This case was last updated from PACER on 03/30/2021 at 11:26:05 (UTC).

Lynk Labs, Inc. v. Home Depot USA, Inc. et al

Case Summary

On January 29, 2021, Plaintiff, Lynk Labs, Inc. (“Lynk”), represented by Darlene F. Ghavimi, James A. Shimota, Devon C. Beane and Nelson M. Hua of K&L Gates LLP, filed an intellectual property lawsuit against Home Depot USA, Inc., The Home Depot Inc., and Home Depot Product Authority, (collectively “Home Depot”), represented by Aaron Fountain of DLA Piper LLP, seeking damages and injunctive relief for Defendant's alleged wilful infringement of one or more claims of Patents relating to LEDs 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.

 

In their complaint, the Plaintiff alleged that Home Depot has willfully infringed their U.S. Patent Nos. 10,492,251 entitled “AC Light Emitting Diode and AC LED Drive Methods and Apparatus,” (the “’251 Patent”); 10,757,783 entitled “Color Temperature Controlled and Low THD LED Lighting Devices and Systems and Methods of Driving the Same,” (the “’783 Patent”); 10,091,842 entitled “AC Light Emitting Diode and AC LED Drive Methods and Apparatus,” (the “’842 Patent”); 10,537,001 entitled “Multi-voltage and Multi-brightness LED Lighting Devices and Methods of Using Same,” (the “’001 Patent”); 10,349,479 entitled “Color Temperature Controlled and Low THD LED Lighting Devices and Systems and Methods of Driving the Same,” (the “’479 Patent”); 10,652,979 entitled “LED Lighting System” (the “’979 Patent”); 10,154,551 entitled “AC Light Emitting Diode and AC LED Drive Methods and Apparatus,” (the “’551 Patent”); and 10,517,149 entitled “AC Light Emitting Diode and AC LED Drive Methods and Apparatus”  (the “’149 Patent”) (collectively “the Patents-in-Suit”).

 

The Plaintiff alleged that “Home Depot is and has been willfully infringing many of Lynk’s patents for years and attempting to transfer its legal responsibilities off to its suppliers with no regard for the ongoing burden it presents to a small business like Lynk.”

 

Further, the Plaintiff alleged that “Lynk has invested almost three years in attempting to resolve Home Depot’s infringement of Lynk’s patents without litigation, but has been left with no other option but to file the present lawsuit.”

 

The Plaintiff laid down eight reliefs for claim, one for the infringement of each of the Patents 251, 783, 842, 001, 479, 979, 551 and 149 respectively, wherein it has been alleged that Home Depot imports, offers for sale, and sells certain private label LED lights, which directly infringe one or more claims under Patents-in-suit and that through its private label, it induced, aided, instructed or otherwise caused the end user to use their infringing products in absolute disregard to the the infringement. Plaintiff further goes on to claim that Home Depot had the knowledge of such infringement and has opted to be wilfully blind to such infringement.

 

In its prayer for relief, Plaintiff requested that the court permanently enjoins Home Depot from further infringement of the Patents-in-Suit, find Home Depot liable for the infringement, award damages adequate to compensate past infringement by Home Decor including interests and costs, and declare this as an exceptional case so as to increase the amount of damages to at least three times the amount found by jury or assessed by the court along with attorney fees. 

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-00097

  • Filing Date:

    01/29/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

Lynk Labs, Inc.

Defendants

Home Depot Product Authority, LLC

The Home Depot Inc.

Home Depot USA, Inc.

Attorney/Law Firm Details

Plaintiff Attorneys

Darlene Ghavimi

Attorney at K&L Gates

2801 Via Fortuna, Suite 350

Austin, TX 78746

James A. Shimota

Attorney at K&L Gates LLP

70 W. Madison Street, Suite 3300

Chicago, IL 60602

Devon C. Beane

Attorney at K&L Gates LLP

70 W. Madison Street, Suite 3300

Chicago, IL 60602

Nelson M. Hua

Attorney at K&L Gates LLP

70 W. Madison Street, Suite 3300

Chicago, IL 60602

Defendant Attorney

Aaron Fountain

Attorney at DLA Piper LLP

401 Congress, Suite 2500

Austin, TX 78701

 

Court Documents

#18

(#18) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Ghavimi, Darlene) (Entered: 03/17/2021)

17 #21

Exhibit U

17 #20

Exhibit T

17 #17

Exhibit Q

17 #15

Exhibit O

17 #14

Exhibit N

17 #13

Exhibit M

17 #12

Exhibit L

17 #1

Exhibit A

1 #14

Exhibit N

1 #13

Exhibit M

1 #12

Exhibit L

1 #11

Exhibit K

1 #10

Exhibit J

1 #9

Exhibit I

1 #8

Exhibit H

1 #7

Exhibit G

1 #4

Exhibit D

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Docket Entries

  • 03/17/2021
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  • Docket(#18) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Ghavimi, Darlene) (Entered: 03/17/2021)

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  • 03/17/2021
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  • Docket(#17) AMENDED COMPLAINT for Patent Infringement against Home Depot Product Authority, LLC, Home Depot USA, Inc., The Home Depot Inc. amending, filed by Lynk Labs, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U)(Ghavimi, Darlene) (Entered: 03/17/2021)

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  • 03/11/2021
  • DocketReset Deadlines: Home Depot Product Authority, LLC answer due 4/12/2021; Home Depot USA, Inc. answer due 4/12/2021; The Home Depot Inc. answer due 4/12/2021. (am) (Entered: 03/11/2021)

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  • 03/11/2021
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  • DocketText Order GRANTING #15 Motion for Extension of Time to Answer entered by Judge Alan D Albright. Defendants Home Depot USA, Inc., The Home Depot Inc., and Home Depot Product Authority, LLC's deadline to answer, move, or otherwise respond to Lynk Labs' Complaint (Dkt. 1) is extended until April 12, 2021. (This is a text-only entry generated by the court. There is no document associated with this entry.) (re) (Entered: 03/11/2021)

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  • 02/23/2021
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  • Docket(#15) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint,, or Otherwise Respond by Home Depot Product Authority, LLC, Home Depot USA, Inc., The Home Depot Inc.. (Attachments: #1 Proposed Order)(Fountain, Aaron) (Entered: 02/23/2021)

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  • 02/12/2021
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  • Docket(#16) Standing Order Regarding Filing Documents Under Seal and Redacted Pleadings in Patent Cases. Signed by Judge Alan D Albright. as of 2/12/2021. (bot1) (Entered: 02/25/2021)

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  • 02/08/2021
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  • Docket(#14) SUMMONS Returned Executed by Lynk Labs, Inc.. Home Depot Product Authority, LLC served on 2/4/2021, answer due 2/25/2021. (Ghavimi, Darlene) (Entered: 02/08/2021)

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  • 02/08/2021
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  • Docket(#13) SUMMONS Returned Executed by Lynk Labs, Inc.. The Home Depot Inc. served on 2/4/2021, answer due 2/25/2021. (Ghavimi, Darlene) (Entered: 02/08/2021)

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  • 02/08/2021
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  • Docket(#12) SUMMONS Returned Executed by Lynk Labs, Inc.. Home Depot USA, Inc. served on 2/4/2021, answer due 2/25/2021. (Ghavimi, Darlene) (Entered: 02/08/2021)

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  • 02/04/2021
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  • DocketText Order GRANTING #11 Motion to Appear Pro Hac Vice for Attorney Nelson M. Hua for Lynk Labs, 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.) (mm6) (Entered: 02/04/2021)

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3 More Docket Entries
  • 02/01/2021
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  • Docket(#10) MOTION to Appear Pro Hac Vice by Darlene Ghavimi for Devon C. Beane ( Filing fee $ 100 receipt number 0542-14435540) by on behalf of Lynk Labs, Inc.. (Ghavimi, Darlene) (Entered: 02/01/2021)

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  • 02/01/2021
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  • Docket(#9) MOTION to Appear Pro Hac Vice by Darlene Ghavimi for James A. Shimota ( Filing fee $ 100 receipt number 0542-14435476) by on behalf of Lynk Labs, Inc.. (Ghavimi, Darlene) (Entered: 02/01/2021)

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  • 02/01/2021
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  • Docket(#8) Summons Issued as to Home Depot Product Authority, LLC. (lad) (Entered: 02/01/2021)

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  • 02/01/2021
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  • Docket(#7) Summons Issued as to The Home Depot Inc.. (lad) (Entered: 02/01/2021)

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  • 02/01/2021
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  • Docket(#6) Summons Issued as to Home Depot USA, Inc.. (lad) (Entered: 02/01/2021)

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  • 01/29/2021
  • 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: 02/01/2021)

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  • 01/29/2021
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  • Docket(#4) REQUEST FOR ISSUANCE OF SUMMONS by Lynk Labs, Inc.. to Defendants Home Depot USA, Inc., The Home Depot Inc., and Home Depot Product Authority, LLC (Ghavimi, Darlene) (Entered: 01/29/2021)

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  • 01/29/2021
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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. (Ghavimi, Darlene) (Entered: 01/29/2021)

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  • 01/29/2021
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  • Docket(#2) RULE 7 DISCLOSURE STATEMENT filed by Lynk Labs, Inc.. (Ghavimi, Darlene) (Entered: 01/29/2021)

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  • 01/29/2021
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  • Docket(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-14432046), filed by Lynk Labs, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Civil Cover Sheet)(Ghavimi, Darlene) (Entered: 01/29/2021)

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