This case was last updated from U.S. District Courts on 09/06/2021 at 10:27:39 (UTC).

Liberty Peak Ventures, LLC v. Citigroup Inc. et al

Case Summary

On July 8, 2021, Liberty Peak Ventures, LLC (“LPV” or “Plaintiff”), represented by Jeffrey Ray Bragalone Olejko Saad PC and Marcus Benavides of Benavides Law, filed an intellectual property lawsuit against Citigroup Inc. and Citibank, N.A. (collectively, “Defendants” or the “Citi Defendants”), seeking declaratory and compensatory relief, along with prejudgment and post-judgment interest for the alleged infringement of Asserted Patents, owned by the Plaintiff. This case was filed in U.S. District Court in the Western District of Texas with Judge Alan D. Albright presiding. 

The Plaintiff filed this suit for the Defendant’s alleged direct and/or indirect infringement of U.S. Patent Nos. 7,431,207 (the “’207 patent”) entitled “System and Method for Two-Step Payment Transaction Authorizations” ; 6,820,802 (the “’802 patent”) entitled “Wireless Transaction Medium Having Combined Magnetic Stripe and Radio Frequency Communications”; 8,584,938 (the “’938 patent”) entitled “System, Method, and Computer Program Product for Issuing and Using Debit Cards”; 8,905,301 (the “’301 patent”) entitled “Online Card Activation System and Method”, (collectively, the “Asserted Patents”).

In its complaint, the Plaintiff alleged that, “The Citi Defendants have and continue to directly and/or indirectly infringe (by inducing infringement) one or more claims of the Asserted patents in this District and elsewhere in Texas and the United States.”

The Plaintiff further alleged that, “On information and belief, the Citi Defendants design, develop, manufacture, distribute, sell, offer for sale, and use the Accused Instrumentalities that infringe the Asserted Patents, which include Citi Defendants’ offering, issuing, providing, registering, facilitating, maintaining, transacting, authenticating, and processing credit card and debit card accounts and related products and services for Citi’s customers, consumers, and clients.”

The Plaintiff further alleged that, “Defendant Citigroup directly infringes the Asserted Patents via 35 U.S.C. § 271(a) by making, offering for sale, selling, and/or using the Accused Instrumentalities, their components, and/or products and processes containing the same that incorporate the fundamental technologies covered by the Asserted Patents to, for example, its alter egos, agents, intermediaries, distributors, customers, subsidiaries, partners, affiliates, clients and/or consumers.”

The Plaintiff lists out four claims for relief. The first claim is for the alleged infringement of ’207 patent. The second claim is for the alleged infringement of ’938 patent. The third claim is for the alleged infringement of ’301 patent, and the fourth claim is for the alleged infringement of ’802 patent. 

In its prayer for relief, the Plaintiff requested the Court: to declare that the Defendants have infringed the Asserted Patents as alleged herein; pass a judgment for an accounting of damages sustained by Plaintiff; an order requiring Defendants to pay Plaintiff damages under 35 U.S.C. § 284, including up to treble damages as provided by 35 U.S.C. § 284, and any royalties determined to be appropriate. The Plaintiff further requested the Court to order the Defendants to pay the Plaintiff pre-judgment and post-judgment interest on the damages awarded, and an order finding this case exceptional and requiring the Defendants to pay the costs of this action. 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-00711

  • Filing Date:

    07/08/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

Liberty Peak Ventures, LLC

Defendants

Citigroup Inc.

CitiBank, N.A.

Attorney/Law Firm Details

Plaintiff Attorneys

Jeffrey Ray Bragalone

Attorney at Bragalone Olejko Saad PC

2200 Ross Avenue, Suite 4600W

Dallas, TX 75201

Marcus Benavides

Attorney at Bragalone Olejko Saad PC

2200 Ross Ave., Suite 4600W

Dallas, TX 75201

Terry A. Saad

Attorney at Bragalone Olejko Saad PC

2200 Ross Avenue, Suite 4600W

Dallas, TX 75201

Defendant Attorneys

Charles E. Phipps

Attorney at Locke Lord LLP

2200 Ross Avenue, Suite 2800

Dallas, TX 75201

Robert T. Mowrey

Attorney at Locke Lord LLP

2200 Ross Avenue, Suite 2200

Dallas, TX 75201-6766

Chelsea A. Loughran

Attorney at Wolf, Greenfield & Sacks, P.C.

600 Atlantic Avenue

Boston, MA 02210

Emma L. Frank

Attorney at Wolf, Greenfield & Sacks, P.C.

600 Atlantic Avenue

Boston, MA 02210

Michael N. Rader

Attorney at Wolf, Greenfield & Sacks, P.C.

605 Third Avenue, 25Th Floor

New York, NY 10158

Tonia A. Sayour

Attorney at Wolf, Greenfield & Sacks, P.C.

605 Third Avenue, 25Th Floor

New York, NY 10158

 

Court Documents

16 #1

Proposed Order

#16

15 #1

Proposed Order

#15

14 #1

Proposed Order

#14

13 #1

Proposed Order

#13

12 #1

Proposed Order

#8

#7

#6

#5

#4

#3

#2

1 #1

Civil Cover Sheet

#1

20 More Documents Available
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Docket Entries

  • 08/23/2021
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  • Docket(#16) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint or otherwise respond by CitiBank, N.A., Citigroup Inc.. (Attachments: #1 Proposed Order)(Phipps, Charles) Extended as requested on 8/23/2021 (ir). (Entered: 08/23/2021)

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  • 08/19/2021
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  • DocketText Order GRANTING #13 Motion to Appear Pro Hac Vice for Attorney Emma L. Frank for CitiBank, N.A., and for Citigroup Inc. Before the Court is the Motion for Admission Pro Hac Vice. The Court, having reviewed the Motion, finds it should be GRANTED and therefore orders as follows: IT IS ORDERED the Motion for Admission Pro Hac Vice is GRANTED. IT IS FURTHER ORDERED that Applicant, if he/she has not already done so, shall immediately tender the amount of $100.00, made payable to: Clerk, U.S. District Court, in compliance with Local Rule AT-I (f)(2). Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jc5) (Entered: 08/19/2021)

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  • 08/18/2021
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  • DocketText Order GRANTING #15 Motion to Appear Pro Hac Vice for Attorney Tonia A. Sayour for CitiBank, N.A., and for Citigroup Inc. Before the Court is the Motion for Admission Pro Hac Vice. The Court, having reviewed the Motion, finds it should be GRANTED and therefore orders as follows: IT IS ORDERED the Motion for Admission Pro Hac Vice is GRANTED. IT IS FURTHER ORDERED that Applicant, if he/she has not already done so, shall immediately tender the amount of $100.00, made payable to: Clerk, U.S. District Court, in compliance with Local Rule AT-I (f)(2). Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jc5) (Entered: 08/19/2021)

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  • 08/18/2021
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  • DocketText Order GRANTING #14 Motion to Appear Pro Hac Vice for Attorney Chelsea A. Loughran for CitiBank, N.A., and for Citigroup Inc. the court. There is no document associated with this entry.) Before the Court is the Motion for Admission Pro Hac Vice. The Court, having reviewed the Motion, finds it should be GRANTED and therefore orders as follows: IT IS ORDERED the Motion for Admission Pro Hac Vice is GRANTED. IT IS FURTHER ORDERED that Applicant, if he/she has not already done so, shall immediately tender the amount of $100.00, made payable to: Clerk, U.S. District Court, in compliance with Local Rule AT-I (f)(2). Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jc5) (Entered: 08/19/2021)

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  • 08/18/2021
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  • DocketText Order GRANTING #12 Motion to Appear Pro Hac Vice for Attorney Michael N. Rader for CitiBank, N.A., and for Citigroup Inc. Before the Court is the Motion for Admission Pro Hac Vice. The Court, having reviewed the Motion, finds it should be GRANTED and therefore orders as follows: IT IS ORDERED the Motion for Admission Pro Hac Vice is GRANTED. IT IS FURTHER ORDERED that Applicant, if he/she has not already done so, shall immediately tender the amount of $100.00, made payable to: Clerk, U.S. District Court, in compliance with Local Rule AT-I (f)(2). Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jc5) (Entered: 08/19/2021)

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  • 08/18/2021
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  • DocketText Order GRANTING #11 Motion to Appear Pro Hac Vice for Attorney Robert T. Maldonado for CitiBank, N.A., and for Citigroup Inc. Before the Court is the Motion for Admission Pro Hac Vice. The Court, having reviewed the Motion, finds it should be GRANTED and therefore orders as follows: IT IS ORDERED the Motion for Admission Pro Hac Vice is GRANTED. IT IS FURTHER ORDERED that Applicant, if he/she has not already done so, shall immediately tender the amount of $100.00, made payable to: Clerk, U.S. District Court, in compliance with Local Rule AT-I (f)(2). Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jc5) (Entered: 08/19/2021)

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  • 08/18/2021
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  • Docket(#15) MOTION to Appear Pro Hac Vice by Charles E. Phipps for Tonia A. Sayour ( Filing fee $ 100 receipt number 0542-15130962) by on behalf of CitiBank, N.A., Citigroup Inc.. (Attachments: #1 Proposed Order)(Phipps, Charles) (Entered: 08/18/2021)

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  • 08/18/2021
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  • Docket(#14) MOTION to Appear Pro Hac Vice by Charles E. Phipps for Chelsea A. Loughran ( Filing fee $ 100 receipt number 0542-15130947) by on behalf of CitiBank, N.A., Citigroup Inc.. (Attachments: #1 Proposed Order)(Phipps, Charles) (Entered: 08/18/2021)

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  • 08/18/2021
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  • Docket(#13) MOTION to Appear Pro Hac Vice by Charles E. Phipps for Emma L. Frank ( Filing fee $ 100 receipt number 0542-15130934) by on behalf of CitiBank, N.A., Citigroup Inc.. (Attachments: #1 Proposed Order)(Phipps, Charles) (Entered: 08/18/2021)

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  • 08/18/2021
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  • Docket(#12) MOTION to Appear Pro Hac Vice by Charles E. Phipps for Michael N. Rader ( Filing fee $ 100 receipt number 0542-15130925) by on behalf of CitiBank, N.A., Citigroup Inc.. (Attachments: #1 Proposed Order)(Phipps, Charles) (Entered: 08/18/2021)

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6 More Docket Entries
  • 07/14/2021
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  • Docket(#8) SUMMONS Returned Executed by Liberty Peak Ventures, LLC. Citigroup Inc. served on 7/12/2021, answer due 8/2/2021. (Saad, Terry) (Entered: 07/14/2021)

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  • 07/09/2021
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  • Docket(#7) Summons Issued as to CitiBank, N.A.. (ir) (Entered: 07/09/2021)

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  • 07/09/2021
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  • Docket(#6) Summons Issued as to Citigroup Inc.. (ir) (Entered: 07/09/2021)

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  • 07/09/2021
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  • Docket(#5) REQUEST FOR ISSUANCE OF SUMMONS by Liberty Peak Ventures, LLC. for CitiBank, N.A. (Saad, Terry) (Entered: 07/09/2021)

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  • 07/09/2021
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  • Docket(#4) REQUEST FOR ISSUANCE OF SUMMONS by Liberty Peak Ventures, LLC. for Citigroup, Inc. (Saad, Terry) (Entered: 07/09/2021)

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  • 07/09/2021
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  • Docket(#3) RULE 7 DISCLOSURE STATEMENT filed by Liberty Peak Ventures, LLC. (Saad, Terry) (Entered: 07/09/2021)

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  • 07/08/2021
  • 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: 07/08/2021)

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  • 07/08/2021
  • DocketAll parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 07/08/2021)

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  • 07/08/2021
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  • Docket(#2) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Saad, Terry) (Entered: 07/08/2021)

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  • 07/08/2021
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  • Docket(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number 0542-14991741). No Summons requested at this time, filed by Liberty Peak Ventures, LLC. (Attachments: #1 Civil Cover Sheet)(Saad, Terry) (Entered: 07/08/2021)

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