This case was last updated from U.S. District Courts on 11/26/2022 at 08:22:36 (UTC).

Heritage IP LLC v. Motorola Solutions Inc

Case Summary

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.

This is a summary of a legal complaint. All statements, claims, and allegations listed herein reflect the position of the plaintiff only and do not represent the position of UniCourt. Additionally, this case summary may not reflect the current position of the parties to this litigation or the current status of this case. To view the latest case updates and court documents, please sign up for a UniCourt account.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    2:22-CV-01374

  • Filing Date:

    09/27/2022

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Theresa L Fricke

 

Party Details

Plaintiff

Heritage IP LLC

Defendant

Motorola Solutions Inc

Attorney/Law Firm Details

Plaintiff Attorney

John A Lee

Attorney at BANIE & ISHIMOTO LLP

3705 Haven Ave #137

Menlo Park, CA 94025

 

Court Documents

#1

(#1) COMPLAINT For Patent Infringement against defendant(s) Motorola Solutions Inc with JURY DEMAND (Receipt # AWAWDC-7718127), filed by Heritage IP LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet, #4 Summons, #5 Report on Patents and Trademarks (AO Form 120))(Lee, John) (Entered: 09/27/2022)

1 #1

Exhibit A

1 #2

Exhibit B

1 #3

Civil Cover Sheet

1 #4

Summons

1 #5

Report on Patents and Trademarks (AO Form 120)

#2

(#2) REPORT on the filing or determination of an action. Emailed to the US Patent Office (MJV) (Entered: 09/29/2022)

#3

(#3) Summons(es) Electronically Issued as to defendant(s) Motorola Solutions Inc (MJV) (Entered: 09/29/2022)

#4

(#4) ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT. Joint Status Report due by 1/3/2023, FRCP 26(f) Conference Deadline is 12/19/2022, Initial Disclosure Deadline is 12/27/2022, by Judge Theresa L Fricke. (GMR) (Entered: 10/04/2022)

#5

(#5) ORDER REGARDING DISCOVERY AND DEPOSITIONS by Judge Theresa L Fricke. (GMR) (Entered: 10/04/2022)

#6

(#6) CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1. Filed by Heritage IP LLC (Lee, John) (Entered: 10/06/2022)

#7

(#7) AFFIDAVIT of Service of Summons and Complaint on Motorola Solutions Inc. on 10/12/2022, filed by Plaintiff Heritage IP LLC. (Lee, John) (Entered: 10/26/2022)

#8

(#8) Unopposed MOTION for Extension of Time to File Answer Complaint, filed by Plaintiff Heritage IP LLC. (Attachments: #1 Proposed Order) Noting Date 10/26/2022, (Lee, John) (Entered: 10/26/2022)

8 #1

Proposed Order

#9

(#9) ORDER granting Plaintiff's #8 Unopposed MOTION for Extension of Time to Respond to Complaint, signed by Judge Theresa L Fricke. Defendant's deadline to respond to the Complaint is extended to December 2, 2022. (GMR) (Entered: 10/26/2022)

3 More Documents Available
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Docket Entries

  • 10/26/2022
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  • Docket(#9) ORDER granting Plaintiff's #8 Unopposed MOTION for Extension of Time to Respond to Complaint, signed by Judge Theresa L Fricke. Defendant's deadline to respond to the Complaint is extended to December 2, 2022. (GMR) (Entered: 10/26/2022)

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  • 10/26/2022
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  • Docket(#8) Unopposed MOTION for Extension of Time to File Answer Complaint, filed by Plaintiff Heritage IP LLC. (Attachments: #1 Proposed Order) Noting Date 10/26/2022, (Lee, John) (Entered: 10/26/2022)

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  • 10/26/2022
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  • Docket(#7) AFFIDAVIT of Service of Summons and Complaint on Motorola Solutions Inc. on 10/12/2022, filed by Plaintiff Heritage IP LLC. (Lee, John) (Entered: 10/26/2022)

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  • 10/06/2022
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  • Docket(#6) CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1. Filed by Heritage IP LLC (Lee, John) (Entered: 10/06/2022)

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  • 10/04/2022
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  • Docket(#5) ORDER REGARDING DISCOVERY AND DEPOSITIONS by Judge Theresa L Fricke. (GMR) (Entered: 10/04/2022)

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  • 10/04/2022
  • View Court Documents
  • Docket(#4) ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT. Joint Status Report due by 1/3/2023, FRCP 26(f) Conference Deadline is 12/19/2022, Initial Disclosure Deadline is 12/27/2022, by Judge Theresa L Fricke. (GMR) (Entered: 10/04/2022)

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  • 09/29/2022
  • DocketNOTICE Pursuant to Fed.R.Civ.P 7.1, Plaintiff(s) must file a Corporate Disclosure Statement by 10/6/2022. (MJV) (Entered: 09/29/2022)

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  • 09/29/2022
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  • Docket(#3) Summons(es) Electronically Issued as to defendant(s) Motorola Solutions Inc (MJV) (Entered: 09/29/2022)

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  • 09/29/2022
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  • Docket(#2) REPORT on the filing or determination of an action. Emailed to the US Patent Office (MJV) (Entered: 09/29/2022)

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  • 09/29/2022
  • DocketJudge Theresa L Fricke added. (MJV) (Entered: 09/29/2022)

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  • 09/27/2022
  • View Court Documents
  • Docket(#1) COMPLAINT For Patent Infringement against defendant(s) Motorola Solutions Inc with JURY DEMAND (Receipt # AWAWDC-7718127), filed by Heritage IP LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet, #4 Summons, #5 Report on Patents and Trademarks (AO Form 120))(Lee, John) (Entered: 09/27/2022)

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