This case was last updated from U.S. District Courts on 11/27/2021 at 08:02:32 (UTC).

KT Imaging USA, LLC v. Dell Technologies Inc. et al

Case Summary

On September 28, 2021, KT Imaging USA, LLC (“KTI” or “Plaintiff”), represented by Stafford Grigsby Helm Davis of The Stafford Davis Firm, PC, filed an intellectual property lawsuit against Dell Technologies Inc. and Dell Inc. (collectively, “Dell” or “Defendants”), seeking injunctive relief and damages along with pre-and post-judgement interest for the alleged infringement of United States Patents owned by Plaintiff. This case was filed in the U.S. District Court in the Western District of Texas.

Plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 6,876,544 (“the ’544 Patent”), entitled “Image Sensor Module and Method for Manufacturing the Same”, U.S. Patent No. 7,196,322 (“the ’322 Patent”), entitled “Image Sensor Package” and U.S. Patent No. 8,004,602 (“the ’602 Patent”), entitled “Image Sensor Structure and Integrated Lens Module Thereof” (collectively, “Patents-in-suit”) owned by Plaintiff.

In the complaint Plaintiff alleged that, “On information and belief, Dell has infringed the ’544 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States or importing into the United States the Accused Products and all other products with substantially similar imaging sensors.  For example, on information and belief, Dell has infringed and continues to infringe at least claim 1 of the ’544 Patent by including an image sensor module to be mounted to a printed circuit board in the Dell Latitude 7200 product.”

Plaintiff further alleged that, “On information and belief, Dell has infringed the ’322 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States or importing into the United States the Accused Products and all other products with substantially similar imaging sensors. On information and belief, Dell has induced infringement of the ’322 Patent pursuant to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging others, including, but not limited to, its partners, resellers, distributers, customers, and end users, to make, use, sell, and/or offer to sell in the United States, and/or import into the United States, the Accused Products.”

Plaintiff also alleged that, “On information and belief, Dell has infringed the ’602 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States, or importing into the United States the Accused Products and all other products with substantially similar imaging sensors. For example, on information and belief, Dell has infringed and continues to infringe at least claim 1 of the ’602 Patent by including an image sensor structure with an integrated lens module in the Dell Vostro 3400 Laptop product. Dell has committed the foregoing infringing activities without a license.”

There are three claims for relief laid down by Plaintiff which deal with the alleged infringement of the Patents-in-suit owned by Plaintiff.

In its prayer for relief Plaintiff has requested the court to enter a judgment that Dell has infringed the Patents-in-Suit. Plaintiff also requested the court to permanently enjoin Dell from infringing the Patents-in-Suit, award compensatory damages adequate to compensate KTI for Dell’s infringement of the Patents-in-Suit, and award reasonable attorneys’ fees and expenses against Dell pursuant to 35 U.S.C. § 285 along with pre- and post-judgement interest.

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-01004

  • Filing Date:

    09/28/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

KT Imaging USA, LLC

Defendants

Dell Technologies Inc.

Dell Inc.

Attorney/Law Firm Details

Plaintiff Attorneys

Andrey Belenky

Attorney at Kheyfits Belenky LLP

80 Broad St., 5Th Floor

New York, NY 10004

Brandon Moore

Attorney at Kheyfits Belenky LLP

108 Wild Basin Road South, Suite 250

Austin, TX 78746

Catherine Bartles

Attorney at Stafford Davis Firm, PC

815 S Broadway Ave

Tyler, TX 75701

Dmitry Kheyfits

Attorney at Kheyfits Belenky LLP

108 Wild Basin Road

Austin, TX 78746

Hanna G. Cohen

Attorney at Kheyfits Belenky LLP

1140 Avenue Of The Americas, 9Th Floor

New York, NY 10036

Stafford Grigsby Helm Davis

Attorney at The Stafford Davis Firm, PC

815 South Broadway Avenue

Tyler, TX 75701

Defendant Attorney

Deron R Dacus

Attorney at The Dacus Firm, P.C.

821 Ese Loop 323, Suite 430

Tyler, TX 75701

 

Court Documents

#9

(#9) NOTICE of Agreed Extension of Time to Answer, Move or Otherwise Respond to Complaint by Dell Inc., Dell Technologies Inc. re #1 Complaint,, (Dacus, Deron) (Entered: 11/02/2021)

1 #24

Civil Cover Sheet

1 #22

Exhibit 20

1 #21

Exhibit 19

1 #18

Exhibit 16

1 #16

Exhibit 14

1 #15

Exhibit 13

1 #14

Exhibit 12

1 #13

Exhibit 11

1 #12

Exhibit 10

1 #11

Exhibit 9

1 #10

Exhibit 8

1 #9

Exhibit 7

1 #8

Exhibit 6

1 #7

Exhibit 5

1 #4

Exhibit 2

1 #2

Exhibit Attachment B

1 #1

Exhibit Attachment A

24 More Documents Available
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Docket Entries

  • 11/02/2021
  • DocketReset Deadlines: Dell Inc. answer due 12/17/2021; Dell Technologies Inc. answer due 12/17/2021. (jc5) (Entered: 11/02/2021)

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  • 11/02/2021
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  • Docket(#9) NOTICE of Agreed Extension of Time to Answer, Move or Otherwise Respond to Complaint by Dell Inc., Dell Technologies Inc. re #1 Complaint,, (Dacus, Deron) (Entered: 11/02/2021)

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  • 10/08/2021
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  • Docket(#8) Standing Order Regarding Order Governing Proceedings Patent Cases. Signed by Judge Alan D Albright. (Entered: 10/13/2021)

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  • 10/06/2021
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  • Docket(#7) NOTICE of Attorney Appearance by Catherine Bartles on behalf of KT Imaging USA, LLC (Bartles, Catherine) (Entered: 10/06/2021)

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  • 09/29/2021
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  • Docket(#6) Summons Issued as to Dell Inc.. (lad) (Entered: 09/29/2021)

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  • 09/29/2021
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  • Docket(#5) Summons Issued as to Dell Technologies Inc.. (lad) (Entered: 09/29/2021)

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  • 09/29/2021
  • DocketAll parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 09/29/2021)

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  • 09/28/2021
  • DocketCase assigned to Judge Alan D Albright. 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. (lad) (Entered: 09/29/2021)

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  • 09/28/2021
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  • Docket(#4) RULE 7 DISCLOSURE STATEMENT filed by KT Imaging USA, LLC. (Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#3) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#2) REQUEST FOR ISSUANCE OF SUMMONS by KT Imaging USA, LLC. (Attachments: #1 Exhibit Summons)(Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-15276038), filed by KT Imaging USA, LLC. (Attachments: #1 Exhibit Attachment A, #2 Exhibit Attachment B, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Exhibit 12, #15 Exhibit 13, #16 Exhibit 14, #17 Exhibit 15, #18 Exhibit 16, #19 Exhibit 17, #20 Exhibit 18, #21 Exhibit 19, #22 Exhibit 20, #23 Exhibit 21, #24 Civil Cover Sheet)(Davis, Stafford) (Entered: 09/28/2021)

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