On May 17, 2023, RecepTrexx LLC (“Plaintiff”), represented by Isaac Rabicoff of Rabicoff Law LLC, filed an intellectual property lawsuit against Honeywell International Inc. (“Defendant”), seeking damages for alleged infringement of the U.S. patent owned by the plaintiff. This case was filed in the U.S. District Court for the Western District of Texas.
In the complaint, the plaintiff alleged, “The ’706 Patent is entitled ‘Multicast wireless ad hoc packet routing’, and issued 2005-06-21. The application leading to the ’706 Patent was filed on 2001-05-23.”
Plaintiff also alleged, “The plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 6,909,706 (the “Patent-in-Suit”) owned by the plaintiff.”
The plaintiff then alleged, “Defendant has been and continues to directly infringe one or more claims of the ’706 Patent in at least this District by making, using, offering to sell, selling and/or importing, without limitation, at least the Defendant products identified in the charts incorporated into this Count below (among the ‘Exemplary Defendant Products’) that infringe at least the exemplary claims of the ’706 Patent also identified in the charts incorporated into this Count below (the ‘Exemplary ’706 Patent Claims’) literally or by the doctrine of equivalents.”
The plaintiff further alleged that “numerous other devices that infringe the claims of the ’706 Patent have been made, used, sold, imported, and offered for sale by Defendant and/or its customers.”
Plaintiff also alleged, “Defendant also has and continues to directly infringe, literally or under the doctrine of equivalents, the Exemplary ’706 Patent Claims, by having its employees internally test and use these Exemplary Products.”
The plaintiff then alleged, “Defendant continues to make, use, test, sell, offer for sale, market, and/or import into the United States, products that infringe the ’706 Patent. On information and belief, Defendant has also continued to sell the Exemplary Defendant Products and distribute product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the ’706 Patent.”
The plaintiff further alleged, “Defendant has actively, knowingly, and intentionally continued to induce infringement of the ’706 Patent, literally or by the doctrine of equivalents, by selling Exemplary Defendant Products to their customers for use in end-user products in a manner that infringes one or more claims of the ’706 Patent.”
Plaintiff presented one claim for relief from alleged infringement of the ‘706 owned by the plaintiff.
In the prayer for relief, the plaintiff requested declaring that the '706 patent is valid and enforceable and that the defendant has directly infringed one or more claims of the '706 patent. The plaintiff also requested an award of compensatory damages, and all appropriate damages.
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6:23-CV-00380
05/17/2023
Pending - Other Pending
Intellectual Property - Patent
Orlando L. Garcia
RecepTrexx LLC
Honeywell International Inc.
Isaac Rabicoff
Proposed Order
(#12) Unopposed MOTION for Extension of Time to File Answer re #10 Amended Complaint by RecepTrexx LLC. (Attachments: #1 Proposed Order)(Rabicoff, Isaac) (Entered: 06/23/2023)
(#11) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Rabicoff, Isaac) (Entered: 06/15/2023)
Exhibit 4
Exhibit 3
Exhibit 2
Exhibit 1
(#10) AMENDED COMPLAINT against Honeywell International Inc. amending #1 Complaint., filed by RecepTrexx LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Rabicoff, Isaac) (Entered: 06/15/2023)
(#9) SUMMONS Returned Executed by RecepTrexx LLC. Honeywell International Inc. served on 5/22/2023, answer due 6/12/2023. (Rabicoff, Isaac) (Entered: 06/06/2023)
Proposed Order
(#8) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint by RecepTrexx LLC. (Attachments: #1 Proposed Order)(Rabicoff, Isaac) (Entered: 06/06/2023)
(#7) Summons Issued as to Honeywell International Inc. (zv) (Entered: 05/18/2023)
(#6) NOTICE of Related Case by RecepTrexx LLC (Rabicoff, Isaac) (Entered: 05/17/2023)
(#5) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Rabicoff, Isaac) (Entered: 05/17/2023)
Civil Cover Sheet
Exhibit 2
Exhibit 1
(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number ATXWDC-17449539), filed by RecepTrexx LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Civil Cover Sheet)(Rabicoff, Isaac) (Entered: 05/17/2023)
DocketText Order GRANTING #12 Motion for Extension of Time to Answer. It is therefore ORDERED that Defendants answer be submitted to the Court on or before August 14, 2023. Entered by Judge Orlando L. Garcia. (This is a text-only entry generated by the court. There is no document associated with this entry.) (nm) (Entered: 06/26/2023)
[-] Read LessDocket(#12) Unopposed MOTION for Extension of Time to File Answer re #10 Amended Complaint by RecepTrexx LLC. (Attachments: #1 Proposed Order)(Rabicoff, Isaac) (Entered: 06/23/2023)
[-] Read LessDocket(#11) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Rabicoff, Isaac) (Entered: 06/15/2023)
[-] Read LessDocketPlaintiff's counsel was informed by Clerk's Office if Amended Complaint #10 is adding patents-in-suit the AO120 form must be updated, flatten, and e-file using the "Notice of Filing of Patent/Trademark Form" event. (zv) (Entered: 06/15/2023)
[-] Read LessDocket(#10) AMENDED COMPLAINT against Honeywell International Inc. amending #1 Complaint., filed by RecepTrexx LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Rabicoff, Isaac) (Entered: 06/15/2023)
[-] Read LessDocketReset Deadlines: Honeywell International Inc. answer due 7/12/2023. (zv) (Entered: 06/06/2023)
[-] Read LessDocket(#9) SUMMONS Returned Executed by RecepTrexx LLC. Honeywell International Inc. served on 5/22/2023, answer due 6/12/2023. (Rabicoff, Isaac) (Entered: 06/06/2023)
[-] Read LessDocketText Order GRANTING #8 Motion for Extension of Time to Answer by Defendant Honeywell International Inc. IT IS FURTHER ORDERED that Defendant shall have until July 12, 2023, to answer entered by Judge Orlando L. Garcia. (This is a text-only entry generated by the court. There is no document associated with this entry.) (pt) (Entered: 06/06/2023)
[-] Read LessDocket(#8) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint by RecepTrexx LLC. (Attachments: #1 Proposed Order)(Rabicoff, Isaac) (Entered: 06/06/2023)
[-] Read LessDocket(#7) Summons Issued as to Honeywell International Inc. (zv) (Entered: 05/18/2023)
[-] Read LessDocketCase assigned to Judge Orlando L. Garcia. CM WILL NOW REFLECT THE JUDGE INITIALS AS PART OF THE CASE NUMBER. PLEASE APPEND THESE JUDGE INITIALS TO THE CASE NUMBER ON EACH DOCUMENT THAT YOU FILE IN THIS CASE. (zv) (Entered: 05/18/2023)
[-] Read LessDocketPlease remember to comply with the standing orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (zv) (Entered: 05/18/2023)
[-] Read LessDocket(#6) NOTICE of Related Case by RecepTrexx LLC (Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read LessDocket(#5) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read LessDocket(#4) REQUEST FOR ISSUANCE OF SUMMONS by RecepTrexx LLC. (Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read LessDocket(#3) RULE 7 DISCLOSURE STATEMENT filed by RecepTrexx LLC. (Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read LessDocket(#2) NOTICE of Attorney Appearance by Isaac Rabicoff on behalf of RecepTrexx LLC (Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read LessDocket(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number ATXWDC-17449539), filed by RecepTrexx LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Civil Cover Sheet)(Rabicoff, Isaac) (Entered: 05/17/2023)
[-] Read Less