Linquet Technologies, Inc. v. Tile, Inc.
Case Summary
On July 27, 2020, Linquet Technologies, Inc. (“Linquet” or “Plaintiff”), represented by Helen E. Chacon, R. Trevor Carter and Reid E. Dodge of Faegre Drinker Biddle & Reath LLP, filed an intellectual property lawsuit against Tile, Inc. (“Tile”), represented by Katherine A. Burgess, Mark Roy Ryoichi Oda, Puneet Kohli and Sarah J. Guske of Baker Botts LLP, seeking declaratory and injunctive relief along with damages for alleged infringement of U.S. Patent owned by Plaintiff. This case was filed in the U.S. District Court for the Northern District of California, with Judges Nathanael M. Cousins and James Donato presiding.
The plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 10,163,318 (the “’318 Patent”) entitled “comprehensive system and method of universal real-time linking of real objects to a machine, network, internet, or software service,” owned by the plaintiff.
In the complaint, the plaintiff stated, “Founded in 2010, Linquet is an innovator in location technologies solutions, including, in particular, cloud-based/community-based solutions for locating and protecting mobile devices, keys, pets, luggage, and other items. Linquet has invested heavily in developing its innovative cloud-based solution to protect and locate items.”
The plaintiff further stated, “In doing so, Linquet has acquired an array of intellectual property rights, including but not limited to multiple patent rights for its innovations. Those patents include, for example, the ’318 Patent, which are and have been published at https://linquet.com/patents since at least December 25, 2018.”
The plaintiff alleged, “Despite its pioneering innovations, Linquet has struggled to obtain significant sales or funding. On information and belief, this is at least partly due to Tile’s infringing products and services. Tile’s infringing products include, for example and without limitation, the Tile Sticker, Tile Slim, Tile Pro, Tile Mate, and Tile embeddable technology (collectively, ‘Tile’s Tags’), which are designed for use with Tile’s App/Software and Tile’s cloud, which include, for example, Tile’s community find feature. Hereinafter, Tile’s Tags, Tile’s App/Software, and Tile’s cloud, are collectively referred to as the ‘Tile System’.”
Plaintiff further alleged, “Tile has infringed and continues to infringe directly, jointly, contributorily, and/or by inducement one or more claims of the ’318 Patent by its actions in connection with the Tile System. Tile also sells and offers for sale accessories specifically designed for and sold with the Tile System. Tile’s infringement has been, and continues to be, willful and deliberate.”
The plaintiff then alleged, “On January 27, 2020, Linquet, through counsel, also notified Tile of its infringing conduct. With this letter, Linquet provided a copy of the ’318 Patent and a claim chart specifically describing how the Tile System infringed at least claim 1 of the ’318 Patent. Despite Linquet’s best efforts, Tile has so far refused to engage in reasonable and good-faith discussions to resolve this matter outside of litigation.”
The plaintiff also alleged, “Linquet has been substantially and irreparably harmed by Tile’s direct infringement of at least claims 1 and 2 of the ’318 Patent, and will continue to be substantially and irreparably harmed.”
Plaintiff stated one claim for the alleged infringement of U.S. Patent No. 10,163,318.
In its prayer for relief, Plaintiff requested a judgment for declaratory and injunctive relief. The plaintiff also requested an award for costs and damages along with pre- and post-judgement interest.
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Case Details
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Case Number:
3:20-CV-05153
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Filing Date:
07/27/2020
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Case Status:
Disposed - Other Disposed
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Case Type:
Intellectual Property - Patent
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Court:
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Courthouse:
Judge Details
Presiding Judges
Nathanael M. Cousins
James Donato
Party Details
Plaintiff
Linquet Technologies, Inc.
Defendant
Tile, Inc.
Attorney/Law Firm Details
Plaintiff Attorneys
Helen Elizabeth Chacon
Attorney at Faegre Drinker Biddle & Reath LLP
1950 University Avenue, Suite 450
East Palo Alto, CA 94303
R. Trevor Carter
Attorney at Faegre Drinker Biddle & Reath LLP
300 N. Meridian Street, Suite 2500
Indianapolis, IN 46204
Justin Dean Schneider
Attorney at Keker, Van Nest & Peters LLP
530 Downing Street
Denver, CO 80218
Reid E. Dodge
Attorney at Faegre Drinker Biddle & Reath LLP
300 N. Meridian Street, Suite 2500
Indianapolis, IN 46204
Defendant Attorneys
Sarah JoAnn Guske
Attorney at Baker Botts LLP
101 California Street, Suite 3200
San Francisco, CA 94111
Katherine Anne Burgess
Attorney at Baker Botts, LLP
101 California Street, Suite 3600
San Francisco, CA 94111
Mark Roy Ryoichi Oda
Attorney at Baker Botts LLP
101 California Street, Suite 3600
San Francisco, CA 94111
Puneet Kohli
Attorney at Baker Botts L.L.P.
98 San Jacinto Blvd., Suite 1500
Austin, TX 78701
Court Documents
(#82) JUDGMENT. Signed by Judge James Donato on 7/18/2022. (jdlc3, COURT STAFF) (Filed on 7/18/2022) (Entered: 07/18/2022)
(#81) ORDER RE MOTION TO DISMISS. Signed by Judge James Donato on 7/18/2022. (jdlc3, COURT STAFF) (Filed on 7/18/2022) (Entered: 07/18/2022)
(#79) ORDER RE STIPULATED MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF. Signed by Judge James Donato on 4/6/2022. (jdlc3, COURT STAFF) (Filed on 4/6/2022) (Entered: 04/06/2022)
(#78) ADMINISTRATIVE MOTION to Withdraw JD Schneider as Counsel filed by Linquet Technologies, Inc.. Responses due by 4/4/2022. (Schneider, Justin) (Filed on 3/31/2022) (Entered: 03/31/2022)
(#77) NOTICE of Appearance by Katherine Anne Burgess (Burgess, Katherine) (Filed on 1/26/2022) (Entered: 01/26/2022)
Exhibit A - Mentone v Digi Intl
Main Document
(#74) REPLY (re #72 MOTION to Dismiss Second Amended Complaint ) filed byTile, Inc.. (Guske, Sarah) (Filed on 11/12/2021) (Entered: 11/12/2021)
Appendix 1
Civil Cover Sheet
Exhibit C - Claim Chart
Exhibit B - Demand Letter
Exhibit A - US Pat 10,163,318
Docket Entries
- 07/18/2022
- View Court Documents
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Docket(#82) JUDGMENT. Signed by Judge James Donato on 7/18/2022. (jdlc3, COURT STAFF) (Filed on 7/18/2022) (Entered: 07/18/2022)
- 07/18/2022
- View Court Documents
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Docket(#81) ORDER RE MOTION TO DISMISS. Signed by Judge James Donato on 7/18/2022. (jdlc3, COURT STAFF) (Filed on 7/18/2022) (Entered: 07/18/2022)
- 07/05/2022
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Docket(#80) ORDER. The Court vacates all pretrial and trial dates pending further order. Signed by Judge James Donato on 7/5/2022. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jdlc3, COURT STAFF) (Filed on 7/5/2022) (Entered: 07/05/2022)
- 04/06/2022
- View Court Documents
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Docket(#79) ORDER RE STIPULATED MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF. Signed by Judge James Donato on 4/6/2022. (jdlc3, COURT STAFF) (Filed on 4/6/2022) (Entered: 04/06/2022)
- 03/31/2022
- View Court Documents
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Docket(#78) ADMINISTRATIVE MOTION to Withdraw JD Schneider as Counsel filed by Linquet Technologies, Inc.. Responses due by 4/4/2022. (Schneider, Justin) (Filed on 3/31/2022) (Entered: 03/31/2022)
- 01/26/2022
- View Court Documents
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Docket(#77) NOTICE of Appearance by Katherine Anne Burgess (Burgess, Katherine) (Filed on 1/26/2022) (Entered: 01/26/2022)
- 11/24/2021
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Docket(#76) ORDER. The motion to dismiss, Dkt. No. 72, is suitable for decision without oral argument pursuant to Civil Local Rule 7-1(b). The hearing that was set for December 2, 2021, is vacated. Signed by Judge James Donato on 11/24/2021. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jdlc3, COURT STAFF) (Filed on 11/24/2021) (Entered: 11/24/2021)
- 11/16/2021
- View Court Documents
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Docket(#75) Statement of Recent Decision by Linquet Technologies, Inc.. (Attachments: #1 Exhibit A - Mentone v Digi Intl)(Dodge, Reid) (Filed on 11/16/2021) (Entered: 11/16/2021)
- 11/12/2021
- View Court Documents
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Docket(#74) REPLY (re #72 MOTION to Dismiss Second Amended Complaint ) filed byTile, Inc.. (Guske, Sarah) (Filed on 11/12/2021) (Entered: 11/12/2021)
- 11/05/2021
- View Court Documents
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Docket(#73) OPPOSITION/RESPONSE (re #72 MOTION to Dismiss Second Amended Complaint ) filed byLinquet Technologies, Inc.. (Schneider, Justin) (Filed on 11/5/2021) (Entered: 11/05/2021)
- 08/07/2020
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Docket(#10) CLERK'S NOTICE OF IMPENDING REASSIGNMENT TO A U.S. DISTRICT COURT JUDGE: The Clerk of this Court will now randomly reassign this case to a District Judge because a party has not consented to the jurisdiction of a Magistrate Judge. You will be informed by separate notice of the district judge to whom this case is reassigned. ALL HEARING DATES PRESENTLY SCHEDULED BEFORE THE CURRENT MAGISTRATE JUDGE ARE VACATED. This is a text only docket entry; there is no document associated with this notice. (lmh, COURT STAFF) (Filed on 8/7/2020) (Entered: 08/07/2020)
- 08/07/2020
- View Court Documents
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Docket(#9) CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by Linquet Technologies, Inc... (Carter, R.) (Filed on 8/7/2020) (Entered: 08/07/2020)
- 08/05/2020
- View Court Documents
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Docket(#8) WAIVER OF SERVICE Returned Executed filed by Linquet Technologies, Inc.. Service waived by Tile, Inc. waiver sent on 7/28/2020, answer due 9/28/2020. (Carter, R.) (Filed on 8/5/2020) (Entered: 08/05/2020)
- 07/29/2020
- View Court Documents
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Docket(#7) ORDER GRANTING #6 APPLICATION for Admission of Attorney R. Trevor Carter Pro Hac Vice representing Plaintiff. Signed by Judge Nathanael Cousins. (lmhS, COURT STAFF) (Filed on 7/29/2020) (Entered: 07/29/2020)
- 07/28/2020
- View Court Documents
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Docket(#6) MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 310, receipt number 0971-14746512.) filed by Linquet Technologies, Inc.. (Attachments: #1 Certificate of Good Standing)(Carter, R.) (Filed on 7/28/2020) (Entered: 07/28/2020)
- 07/28/2020
- View Court Documents
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Docket(#5) Initial Case Management Scheduling Order with ADR Deadlines: Case Management Statement due by 10/21/2020. Initial Case Management Conference set for 10/28/2020 10:00 AM in San Jose, Courtroom 5, 4th Floor. (sfbS, COURT STAFF) (Filed on 7/28/2020) (Entered: 07/28/2020)
- 07/27/2020
- View Court Documents
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Docket(#4) Certificate of Interested Entities by Linquet Technologies, Inc. identifying Other Affiliate Xatash Corp., Other Affiliate Yabert Capital Inc., Other Affiliate Initio Capital II Limited, Other Affiliate Zachary Levow, Other Affiliate CBinoor Inc., Other Affiliate Curiam Investments 2, LLC, Other Affiliate Faegre Drinker Biddle & Reath LLP for Linquet Technologies, Inc.. (Chacon, Helen) (Filed on 7/27/2020) (Entered: 07/27/2020)
- 07/27/2020
- View Court Documents
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Docket(#3) REPORT on the filing or determination of an action regarding US Patent No. 10,163,318 (cc: form mailed to register). (Chacon, Helen) (Filed on 7/27/2020) (Entered: 07/27/2020)
- 07/27/2020
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Docket(#2) Case assigned to Judge Nathanael M. Cousins. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. Counsel is required to send chambers a copy of the initiating documents pursuant to L.R. 5-1(e)(7). A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 8/10/2020. (bwS, COURT STAFF) (Filed on 7/27/2020) (Entered: 07/27/2020)
- 07/27/2020
- View Court Documents
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Docket(#1) COMPLAINT against Tile, Inc. ( Filing fee $ 400, receipt number 0971-14740701.). Filed byLinquet Technologies, Inc.. (Attachments: #1 Exhibit A - US Pat 10,163,318, #2 Exhibit B - Demand Letter, #3 Exhibit C - Claim Chart, #4 Civil Cover Sheet)(Chacon, Helen) (Filed on 7/27/2020) (Entered: 07/27/2020)
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