This case was last updated from PACER on 08/24/2021 at 06:18:14 (UTC).

Aqua Lighting Technologies LLC v. Blue Square Manufacturing LLC

Case Summary

On June 24, 2021, Aqua Lighting Technologies, LLC (“Aqua Lighting” or “Plaintiff”), represented by Christopher J. Lee and Dragan Gjorgiev of Lee Sheikh Megley & Haan, Kara Brasovan Kaplan and Kira Nicole Barrett of Gordon Rees Scully Mansukhani LLP filed an intellectual property lawsuit against Blue Square Manufacturing, LLC (“Blue Square” or “Defendant”), seeking declaratory relief, damages, and reasonable royalty for alleged infringement of patented technology relating to Underwater Lighting Assembly owned by Plaintiff. This case was filed in the U.S. District Court in the District of Arizona with Judge Steven P. Logan presiding.

 

In its complaint, the Plaintiff alleged that, “The ’291 patent, entitled “Underwater Lighting Assembly,” was filed with the United States Patent and Trademark Office (“USPTO”) on December 20, 2000 and issued on September 9, 2003. A copy of the ’291 patent is attached as Exhibit 1, and its file history is attached as Exhibit 2, both of which are incorporated herein by reference.”

 

The Plaintiff further alleged that “On February 10, 2020, Aqua Lighting sent to Blue Square a detailed letter explaining Aqua Lighting’s patented technologies and inquiring whether Blue Square had an interest in obtaining a license under the ’291 patent. Aqua Lighting attached a copy of the ’291 patent to the February 10, 2020 letter, along with a detailed 37-page claim chart demonstrating Blue Square’s infringement of the ’291 patent using screenshots from documents and other content available on Blue Square’s website.”

 

The Plaintiff also alleged that “On March 6, 2020, Aqua Lighting sent Blue Square follow-up correspondence by email requesting that Blue Square “engage in good faith in meaningful dialogue about licensing Aqua Lighting’s patented technology.”” and further that “Blue Square offered for sale and sold the following models of kits with multi- color Spectrum 360 LED Lights during the life of the ’291 patent: K1002-P, K1003-J,  K1004-H, K1007-P, K1008-J, K1009-H, K1012-P, K1013-J, and K1014-H.”

 

The Plaintiff even further alleged that “During the life of the ’291 patent, Blue Square infringed, literally and/or through the doctrine of equivalents, upon claims of the ’291 patent by its manufacture, offer for sale, and sale of the Accused Products in violation of 35 U.S.C. § 271 (a), (b), and/or (c).”

There is one claim for relief by the Plaintiff for alleged infringement of U.S. Patent No. 6,616,291, wherein the Plaintiff alleged that Blue Square’s acts of infringement caused damage to Aqua Lighting in an amount to be proven at trial.

 

In its prayer for relief, the Plaintiff requested the Court to enter an order against Defendant for compensatory damages and reasonable royalty, along with enhanced damages and finding that this case is exceptional and an award to Aqua Lighting of its reasonable attorneys’ fees and costs, as provided by 35 U.S.C. § 285, and other reliefs as deemed appropriate by the Court. 

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    2:21-CV-01096

  • Filing Date:

    06/24/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

  • Courthouse:

    Arizona District

Judge Details

Presiding Judge

Steven P Logan

 

Party Details

Plaintiff

Aqua Lighting Technologies LLC

Defendant

Blue Square Manufacturing LLC

Attorney/Law Firm Details

Plaintiff Attorneys

Christopher J Lee

Attorney at Lee Sheikh Megley & Haan

111 W. Jackson Blvd., Ste. 2230

Chicago, IL 60604

Dragan Gjorgiev

Attorney at Lee Sheikh Megley & Haan

111 W. Jackson Blvd., Ste. 2230

Chicago, IL 60604

Kara Brasovan Kaplan

Attorney at Gordon Rees Scully Mansukhani LLP - Phoenix, AZ

1 Renaissance Sq., 2 N Central Ave., Ste. 2200

Phoenix, AZ 85004

Kira Nicole Barrett

Attorney at Gordon Rees Scully Mansukhani LLP - Phoenix, AZ

1 Renaissance Sq., 2 N Central Ave., Ste. 2200

Phoenix, AZ 85004

 

Court Documents

11 #1

Text of Proposed Order Proposed Order

#11

(#11) *JOINT MOTION for Extension of Time to File Answer re: #1 Complaint Agreed Motion for Extension of Time to Respond to Complaint by Aqua Lighting Technologies LLC. (Attachments: #1 Text of Proposed Order Proposed Order)(Gjorgiev, Dragan) *Modified to correct text on 7/16/2021 (MHW). (Entered: 07/15/2021)

#10

(#10) SERVICE EXECUTED filed by Aqua Lighting Technologies LLC: Certificate of Service re: Court's 6/25/21 Preliminary Order upon Blue Square Manufacturing, LLC on 6/28/2021. (Kaplan, Kara) (Entered: 07/07/2021)

#9

(#9) SERVICE EXECUTED filed by Aqua Lighting Technologies LLC: Certificate of Service re: Summons, Complaint, Civil Cover Sheet, Corporate Disclosure and Magistrate Form upon Defendant Blue Square Manufacturing on June 25, 2021. (Kaplan, Kara) (Entered: 07/01/2021)

#8

(#8) NOTICE of Filing - Copyright, Trademark or Patent Information filed by Aqua Lighting Technologies LLC. (Kaplan, Kara) (Entered: 06/29/2021)

#7

(#7) PRELIMINARY ORDER that a motion pursuant to Fed. R. Civ. P. 12(b) is discouraged if the defect can be cured by filing an amended pleading. The parties must meet and confer prior to the filing of such motions to determine whether it can be avoided. FURTHER ORDERED that Plaintiff(s) serve a copy of this Order upon Defendant(s) and file a notice of service. Unless the Court orders otherwise, on September 22, 2021, the Clerk of Court shall terminate without further notice any Defendant in this action that has not been served pursuant to Rule 4(m) of the Federal Rules of Civil Procedure See attached Order for complete details. Signed by Judge Steven P. Logan on 6/24/2021. (LMR) (Entered: 06/25/2021)

6 #1

AO 121

#6

(#6) MINUTE ORDER: Request for Copyright, Trademark, or Patent Information. This case has been designated as a copyright, trademark, or patent case. The Clerk's Office is required to provide information to the Patent and Trademark Office and/or Copyright Office regarding this case. Attached to this docket entry are the required form(s) that must be completed. Plaintiff shall complete the form that is applicable to this particular case. In some cases, you may need to complete both forms.Within seven (7) days, Plaintiff must submit the required form(s) to the Clerk's Office. Please complete the form and file it with the Court using the specific event: Notice of Filing - Copyright, Trademark or Patent Information, found under the Other Filings header. Please DO NOT mail the form directly to the Patent or Copyright Office. The Clerk's Office will submit the form. If neither form is required for this case, please file a notice indicating the reason the form is not necessary and use the event listed above. This form must be updated if additional patents, copyrights, or trademarks are alleged in a responsive pleading (Attachments: #1 AO 121)(SCA) (Entered: 06/24/2021)

#5

(#5) Summons Issued as to Blue Square Manufacturing LLC. (SCA). *** IMPORTANT: When printing the summons, select "Document and stamps" or "Document and comments" for the seal to appear on the document. (Entered: 06/24/2021)

#4

(#4) Filing fee paid, receipt number 0970-19600674. This case has been assigned to the Honorable Steven P. Logan. All future pleadings or documents should bear the correct case number: CV-21-01096-PHX-SPL. Notice of Availability of Magistrate Judge to Exercise Jurisdiction form attached. (SCA) (Entered: 06/24/2021)

#3

(#3) SUMMONS Submitted by Blue Square Manufacturing LLC. (Kaplan, Kara) (SCA) (Entered: 06/24/2021)

#2

(#2) Corporate Disclosure Statement by Aqua Lighting Technologies LLC. (Kaplan, Kara) (SCA) (Entered: 06/24/2021)

1 #3

Exhibit B

1 #2

Exhibit A

1 #1

Civil Cover Sheet

#1

(#1) COMPLAINT. Filing fee received: $ 402.00, receipt number 0970-19600674 filed by Aqua Lighting Technologies LLC. (Kaplan, Kara) (Attachments: #1 Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B)(SCA) (Entered: 06/24/2021)

8 More Documents Available
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Docket Entries

  • 07/19/2021
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  • Docket(#12) ORDER granting #11 Joint Motion for Extension of Time to Answer. Defendant shall have until August 30, 2021 to file an answer to the Complaint and otherwise respond as provided by Rule 12 of the Federal Rules of Civil Procedure. No further extensions will be granted. Signed by Judge Steven P Logan on 7/19/21. (SJF) (Entered: 07/19/2021)

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  • 07/15/2021
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  • Docket(#11) *JOINT MOTION for Extension of Time to File Answer re: #1 Complaint Agreed Motion for Extension of Time to Respond to Complaint by Aqua Lighting Technologies LLC. (Attachments: #1 Text of Proposed Order Proposed Order)(Gjorgiev, Dragan) *Modified to correct text on 7/16/2021 (MHW). (Entered: 07/15/2021)

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  • 07/07/2021
  • View Court Documents
  • Docket(#10) SERVICE EXECUTED filed by Aqua Lighting Technologies LLC: Certificate of Service re: Court's 6/25/21 Preliminary Order upon Blue Square Manufacturing, LLC on 6/28/2021. (Kaplan, Kara) (Entered: 07/07/2021)

    Read MoreRead Less
  • 07/01/2021
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  • Docket(#9) SERVICE EXECUTED filed by Aqua Lighting Technologies LLC: Certificate of Service re: Summons, Complaint, Civil Cover Sheet, Corporate Disclosure and Magistrate Form upon Defendant Blue Square Manufacturing on June 25, 2021. (Kaplan, Kara) (Entered: 07/01/2021)

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  • 06/29/2021
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  • Docket(#8) NOTICE of Filing - Copyright, Trademark or Patent Information filed by Aqua Lighting Technologies LLC. (Kaplan, Kara) (Entered: 06/29/2021)

    Read MoreRead Less
  • 06/28/2021
  • DocketRemark: Pro hac vice motion(s) granted for Christopher j Lee, Dragan Gjorgiev on behalf of Plaintiff Aqua Lighting Technologies LLC. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS) (Entered: 06/28/2021)

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  • 06/25/2021
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  • Docket(#7) PRELIMINARY ORDER that a motion pursuant to Fed. R. Civ. P. 12(b) is discouraged if the defect can be cured by filing an amended pleading. The parties must meet and confer prior to the filing of such motions to determine whether it can be avoided. FURTHER ORDERED that Plaintiff(s) serve a copy of this Order upon Defendant(s) and file a notice of service. Unless the Court orders otherwise, on September 22, 2021, the Clerk of Court shall terminate without further notice any Defendant in this action that has not been served pursuant to Rule 4(m) of the Federal Rules of Civil Procedure See attached Order for complete details. Signed by Judge Steven P. Logan on 6/24/2021. (LMR) (Entered: 06/25/2021)

    Read MoreRead Less
  • 06/24/2021
  • View Court Documents
  • Docket(#6) MINUTE ORDER: Request for Copyright, Trademark, or Patent Information. This case has been designated as a copyright, trademark, or patent case. The Clerk's Office is required to provide information to the Patent and Trademark Office and/or Copyright Office regarding this case. Attached to this docket entry are the required form(s) that must be completed. Plaintiff shall complete the form that is applicable to this particular case. In some cases, you may need to complete both forms.Within seven (7) days, Plaintiff must submit the required form(s) to the Clerk's Office. Please complete the form and file it with the Court using the specific event: Notice of Filing - Copyright, Trademark or Patent Information, found under the Other Filings header. Please DO NOT mail the form directly to the Patent or Copyright Office. The Clerk's Office will submit the form. If neither form is required for this case, please file a notice indicating the reason the form is not necessary and use the event listed above. This form must be updated if additional patents, copyrights, or trademarks are alleged in a responsive pleading (Attachments: #1 AO 121)(SCA) (Entered: 06/24/2021)

    Read MoreRead Less
  • 06/24/2021
  • View Court Documents
  • Docket(#5) Summons Issued as to Blue Square Manufacturing LLC. (SCA). *** IMPORTANT: When printing the summons, select "Document and stamps" or "Document and comments" for the seal to appear on the document. (Entered: 06/24/2021)

    Read MoreRead Less
  • 06/24/2021
  • View Court Documents
  • Docket(#4) Filing fee paid, receipt number 0970-19600674. This case has been assigned to the Honorable Steven P. Logan. All future pleadings or documents should bear the correct case number: CV-21-01096-PHX-SPL. Notice of Availability of Magistrate Judge to Exercise Jurisdiction form attached. (SCA) (Entered: 06/24/2021)

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  • 06/24/2021
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  • Docket(#3) SUMMONS Submitted by Blue Square Manufacturing LLC. (Kaplan, Kara) (SCA) (Entered: 06/24/2021)

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  • 06/24/2021
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  • Docket(#2) Corporate Disclosure Statement by Aqua Lighting Technologies LLC. (Kaplan, Kara) (SCA) (Entered: 06/24/2021)

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  • 06/24/2021
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  • Docket(#1) COMPLAINT. Filing fee received: $ 402.00, receipt number 0970-19600674 filed by Aqua Lighting Technologies LLC. (Kaplan, Kara) (Attachments: #1 Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B)(SCA) (Entered: 06/24/2021)

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