This case was last updated from U.S. District Courts on 12/14/2021 at 08:22:18 (UTC).

American Honda Motor Co., Inc. v. LKQ Corporation

Case Summary

On October 15, 2021, American Honda Motor Co., Inc. (“Honda” or “Plaintiff”), represented by William A. Delgado of DTO Law, filed an intellectual property lawsuit against LKQ Corporation (“Defendant”), seeking injunctive relief and damages along with prejudgment and post-judgement interests among other relief for the alleged infringement of the United States Patents owned by Plaintiff and for alleged unfair competition. This case was filed in the United States District Court in the Central District of California.

Plaintiff filed this complaint for the alleged infringement of the United States Patent No. D826,825s (“’825 Patent”), United States Patent No. D674,330s (“’330 Patent”), United States Patent No. D729,720s (“’720 Patent”), United States Patent No. D835,561s (“’561 Patent”), United States Patent No. D767,467s (“’467 Patent”), United States Patent No. D762,543s (“’543 Patent”), United States Patent No. D804,391s (“’391 Patent”), United States Patent No. D803,131 (’131 Patent), United States Patent No. D768,553 (’553 Patent), United States Patent No. D769,165 (’165 Patent), United States Patent No. D770,351 (’351 Patent), United States Patent No. D769,172 (’172 Patent), United States Patent No. D826,826 (’826 Patent), United States Patent No. D827,545 (’545 Patent), United States Patent No. D763,158 (’158 Patent), United States Patent No. D744,400 (’400 Patent), United States Patent No. D741,237 (’237 Patent), United States Patent No. D653,597 (’597 Patent), United States Patent No. D748,034 (’034 Patent), ’216 Patent, ’629 Patent, ’434 Patent, ’153 Patent (collectively, “Patents-in-suit”) owned by Plaintiff. 

In the complaint, Plaintiff alleged that, “Defendant imports, manufactures, uses, offers to sell, and/or sells wheels with an infringing design, including but not limited to LQK products bearing the part numbers” and “Defendant is undoubtedly aware the Accused Products infringe Honda’s designs, demonstrated by the fact that Defendant has itself marketed and/or referred to the Accused Products as “replicas” of Honda Products (as shown in an example below) when selling to retailers and/or customers. Nevertheless, Defendant has persisted in infringing Honda’s patents. Further, given the uniqueness of Honda’s designs and the extent to which the Accused Products are similar, it is clear Defendant willfully infringed the patents-in-suit.” 

Plaintiff further alleged that, “Defendant, through its employees and/or agents, has and continues to directly infringe the ’825 patent by importing, making, using, offering for sale, and/or selling one or more of the Accused Products, including at least the LKQ product bearing product number ALY63141U30N.” 

Plaintiff also alleged that, “The Accused Products have a design that would appear to the ordinary observer to be substantially the same as the design claimed by the ’825 patent” and “Honda has been damaged in an amount to be determined as a direct and proximate result of Defendant’s willful infringement.”

Similar allegations have been made by Plaintiff with reference to the infringement of other Patents-in-suit. 

There are twenty-four claims for relief laid down by Plaintiff. The first twenty-three claims are for the alleged infringement of the Patents in suit. The twenty-fourth claim is for the alleged violation of Cal. Bus. & Prof. Code § 17200 et seq.

In the prayer for relief, Plaintiff has requested the court for preliminary and permanent injunctive relief and declaratory relief along with an award for all damages sustained as a result of Defendant’s infringement, including a reasonable royalty, lost profits, price erosion, and restitutionary damages, enhanced damages, and cost of the suit. 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    2:21-CV-08210

  • Filing Date:

    10/15/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Andre Birotte Jr

Referral Judge

Steve Kim

 

Party Details

Plaintiff and Counter Defendant

American Honda Motor Co., Inc.

Defendant and Counter Claimant

LKQ Corporation

Attorney/Law Firm Details

Plaintiff and Counter Defendant Attorneys

William A. Delgado

Attorney at DTO Law

601 South Figueroa Street, Suite 2130

Los Angeles, CA 90017

Prachi Viral Mehta

Attorney at DTO Law

2400 Broadway Street Suite 220

Redwood City, CA 94063

Shilpa A. Coorg

Attorney at DTO Law

601 South Figueroa Street, Suite 2130

Los Angeles, CA 90017

Defendant and Counter Claimant Attorneys

Barry F. Irwin

Attorney at Irwin IP LLC

180 North Wacker Drive, Suite 400

Chicago, IL 60606

Daniel Sokoloff

Attorney at Irwin IP LLC

180 North Wacker Drive, Suite 400

Chicago, IL 60606

Reid P. Huefner

Attorney at Irwin IP LLC

180 North Wacker Drive, Suite 400

Chicago, IL 60606

Victoria A. Hanson

Attorney at Irwin IP LLC

180 North Wacker Drive, Suite 400

Chicago, IL 60606

Brian K. Brookey

Attorney at Tucker Ellis LLP

515 South Flower Street, 42Nd Floor

Los Angeles, CA 90071-2223

 

Court Documents

#31

(#31) ORDER GRANTING APPLICATION of Non-Resident Attorney Victoria S. Hanson to Appear Pro Hac Vice on behalf of Defendant and Counterclaimant LKQ Corporation and designating Brian K. Brookey as local counsel #23 by Judge Otis D. Wright, II. (lc) (Entered: 11/16/2021)

#30

(#30) ORDER GRANTING APPLICATION of Non-Resident Attorney Daniel Sokoloff to Appear Pro Hac Vice on behalf of Defendant LKQ Corporation and designating Brian K. Brookey as local counsel #22 by Judge Otis D. Wright, II (lc) (Entered: 11/16/2021)

24 #1

Proposed Order

24 #24

Main Document

23 #1

Proposed Order

23 #23

Main Document

22 #1

Proposed Order

22 #22

Main Document

#12

(#37) ANSWER to Answer to Complaint (Attorney Civil Case Opening),, Counterclaim, #12 with JURY DEMAND filed by Defendant and Counter-Defendant American Honda Motor Co., Inc..(Delgado, William) (Entered: 11/30/2021)

#9

(#9) 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening), #1 as to Defendant LKQ Corporation. (lh) (Entered: 10/18/2021)

#8

(#8) Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (lh) (Entered: 10/18/2021)

#7

(#7) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) (Entered: 10/18/2021)

#6

(#6) NOTICE OF ASSIGNMENT to District Judge Christina A. Snyder and Magistrate Judge Steve Kim. (lh) (Entered: 10/18/2021)

#5

(#5) REPORT ON THE FILING OF AN ACTION Regarding a Patent or a Trademark (Initial Notification) filed by American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

#4

(#4) CIVIL COVER SHEET filed by Plaintiff American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

#3

(#3) NOTICE of Interested Parties filed by Plaintiff American Honda Motor Co., Inc., a California corporation, identifying American Honda Motor Co., Inc., Honda Motor Company, Ltd., and LKQ Corporation. (Delgado, William) (Entered: 10/15/2021)

#2

(#2) Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening), #1 filed by Plaintiff American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

#1

(#9) 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening), #1 as to Defendant LKQ Corporation. (lh) (Entered: 10/18/2021)

35 More Documents Available
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Docket Entries

  • 11/30/2021
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  • Docket(#37) ANSWER to Answer to Complaint (Attorney Civil Case Opening),, Counterclaim, #12 with JURY DEMAND filed by Defendant and Counter-Defendant American Honda Motor Co., Inc..(Delgado, William) (Entered: 11/30/2021)

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  • 11/22/2021
  • Docket(#36) ORDER SETTING SCHEDULING CONFERENCE by Judge Andre Birotte Jr. Scheduling Conference set for 2/25/2022 at 10:00 AM before Judge Andre Birotte Jr. (cb) (Entered: 11/22/2021)

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  • 11/22/2021
  • Docket(#35) STANDING ORDER upon filing of the complaint by Judge Andre Birotte Jr. (cb) (Entered: 11/22/2021)

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  • 11/19/2021
  • Docket(#34) NOTICE AND ORDER REGARDING TRANSFER AND/OR REASSIGNMENT OF PATENT CASE by Judge Otis D. Wright, II. Case transferred from Judge Otis D. Wright, II to Judge Andre Birotte Jr for all further proceedings. Case number now reads 2:21-cv-08210 AB(SKx). (rn) (Entered: 11/19/2021)

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  • 11/19/2021
  • Docket(#33) COUNSEL ARE NOTIFIED, the Scheduling Conference set on January 10, 2022 before Judge Wright is hereby VACATED.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (sce) TEXT ONLY ENTRY (Entered: 11/19/2021)

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  • 11/15/2021
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  • Docket(#32) ORDER GRANTING APPLICATION of Non-Resident Attorney Reid P. Huefner to Appear Pro Hac Vice on behalf of Defendant and Counterclaimant LKQ Corporation and designating Brian K. Brookey as local counsel #24 by Judge Otis D. Wright, II (lc) (Entered: 11/16/2021)

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  • 11/15/2021
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  • Docket(#31) ORDER GRANTING APPLICATION of Non-Resident Attorney Victoria S. Hanson to Appear Pro Hac Vice on behalf of Defendant and Counterclaimant LKQ Corporation and designating Brian K. Brookey as local counsel #23 by Judge Otis D. Wright, II. (lc) (Entered: 11/16/2021)

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  • 11/15/2021
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  • Docket(#30) ORDER GRANTING APPLICATION of Non-Resident Attorney Daniel Sokoloff to Appear Pro Hac Vice on behalf of Defendant LKQ Corporation and designating Brian K. Brookey as local counsel #22 by Judge Otis D. Wright, II (lc) (Entered: 11/16/2021)

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  • 11/15/2021
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  • Docket(#29) ORDER GRANTING APPLICATION of Non-Resident Attorney Barry F. Irwin to Appear Pro Hac Vice on behalf of Defendant and Counterclaimant LKQ Corporation and designating Brian K. Brookey as local counsel #21 by Judge Otis D. Wright, II (lc) (Entered: 11/16/2021)

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  • 11/15/2021
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  • Docket(#28) ORDER DENYING AS MOOT APPLICATION of Non-Resident Attorney Victoria A. Hanson to Appear Pro Hac Vice on behalf of Defendant and Counter Claimant LKQ Corporation and designating Brian K. Brookey as local counsel #18 by Judge Otis D. Wright, II. (lc) Modified on 11/16/2021 (lc). (Entered: 11/16/2021)

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17 More Docket Entries
  • 10/26/2021
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  • Docket(#10) ORDER RETURNING CASE FOR REASSIGNMENT by Judge Christina A. Snyder. ORDER case returned to the Clerk for random reassignment pursuant to General Order 21-01. Case randomly reassigned from Judge Christina A. Snyder to Judge Otis D. Wright, II for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:21-cv-08210 ODW (SKx). (esa) (Entered: 10/26/2021)

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  • 10/18/2021
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  • Docket(#9) 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening), #1 as to Defendant LKQ Corporation. (lh) (Entered: 10/18/2021)

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  • 10/18/2021
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  • Docket(#8) Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (lh) (Entered: 10/18/2021)

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  • 10/18/2021
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  • Docket(#7) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) (Entered: 10/18/2021)

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  • 10/18/2021
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  • Docket(#6) NOTICE OF ASSIGNMENT to District Judge Christina A. Snyder and Magistrate Judge Steve Kim. (lh) (Entered: 10/18/2021)

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  • 10/15/2021
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  • Docket(#5) REPORT ON THE FILING OF AN ACTION Regarding a Patent or a Trademark (Initial Notification) filed by American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

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  • 10/15/2021
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  • Docket(#4) CIVIL COVER SHEET filed by Plaintiff American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

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  • 10/15/2021
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  • Docket(#3) NOTICE of Interested Parties filed by Plaintiff American Honda Motor Co., Inc., a California corporation, identifying American Honda Motor Co., Inc., Honda Motor Company, Ltd., and LKQ Corporation. (Delgado, William) (Entered: 10/15/2021)

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  • 10/15/2021
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  • Docket(#2) Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening), #1 filed by Plaintiff American Honda Motor Co., Inc., a California corporation. (Delgado, William) (Entered: 10/15/2021)

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  • 10/15/2021
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  • Docket(#1) COMPLAINT Receipt No: ACACDC-32161635 - Fee: $402, filed by Plaintiff American Honda Motor Co., Inc., a California corporation. (Attorney William A Delgado added to party American Honda Motor Co., Inc., a California corporation(pty:pla))(Delgado, William) (Entered: 10/15/2021)

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