This case was last updated from U.S. District Courts on 02/11/2022 at 07:40:23 (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

John E. Schiltz

Matthew R. Berry

Robert Christopher Bunt

Charles L. Ainsworth

Komal S. Patel

Defendant Attorneys

Evan Mann

Gregory T.S. Bischoping

Heather E. Takahashi

Zachary M. Briers

Brian Christopher Banner

 

Court Documents

#19

(#19) ORDER GRANTING #15 Motion to Appear Pro Hac Vice for Attorney Gregory T.S. Bischoping for Google LLC. 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. Signed by Judge Alan D Albright. (ir) (Entered: 01/07/2022)

#18

(#18) ORDER GRANTING #14 Motion to Appear Pro Hac Vice for Attorney Evan Mann. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

#17

(#17) ORDER GRANTING #13 Motion to Appear Pro Hac Vice for Attorney Heather E. Takahashi. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

#16

(#16) ORDER GRANTING #12 Motion to Appear Pro Hac Vice for Attorney Zachary M. Briers. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

#15

(#15) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Gregory T.S. Bischoping ( Filing fee $ 100 receipt number 0542-15582019) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

#14

(#14) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Evan Mann ( Filing fee $ 100 receipt number 0542-15581991) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

#13

(#13) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Heather E. Takahashi ( Filing fee $ 100 receipt number 0542-15581969) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

#12

(#12) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Zachary M. Briers ( Filing fee $ 100 receipt number 0542-15581943) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

#11

(#11) ORDER GRANTING #7 Motion to Appear Pro Hac Vice for Attorney Komal S. Patel for Nobots LLC. 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. Signed by Judge Alan D Albright. (zv) (Entered: 12/28/2021)

#6

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

#5

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

#4

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

#3

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

#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)

1 #3

Exhibit B

1 #2

Exhibit A

1 #1

Civil Cover Sheet

#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)

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Docket Entries

  • 01/07/2022
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  • Docket(#19) ORDER GRANTING #15 Motion to Appear Pro Hac Vice for Attorney Gregory T.S. Bischoping for Google LLC. 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. Signed by Judge Alan D Albright. (ir) (Entered: 01/07/2022)

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  • 01/07/2022
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  • Docket(#18) ORDER GRANTING #14 Motion to Appear Pro Hac Vice for Attorney Evan Mann. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

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  • 01/07/2022
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  • Docket(#17) ORDER GRANTING #13 Motion to Appear Pro Hac Vice for Attorney Heather E. Takahashi. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

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  • 01/07/2022
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  • Docket(#16) ORDER GRANTING #12 Motion to Appear Pro Hac Vice for Attorney Zachary M. Briers. Attorney added for Google LLC. 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, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (jkda) (Entered: 01/07/2022)

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  • 01/05/2022
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  • Docket(#15) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Gregory T.S. Bischoping ( Filing fee $ 100 receipt number 0542-15582019) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

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  • 01/05/2022
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  • Docket(#14) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Evan Mann ( Filing fee $ 100 receipt number 0542-15581991) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

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  • 01/05/2022
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  • Docket(#13) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Heather E. Takahashi ( Filing fee $ 100 receipt number 0542-15581969) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

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  • 01/05/2022
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  • Docket(#12) MOTION to Appear Pro Hac Vice by Brian Christopher Banner on behalf of Zachary M. Briers ( Filing fee $ 100 receipt number 0542-15581943) by on behalf of Google LLC. (Banner, Brian) (Entered: 01/05/2022)

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  • 12/21/2021
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  • Docket(#11) ORDER GRANTING #7 Motion to Appear Pro Hac Vice for Attorney Komal S. Patel for Nobots LLC. 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. Signed by Judge Alan D Albright. (zv) (Entered: 12/28/2021)

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  • 12/21/2021
  • DocketReset Deadlines: Google LLC answer due 2/17/2022. (ir) (Entered: 12/27/2021)

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2 More Docket Entries
  • 12/17/2021
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  • Docket(#8) SUMMONS Returned Executed by Nobots LLC. Google LLC served on 12/13/2021, answer due 1/3/2022. (Ainsworth, Charles) (Entered: 12/17/2021)

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  • 12/17/2021
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  • Docket(#7) MOTION to Appear Pro Hac Vice by Charles L. Ainsworth on behalf of Komal S. Patel ( Filing fee $ 100 receipt number 0542-15546486) by on behalf of Nobots LLC. (Attachments: #1 Proposed Order)(Ainsworth, Charles) (Entered: 12/17/2021)

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  • 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
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  • 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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