Filing (CM/ECF) system and the electronic service of documents. Please visit the PACER website www.pacer.gov to register Attorney. Verified Petition due by 6/8/2022. (no image attached) Local counsel is responsible for forwarding this information to pro hac vice counsel. (DRS) (Entered: 05/25/2022)

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  • 05/25/2022

  • DocketAttorney update in case due to counsel entry error: Pro Hac Vice Attorneys Michael Oblon, Keith Davis, and H Albert Liou for Allegiant Travel Company added. (DRS) (Entered: 05/25/2022)

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  • 05/24/2022
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  • Docket(#1) COMPLAINT against All Defendants (Filing fee $402 receipt number ANVDC-6915586) by Allegiant Travel Company. Proof of service due by 8/22/2022. (Attachments: #1 Civil Cover Sheet, #2 Index, #3 Exhibit A - Correspondence 2021 between R2 and Allegiant, #4 Exhibit B - Mutual Confidentiality Agreement, #5 Exhibit C - U.S. Patent No. 7,698,329, #6 Exhibit D - U.S. Patent No. 8,190,610, #7 Exhibit E - U.S. Patent No. 8,307,029, #8 Exhibit F - U.S. Patent No. 8,527,623, #9 Exhibit G - U.S. Patent No. 9,558,175, #10 Exhibit H - U.S. Patent No. 10,176,272, #11 Exhibit I - U.S. Patent No. 8,341,157, #12 Summons) (Hicks, Patrick) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court. (Entered: 05/24/2022)

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