This case was last updated from PACER on 06/05/2021 at 09:06:51 (UTC).

Cine Graphic Solutions LLC v. Motorola Mobility LLC

Case Summary

On April 6, 2021, Cine Graphic Solutions, LLC (“Cine Graphic” or “Plaintiff”), represented by Timothy E. Grochocinski of Nelson Bumgardner Albritton P.C. filed an intellectual property lawsuit against Motorola Mobility LLC (“Motorola'' or “Defendant”), seeking declaratory and monetary relief, with prejudgment and post-judgment interest for the alleged infringement of various patents owned by the Plaintiff. This case was filed in the U.S. District Court for the Northern District of Illinois with Judge Manish S. Shah presiding.

 

In its complaint, the Plaintiff alleged that the Defendant has infringed and continues to infringe U.S. Patent Nos. 7,388,587 (“the ʼ587 patent”), 7,629,977 (“the ʼ977 patent”), and 8,035,644 (“the ʼ644 patent”) (collectively, the “patents-in-suit”) owned by Plaintiff. 

 

Plaintiff further alleged that “Motorola makes, uses, sells, offers to sell, and/or imports into the United States products as claimed and/or otherwise engages in practices that infringe one or more claims of each of the patents-in-suit.” “On information and belief, Motorola developed a feature for its hardware and software products that provides the same and/or similar functionality as Mr. Richardson’s Cinegifs after the publication and/or issuance of the patents-in-suit. Specifically, Motorola developed and released mobile phone products, smartphone products, and software (such as apps) that include a feature Motorola has dubbed “Cinemagraph.” “Motorola has infringed and continues to infringe the patents-in-suit by making, using, selling, offering to sell, and/or importing into the United States mobile devices with Motorola’s Cinemagraph feature including Motorola’s Moto Z3, Moto Z3 play, Moto Z4, Moto G-series of smartphones (Moto G6, Moto G7, Moto G7 play, Moto G7 Power, Moto G Power, Moto G8 Plus, Moto G8 Power, Moto G Stylus), Motorola One, Motorola One Macro, Motorola One Action, Motorola One Vision, Motorola One Zoom, Motorola One Hyper, Motorola Razr, Motorola Edge, Motorola Edge + and Motorola One Fusion (the “Accused Phones”). Motorola delivers the Accused Phones with software and hardware pre-installed and pre-configured for creating Cinegifs (which Motorola refers to as “Cinemagraphs,” as stated above).”

 

Plaintiff even further alleged that “Motorola has and continues to infringe the patents-in-suit by making, using, selling, offering to sell, and/or importing into the United States its Moto Camera and Moto Camera 2 apps (the “Accused Apps”). The Accused Phones and the Accused Apps are collectively referred to as the “Accused Products.” “Promotional materials published by Motorola and authorized third parties highlight the infringing technology as a key feature in the Accused Products. Motorola advertises the Cinemagraph feature in the Accused Products.”

 

There are three claims for relief laid down by the plaintiff. The first claim is for the alleged direct infringement under 35 U.S.C. § 271(a) and alleged indirect infringement by inducement under 35 U.S.C. § 271(b) of the ’587 patent. The second claim is for the alleged direct infringement under 35 U.S.C. § 271(a) and alleged indirect infringement by inducement under 35 U.S.C. § 271(b)  of the ’977 patent. The third claim is for the alleged direct infringement under 35 U.S.C. § 271(a) and alleged indirect infringement by inducement under 35 U.S.C. § 271(b)  of the ’644 patent.

 

In its prayer for relief, the Plaintiff has requested the court to declare that one or more claims of each patent-in-suit have been infringed directly and/or indirectly, literally and/or under the doctrine of equivalents, by Defendant; order damages and costs; order a reasonable, ongoing, post judgment royalty; and order prejudgment and post judgment interest on the damages along with costs of litigation. 

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    1:21-CV-01840

  • Filing Date:

    04/06/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Manish S. Shah

 

Party Details

Plaintiff

Cine Graphic Solutions LLC

Defendant

Motorola Mobility LLC

Attorney/Law Firm Details

Plaintiff Attorney

Timothy E. Grochocinski

Attorney at Nelson Bumgardner Albritton P.C.

15020 S. Ravinia Ave., Suite 29

Orland Park, IL 60462

Defendant Attorneys

Lai Yip

Attorney at Sheppard Mullin Richter & Hampton LLP

Four Embarcadero Center, 17Th Floor

San Francisco, CA 94111

Martin R. Bader

Attorney at Sheppard Mullin Richter & Hampton LLP

12275 El Camino Real, Suite 200

San Diego, CA 92130

Bradley C. Graveline

Attorney at Sheppard Mullin Richter & Hampton LLP

70 West Madison Street, 48Th Floor

Chicago, IL 60602

 

Court Documents

#1

#11

#10

#9

#8

#7

#6

#5

#4

#3

#2

1 #7

Civil Cover Sheet

1 #6

Exhibit 6- 644 Chart

1 #5

Exhibit 5- 977 Chart

1 #4

Exhibit 4- 587 Chart

1 #3

Exhibit 3- '644 Patent

1 #2

Exhibit 2- '977 Patent

1 #1

Exhibit 1-'587 Patent

7 More Documents Available
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Docket Entries

  • 05/28/2021
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  • Docket(#11) MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time #10 is granted. Defendant's response to the complaint is due 7/1/21 and the parties' report of the their planning meeting pursuant to LPR 1.2 is due 7/8/2021. The motions for admission pro hac vice #8 #9 are granted. (mss) (Entered: 05/28/2021)

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  • 05/27/2021
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  • Docket(#10) MOTION by Defendant Motorola Mobility LLC for extension of time STIPULATED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT (Graveline, Bradley) (Entered: 05/27/2021)

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  • 05/24/2021
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  • Docket(#9) MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-18280346. (Bader, Martin) (Entered: 05/24/2021)

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  • 05/24/2021
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  • Docket(#8) MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-18280271. (Yip, Lai) (Entered: 05/24/2021)

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  • 05/24/2021
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  • Docket(#7) ATTORNEY Appearance for Defendant Motorola Mobility LLC by Bradley C. Graveline (Graveline, Bradley) (Entered: 05/24/2021)

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  • 04/26/2021
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  • Docket(#6) MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer #5 is granted. Defendant's response to the complaint is due 6/1/21. The parties shall file a report of the parties' planning meeting pursuant to LPR 1.2. by 6/8/21. A template for the report setting forth the information required, may be found at http://www.ilnd.uscourts.gov/_assets/_documents/_rules/LPR%20Appendix%20A.pdf. In addition to the information required in LPR Appendix A, the parties shall set forth the specific dates and events set by the local patent rules up through the opening claim construction briefs and also report on the status of any settlement discussions. Notices mailed. (psm, ) (Entered: 04/26/2021)

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  • 04/23/2021
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  • Docket(#5) MOTION by Plaintiff Cine Graphic Solutions LLC for extension of time to file answer regarding complaint, #1 (Grochocinski, Timothy) (Entered: 04/23/2021)

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  • 04/16/2021
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  • Docket(#4) SUMMONS Returned Executed by Cine Graphic Solutions LLC as to Motorola Mobility LLC on 4/8/2021, answer due 4/29/2021. (Grochocinski, Timothy) (Entered: 04/16/2021)

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  • 04/07/2021
  • DocketSUMMONS Issued as to Defendant Motorola Mobility LLC (dxb, ) (Entered: 04/07/2021)

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  • 04/06/2021
  • DocketCASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (lw, ) (Entered: 04/06/2021)

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  • 04/06/2021
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  • Docket(#3) NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Cine Graphic Solutions LLC (Grochocinski, Timothy) (Entered: 04/06/2021)

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  • 04/06/2021
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  • Docket(#2) NOTICE by Cine Graphic Solutions LLC of Filing of Report of Filing or Determination of an Action Regarding a Patent or Trademark (Grochocinski, Timothy) (Entered: 04/06/2021)

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  • 04/06/2021
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  • Docket(#1) COMPLAINT for Patent Infringement filed by Cine Graphic Solutions LLC; JURY DEMAND. Filing fee $ 402, receipt number 0752-18096344. (Attachments: #1 Exhibit 1-'587 Patent, #2 Exhibit 2- '977 Patent, #3 Exhibit 3- '644 Patent, #4 Exhibit 4- 587 Chart, #5 Exhibit 5- 977 Chart, #6 Exhibit 6- 644 Chart, #7 Civil Cover Sheet)(Grochocinski, Timothy) (Entered: 04/06/2021)

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