Heritage IP LLC v. Motorola Solutions Inc

On September 27, 2022, Heritage IP LLC (“Heritage” or “Plaintiff”), represented by John A. Lee of Banie & Ishimoto LLP, filed an intellectual property lawsuit against Motorola Solutions, Inc. (“Defendant”), seeking declaratory relief and damages for Defendant’s alleged infringement of U.S. Patent owned by the plaintiff. This case was filed in the U.S. District Court for the Western District of Washington.

The plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 7,221,200 (“the ’200 Patent” or “Asserted Patent”) entitled “Programmable Low Voltage Reset Apparatus for Multi-VDD Chips,” owned by the plaintiff.

In the complaint, the plaintiff alleged, “Defendant infringes the Asserted Patent by implementing, without authorization, Heritage’s proprietary technologies in at least Motorola Solutions PMLN5792 (‘Accused Products’). Defendant has infringed and is infringing, either literally or under the doctrine of equivalents, the ‘200 Patent in violation of 35 U.S.C. § 271 et seq., directly and/or indirectly, by making, using, offering for sale, or selling in the United States, and/or importing into the United States without authority or license, the Accused Products (including Motorola Solutions PMLN5792 product).”

The plaintiff further alleged, “Defendant has provided the Accused Products to its customers and, on information and belief, instructions to use the Accused Products in an infringing manner while being on notice of (or willfully blind to) the ‘200 Patent and Defendants’ infringement. Therefore, on information and belief, Defendant knew or should have known of the ‘200 Patent and of its own infringing acts, or deliberately took steps to avoid learning of those facts. Defendant knowingly and intentionally encourages and aids at least its end-user customers to directly infringe the ‘200 Patent.”

The plaintiff then alleged, “Defendant’s end-user customers directly infringe at least one or more claims of the ‘200 Patent by using the Accused Products in their intended manner to infringe. Defendant induces such infringement by providing the Accused Products and instructions to enable and facilitate infringement, knowing of, or being willfully blind to the existence of, the ‘200 Patent. On information and belief, Defendant specifically intends that its actions will result in infringement of one or more claims of the ‘200 Patent.”

The plaintiff additionally alleged, “Defendant contributorily infringes at least one or more claims of the ‘200 Patent by providing the Accused Products and/or software components thereof, that embody a material part of the claimed inventions of the ‘200 Patent, that are known by Defendant to be specially made or adapted for use in an infringing manner, and are not staple articles with substantial non-infringing uses. The Accused Products are specially designed to infringe at least one or more claims of the ‘200 Patent, and their accused components have no substantial non- infringing uses.”

The plaintiff also alleged, “Defendant’s infringement of the ‘200 Patent was and continues to be willful and deliberate, entitling Heritage to enhanced damages. Defendant’s knowledge of the ‘200 Patent and willful infringement will likely have evidentiary support after a reasonable opportunity for discovery.”

Plaintiff stated one claim for Defendant’s alleged infringement of U.S. Patent No. 7,221,200 owned by the plaintiff.

In its prayer for relief, the plaintiff requested a judgment for declaratory relief, damages and costs together with pre and post-judgment interest.

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