This case was last updated from U.S. District Courts on 12/14/2021 at 07:45:57 (UTC).

Nobots LLC v. Google LLC

Case Summary

On December 13, 2021, Nobots LLC (“Nobots” or “Plaintiff”), represented by Andres Healy, John E. Schiltz and Matthew R. Berry of Susman Godfrey, LLP and Charles L. Ainsworth and Robert Christopher Bunt of Parket, Bunt & Ainsworth, PC, filed an intellectual property lawsuit against Google, LLC (“Google” or “Defendant”), seeking declaratory reliefs and damages along with pre- and post-judgement interest for the Defendant’s alleged infringement of the United States 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 complaint for the alleged infringement of the United States Patent No. 9,595,008 (the “’008 Patent”) and United States Patent No. 10,423,885 (the “’885 Patent”) (collectively, “Patents-in-suit”) owned by the Plaintiff. 

 

In the complaint, the Plaintiff alleged that, “Google has infringed and continues to infringe at least claim l of the ’008 Patent in violation of 35 U.S.C. § 271, either literally or through the doctrine of equivalents, by making, using, selling, or offering for sale in the United States, and/or importing into the United States, without authorization, utilities that practice at least Claim 1 of the ’008 Patent. Google is liable for its infringement of the ’008 Patent pursuant to 35 U S.C § 271(a), (b), and (c).” The Plaintiff then alleged that, “More specifically, Google designs, implements, imports, offers for sale, and/or sells CAPTCHA security methods that assess a confidence level that an operator of a client computing device interacting with a server is a human being rather than an autonomic computer application, or bot, based on a comparison of monitored user data and generates a value representing a confidence level that a human, and not a bot, is operating the client computing device.”

 

The Plaintiff also alleged that, “Google committed and is committing the foregoing infringing activities without license from Nobots. Google’s acts of infringement have damaged Nobots, as owner and assignee of the ’008 Patent. Nobots is entitled to recover from Google the damages it has sustained as a result of Google’s wrongful acts in an amount subject to proof at trial.” The Plaintiff then alleged that, “In addition, Google indirectly infringed, and continues to indirectly infringe, the '008 Patent by actively inducing its infringement in violation 35 U.S.C. § 271(b).”

 

The Plaintiff further alleged that, “Google knowingly induced and induces these acts of infringement with the specific intent to encourage them by taking active steps to encourage and facilitate direct infringement by these third parties, in this District and elsewhere in the United States, through its design, construction, and sale of the infringing products.” The Plaintiff also alleged that, “In addition, Google has indirectly infringed and continues to indirectly infringe the '008 Patent as a contributory infringer in violation of 35 U.S.C. § 271(c) by selling or offering to sell in the United States, or importing into the United States.”

 

Similar allegations have been made by the Plaintiff with reference to the alleged infringement of other Patents-in-suit. 

 

There are two claims for relief laid down by the Plaintiff, one for the alleged infringement of each of the Patents-in-suit.

 

In their prayer for relief, the Plaintiff requested the Court for declaratory reliefs and damages along with a reasonable royalty together with treble damages for willful infringement. The Plaintiff also requested the Court for pre- and post-judgment interest; costs; attorneys’ fees; supplemental damages to Nobots, including any ongoing royalties and interest; and any other relief the Court deems just and proper.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-01290

  • Filing Date:

    12/13/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

Nobots LLC

Defendant

Google LLC

Attorney/Law Firm Details

Plaintiff Attorneys

Andres Healy

Attorney at Susman Godfrey L.L.P.

1201 Third Avenue, Suite 3800

Seattle, WA 98101

John E. Schiltz

Attorney at Susman Godfrey LLP

1201 Third Avenue, Ste. 3800

Seattle, WA 98101

Matthew R. Berry

Attorney at Susman Godfrey, L.L.P.

1201 Third Ave., Suite 3800

Seattle, WA 98101

Robert Christopher Bunt

Attorney at Parker, Bunt & Ainsworth, P.C.

100 East Ferguson, Ste. 418

Tyler, TX 75702

Charles L. Ainsworth

Attorney at Parker, Bunt & Ainsworth, P.C.

100 East Ferguson, Suite 418

Tyler, TX 75702

 

Court Documents

#1

(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number 0542-15527254), filed by Nobots LLC. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B)(Ainsworth, Charles) (Entered: 12/13/2021)

1 #1

Civil Cover Sheet

1 #2

Exhibit A

1 #3

Exhibit B

#2

(#2) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Ainsworth, Charles) (Entered: 12/13/2021)

#3

(#3) RULE 7 DISCLOSURE STATEMENT filed by Nobots LLC. (Ainsworth, Charles) (Entered: 12/13/2021)

#4

(#4) REQUEST FOR ISSUANCE OF SUMMONS by Nobots LLC. (Ainsworth, Charles) (Entered: 12/13/2021)

#5

(#5) Pro Hac Vice Letter to Komal S. Patel. (lad) (Entered: 12/13/2021)

#6

(#6) Summons Issued as to Google LLC. (lad) (Entered: 12/13/2021)

 

Docket Entries

  • 12/13/2021
  • 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: 12/13/2021)

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  • 12/13/2021
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  • Docket(#6) Summons Issued as to Google LLC. (lad) (Entered: 12/13/2021)

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  • 12/13/2021
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  • Docket(#5) Pro Hac Vice Letter to Komal S. Patel. (lad) (Entered: 12/13/2021)

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  • 12/13/2021
  • DocketAll parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 12/13/2021)

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  • 12/13/2021
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  • Docket(#4) REQUEST FOR ISSUANCE OF SUMMONS by Nobots LLC. (Ainsworth, Charles) (Entered: 12/13/2021)

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  • 12/13/2021
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  • Docket(#3) RULE 7 DISCLOSURE STATEMENT filed by Nobots LLC. (Ainsworth, Charles) (Entered: 12/13/2021)

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  • 12/13/2021
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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. (Ainsworth, Charles) (Entered: 12/13/2021)

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  • 12/13/2021
  • View Court Documents
  • Docket(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number 0542-15527254), filed by Nobots LLC. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B)(Ainsworth, Charles) (Entered: 12/13/2021)

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