On June 30, 2021, Heritage IP LLC (“Heritage” or “Plaintiff”), represented by Nicholas Loaknauth of Law Office of Nicholas Loaknauth, P.C., filed an intellectual property lawsuit against Canon U.S.A., Inc., (“Defendant”), seeking declaratory and compensatory relief, including pre-judgment and post-judgment interest and costs, for the alleged infringement of the ’067 Patent, owned by the Plaintiff. This case was filed in U.S. District Court in the Eastern District of New York.
The Plaintiff filed this complaint for the Defendant’s alleged direct infringement of U.S. Patent No. 6,854,067 (“the ’067 Patent”) entitled “Method and System for Interaction between a Processor and a Power on Reset circuit to Dynamically Control Power States in a Microcontroller”. The ’067 Patent recognized several problems with existing microcontrollers having Power on Reset (POR) circuits.
In its complaint, the Plaintiff alleged that “Defendant has directly infringed at least claim 1 of the ‘067 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 claim 1 of the ‘067 Patent also identified in the charts incorporated into this Count below literally or by the doctrine of equivalents. On information and belief, numerous other devices that infringe at least claim 1 of the ‘067 Patent have been made, used, sold, imported, and offered for sale by Defendant and/or its customers.”
The Plaintiff further alleged that “Defendant also has directly infringed, literally or under the doctrine of equivalents, at least claim 1 of the ‘067 Patent Claims, by having its employees internally test and use these Exemplary Products.”
The only claim for relief laid down by the Plaintiff is for the alleged infringement of ’067 patent, wherein the Plaintiff claimed that, Defendant has committed and continues to commit acts of infringement in violation of 35 U.S.C. § 271, and has made, used, marketed, distributed, offered for sale, sold, and/or imported infringing products in the State of New York, including in Eastern District, and engaged in infringing conduct within and directed at or from this District.
In its prayer for relief, the Plaintiff requested the Court to enter a judgment that Defendant has infringed at least one or more claims of the ‘067 Patent, directly and/or indirectly, literally and/or under the doctrine of equivalents and award damages sufficient to compensate Heritage for Defendant’s infringement under 35 U.S.C. § 284, including an enhancement of damages on account of Defendant’s willful infringement. The Plaintiff further requested the Court that the case be found exceptional under 35 U.S.C. § 285 and that Heritage be awarded its reasonable attorneys’ fees; Costs and expenses in this action; an award of prejudgment and post-judgment interest; and such other and further relief as the Court may deem just and proper.
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Pending - Other Pending
Heritage IP LLC
Canon U.S.A., Inc.
Attorney at Law Office of Nicholas Loaknauth, P.C.
New York, NY 10036
Exhibit 2: Claim Chart
Exhibit 1: US Pat. No. 6,854,067
Civil Cover Sheet
(#1) COMPLAINT against Canon U.S.A., Inc. filing fee $ 402, receipt number ANYEDC-14616253 Was the Disclosure Statement on Civil Cover Sheet completed -YES,, filed by Heritage IP LLC. (Attachments: #1 Civil Cover Sheet, #2 Proposed Summons, #3 Exhibit 1: US Pat. No. 6,854,067, #4 Exhibit 2: Claim Chart) (Loaknauth, Nicholas) (Entered: 06/30/2021)
Docket(#1) COMPLAINT against Canon U.S.A., Inc. filing fee $ 402, receipt number ANYEDC-14616253 Was the Disclosure Statement on Civil Cover Sheet completed -YES,, filed by Heritage IP LLC. (Attachments: #1 Civil Cover Sheet, #2 Proposed Summons, #3 Exhibit 1: US Pat. No. 6,854,067, #4 Exhibit 2: Claim Chart) (Loaknauth, Nicholas) (Entered: 06/30/2021)Read MoreRead Less
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