This case was last updated from PACER on 07/29/2021 at 15:56:14 (UTC).

Moxchange LLC v. Daikin America, Inc.

Case Summary

On May 24, 2021, Moxchange LLC (“Moxchange” or “Plaintiff”), represented by Jimmy C. Chong of The Chong Law Firm, P.A., filed an intellectual property lawsuit against Daikin America, Inc. (“Defendant”), seeking declaratory and injunctive relief, damages, along with prejudgment and post-judgment interest, for the alleged patent infringement of invention related to the field of wireless communication network security owned by the Plaintiff. This case was filed in U.S. District Court in the District of Delaware with Judge Leonard P. Stark presiding

 

The Plaintiff filed the complaint for the Defendant’s alleged direct infringement of United States Patent No. 7,233,664 (“the ‘664 Patent”) titled “Dynamic Security Authentication for Wireless Communication Networks.”

 

In its complaint, the Plaintiff alleged that, “Moxchange is the assignee of all right, title and interest in the ‘664 patent, including all rights to enforce and prosecute actions for infringement and to collect damages for all relevant times against infringers of the ‘664 Patent. Accordingly, Moxchange possesses the exclusive right and standing to prosecute the present action for infringement of the ‘664 Patent by Defendant.”

 

The Plaintiff further alleged that, “Upon information and belief, Defendant has been directly infringing claim 1 of the ‘664 patent in Delaware, and elsewhere in the United States, by performing actions comprising using or performing the claimed method of providing secure authentication between wireless communication network nodes by using and/or testing the Daikin ENVi (“Accused Instrumentality”).”

 

The Plaintiff also alleged that, “On information and belief, Defendant has had at least constructive notice of the ‘664 patent by operation of law and, to the extent required, marking requirements have been complied with.”

 

The only claim for relief laid down by the Plaintiff is for the alleged infringement of ‘664 Patent, wherein the Plaintiff claimed that, Defendant has used the patented inventions thereby committing, and continuing to commit, acts of patent infringement as alleged in the complaint. In addition, on information and belief, Defendant has derived revenues from its infringing acts and on information and belief, Defendant will continue its infringement of one or more claims of the ‘664 patent unless enjoined by the Court.

 

In its prayer for relief, the Plaintiff requested the Court to enter a judgment that one or more claims of United States Patent No. 7,233,664 have been infringed by Defendant and a judgment that Defendant account for and pay to Plaintiff all damages to and costs incurred by Plaintiff because of Defendant’s infringing activities and other conduct complained of in the complaint. The Plaintiff further requested that Defendant be enjoined from future infringing activities and Plaintiff be granted pre-judgment and post-judgment interest on the damages caused by Defendant’s infringing activities and other conduct complained of in the complaint and that Plaintiff be granted such other and further relief as the Court may deem just and proper under the circumstances.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    1:21-CV-00727

  • Filing Date:

    05/24/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

  • Courthouse:

    Delaware District

Judge Details

Presiding Judge

Leonard P. Stark

 

Party Details

Plaintiff

Moxchange LLC

Defendant

Daikin America, Inc.

Attorney/Law Firm Details

Plaintiff Attorneys

Jimmy C. Chong

Attorney at The Chong Law Firm, P.A.

2961 Centerville Road, Suite 350

Wilmington, DE 19808

David R. Bennett

Defendant Attorney

Jack B. Blumenfeld

Attorney at Morris, Nichols, Arsht & Tunnell LLP

1201 North Market Street, P.O. Box 1347

Wilmington, DE 19899

 

Court Documents

#9

(#9) STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to September 20, 2021 - filed by Daikin America, Inc.. (Blumenfeld, Jack) (Entered: 07/27/2021)

#8

(#8) STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to August 6, 2021 - filed by Daikin America, Inc.. (Blumenfeld, Jack) (Entered: 06/15/2021)

7 #1

Affidavit

#7

(#7) MOTION for Pro Hac Vice Appearance of Attorney David R. Bennett - filed by Moxchange LLC. (Attachments: #1 Affidavit)(Chong, Jimmy) (Entered: 06/15/2021)

#6

(#6) SUMMONS Returned Executed by Moxchange LLC. Daikin America, Inc. served on 6/2/2021, answer due 6/23/2021. (Chong, Jimmy) (Entered: 06/08/2021)

#5

(#5) Summonses Issued (please complete the top portion of the form and print out for use/service). (kmd) (Entered: 05/24/2021)

#4

(#4) Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed - filed by Moxchange LLC. (kmd) (Entered: 05/24/2021)

#3

(#3) Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) 7,233,664. (kmd) (Entered: 05/24/2021)

#2

(#2) Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (kmd) (Entered: 05/24/2021)

1 #3

Civil Cover Sheet

1 #2

Exhibit B

1 #1

Exhibit A

#1

(#1) COMPLAINT for Patent Infringement filed with Jury Demand against Daikin America, Inc. - Magistrate Consent Notice to Pltf. (Filing fee $402, receipt number ADEDC-3621523.) - filed by Moxchange LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet)(kmd) (Entered: 05/24/2021)

3 More Documents Available
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Docket Entries

  • 07/27/2021
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  • DocketSO ORDERED, re #9 STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to September 20, 2021 filed by Daikin America, Inc. Signed by Judge Leonard P. Stark on 7/27/21. (ntl) (Entered: 07/27/2021)

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  • 07/27/2021
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  • Docket(#9) STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to September 20, 2021 - filed by Daikin America, Inc.. (Blumenfeld, Jack) (Entered: 07/27/2021)

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  • 06/15/2021
  • DocketPro Hac Vice Attorney David R. Bennett for Moxchange LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (myr) (Entered: 06/15/2021)

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  • 06/15/2021
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  • DocketSO ORDERED, re #8 STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to August 6, 2021 filed by Daikin America, Inc. Signed by Judge Leonard P. Stark on 6/15/21. (ntl) (Entered: 06/15/2021)

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  • 06/15/2021
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  • Docket(#8) STIPULATION TO EXTEND TIME for defendant to respond to the Complaint to August 6, 2021 - filed by Daikin America, Inc.. (Blumenfeld, Jack) (Entered: 06/15/2021)

    Read MoreRead Less
  • 06/15/2021
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  • DocketSO ORDERED, re #7 MOTION for Pro Hac Vice Appearance of Attorney David R. Bennett filed by Moxchange LLC. Signed by Judge Leonard P. Stark on 6/15/21. (ntl) (Entered: 06/15/2021)

    Read MoreRead Less
  • 06/15/2021
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  • Docket(#7) MOTION for Pro Hac Vice Appearance of Attorney David R. Bennett - filed by Moxchange LLC. (Attachments: #1 Affidavit)(Chong, Jimmy) (Entered: 06/15/2021)

    Read MoreRead Less
  • 06/08/2021
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  • Docket(#6) SUMMONS Returned Executed by Moxchange LLC. Daikin America, Inc. served on 6/2/2021, answer due 6/23/2021. (Chong, Jimmy) (Entered: 06/08/2021)

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  • 05/26/2021
  • DocketCase Assigned to Judge Leonard P. Stark. Please include the initials of the Judge (LPS) after the case number on all documents filed. Associated Cases: 1:21-cv-00727-LPS, 1:21-cv-00728-LPS (rjb) (Entered: 05/26/2021)

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  • 05/24/2021
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  • Docket(#5) Summonses Issued (please complete the top portion of the form and print out for use/service). (kmd) (Entered: 05/24/2021)

    Read MoreRead Less
  • 05/24/2021
  • View Court Documents
  • Docket(#4) Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed - filed by Moxchange LLC. (kmd) (Entered: 05/24/2021)

    Read MoreRead Less
  • 05/24/2021
  • View Court Documents
  • Docket(#3) Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) 7,233,664. (kmd) (Entered: 05/24/2021)

    Read MoreRead Less
  • 05/24/2021
  • View Court Documents
  • Docket(#2) Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (kmd) (Entered: 05/24/2021)

    Read MoreRead Less
  • 05/24/2021
  • View Court Documents
  • Docket(#1) COMPLAINT for Patent Infringement filed with Jury Demand against Daikin America, Inc. - Magistrate Consent Notice to Pltf. (Filing fee $402, receipt number ADEDC-3621523.) - filed by Moxchange LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet)(kmd) (Entered: 05/24/2021)

    Read MoreRead Less
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