On March 29, 2021, Pineapple34, LLC (“Plaintiff”) represented by Isaac Rabicoff of Rabicoff Law LLC filed an intellectual property lawsuit against Dell Technologies Inc. (“Defendant”) seeking declaratory and monetary relief, for the alleged infringement of technology relating to modular computer user interface systems and various other technologies. This case was filed in U.S. District Court for the Western District of Texas with Judge Alan D. Albright presiding.
In its complaint, Plaintiff alleged that “Defendant has been and continues to directly infringe one or more claims of the ‘Patents-in-suit’ in at least this District by making, using, offering to sell, selling and/or importing, without limitation, at least the Defendant products identified in the charts incorporated into this Count below (among the “Exemplary Defendant Products”) that infringe at least the exemplary claims of the ‘Patents-in-suit’ also identified in the charts incorporated into this Count below (the “Exemplary ‘Patents-in-suit’ Claims”) literally or by the doctrine of equivalents. On information and belief, numerous other devices that infringe the claims of the ‘Patents-in-suit’ have been made, used, sold, imported, and offered for sale by Defendant and/or its customers. Defendant also has and continues to directly infringe, literally or under the doctrine of equivalents, the Exemplary ‘Patents-in-suit’ Claims, by having its employees internally test and use these Exemplary Products.”
Plaintiff further alleged that “The service of this Complaint, in conjunction with the attached claim charts and references cited, constitutes actual knowledge of infringement as alleged here. Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import into the United States, products that infringe the ’251 Patent and ’252 Patent. On information and belief, Defendant has also continued to sell the Exemplary Defendant Products and distribute product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the ’251 Patent and ’252 Patent.”
Plaintiff also alleged that “At least since being served by this Complaint and corresponding claim charts, Defendant has actively, knowingly, and intentionally continued to induce infringement of the ’251 Patent and ’252 Patent, literally or by the doctrine of equivalents, by selling Exemplary Defendant Products to their customers for use in end-user products in a manner that infringes one or more claims of the ’251 Patent and ’252 Patent.”
There are three claims for relief laid down by the plaintiff. The first claim is for the alleged infringement of ’251 patent; the second claim is for the alleged infringement of ’499 patent, and the third claim is for alleged the infringement of ’252 patent.
In its prayer for relief, the Plaintiff has requested the court to declare that the ‘patents-in-suit’ are valid and enforceable and the defendant has infringed directly and indirectly one or more claims of the ‘patents-in-suit’; Award appropriate damages under 35 U.S.C. § 284 for Defendant's continuing or future infringement of the ’251 and ’252 Patents, including pre or post judgment interest and for Defendant's past infringement of the ’499 Patent; Award litigation cost and attorney’s fees.
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Pending - Other Pending
Intellectual Property - Patent
Alan D Albright
Dell Technologies Inc.
Attorney at Rabicoff Law LLC
5680 King Centre Dr, Suite 645
Alexandria, VA 22315
Civil Cover Sheet
Docket(#7) NOTICE of Voluntary Dismissal by Pineapple34, LLC (Attachments: #1 Proposed Order)(Rabicoff, Isaac) (Entered: 04/07/2021)[+] Read More [-] Read Less
Docket(#6) Summons Issued as to Dell Technologies Inc.. (lad) (Entered: 03/30/2021)[+] Read More [-] Read Less
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: 03/30/2021)[+] Read More [-] Read Less
DocketAll parties shall comply with the Standing Orders of Judge Alan D. Albright located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 03/30/2021)[+] Read More [-] Read Less
Docket(#5) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Rabicoff, Isaac) (Entered: 03/29/2021)[+] Read More [-] Read Less
Docket(#4) REQUEST FOR ISSUANCE OF SUMMONS by Pineapple34, LLC. (Rabicoff, Isaac) (Entered: 03/29/2021)[+] Read More [-] Read Less
Docket(#3) RULE 7 DISCLOSURE STATEMENT filed by Pineapple34, LLC. (Rabicoff, Isaac) (Entered: 03/29/2021)[+] Read More [-] Read Less
Docket(#2) NOTICE of Attorney Appearance by Isaac Rabicoff on behalf of Pineapple34, LLC (Rabicoff, Isaac) (Entered: 03/29/2021)[+] Read More [-] Read Less
Docket(#1) COMPLAINT FOR PATENT INFRINGEMENT ( Filing fee $ 402 receipt number 0542-14641753), filed by Pineapple34, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Civil Cover Sheet)(Rabicoff, Isaac) (Entered: 03/29/2021)[+] Read More [-] Read Less
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