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This case was last updated from PACER on 05/28/2021 at 10:51:48 (UTC).

Proven Networks, LLC v. Juniper Networks, Inc.

Case Summary

On March 29, 2021, Proven Networks, LLC (“Plaintiff” or “Proven Networks”) represented by Benjamin T. Wang, Brian D. Ledahl, Marc A. Fenster, Paul A. Kroeger and Riza Mirzaie of Russ August and Kabat filed an intellectual property lawsuit against Juniper Networks, Inc. (“Defendant”) seeking declaratory and monetary relief, with pre-judgment and post-judgment interest thereon for the alleged infringement of technology relating to Equal-Cost Source-Resolved Routing System and Method and various other technologies. This case was filed in U.S. District Court for the Western District of Texas with the Judge Alan D. Albright presiding.

The complaint filed by the Plaintiff is for the alleged breach by Defendant of the following United States patents owned by Proven Networks, each of which generally relate to data networking technology: United States Patent Nos. 8,018,852 (“’852 Patent”); 8,165,024 (“’024 Patent”); and 8,687,573 (the “’573 Patent”) (collectively, the “Asserted Patents”).

In its complaint, Plaintiff alleged that “Defendant also knowingly and intentionally induces infringement of claims 1–39 of the ‘Asserted Patents’ in violation of 35 U.S.C. § 271(b). At least through the filing and service of this Complaint, Defendant has knowledge of the ‘Asserted Patents’ and the infringing nature of the Accused Products. Despite this knowledge of the ‘Asserted Patents’, Defendant continues to actively encourage and instruct its customers and end users (for example, through user manuals and online instruction materials on its website) to use the Accused Products in ways that directly infringe the ‘Asserted Patents’. Defendant does so knowing and intending that its customers and end users will commit these infringing acts. Defendant also continues to make, use, offer for sale, sell, and/or import the Accused Products, despite its knowledge of the ‘Asserted Patents’, thereby specifically intending for and inducing its customers to infringe the ‘Asserted Patents’ through the customers’ normal and customary use of the Accused Products.”

Plaintiff further alleged that “On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Junos OS and SRX Series Services Gateways and NFX Series devices running Junos OS, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–18 of the ’852 Patent; the Junos OS with AppSecure suite and SRX Series Services Gateways and NFX Series devices running Junos OS with AppSecure suite, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–25 of the ’024 Patent; and the Juniper Networks SRC Policy Engine and SRC Series software modules with SRC Policy Engine integrated with Juniper Networks routing platforms and security solutions, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–39 of the ’573 Patent.”

 

There are three claims for relief laid down by the plaintiff. The first claim is for the alleged infringement of ’852 patent, the second claim is for the alleged infringement of ’024 patent, and the third claim is for the alleged infringement of ’573 patent.

In its prayer for relief, the Plaintiff has requested the court to grant a judgment in favor of Plaintiff that Defendant has infringed, either literally and/or under the doctrine of equivalents, the ‘Asserted Patents’; order damages, costs, expenses, and pre-judgment and post-judgment interest for the infringement; order to pay supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment interest; and awarding to Plaintiff its reasonable attorneys’ fees.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-00305

  • Filing Date:

    03/29/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

  • Court:

    U.S. District Courts

  • Courthouse:

    Texas Western District

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

Proven Networks, LLC

Defendant

Juniper Networks, Inc.

Attorney/Law Firm Details

Plaintiff Attorneys

Reza Mirzaie

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Brian D. Ledahl

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Paul A. Kroeger

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Benjamin T. Wang

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Marc A. Fenster

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Defendant Attorneys

Megan Whyman Olesek

Attorney at Turner Boyd LLP

702 Marshall Street, Suite 640

Redwood City, CA 94063

Melissa Richards Smith

Attorney at Gillam and Smith, LLP

303 South Washington Avenue

Marshall, TX 75670

 

Court Documents

10 #1

Proposed Order

#10

(#10) MOTION to Appear Pro Hac Vice by Melissa Richards Smith for M. Olesek ( Filing fee $ 100 receipt number 0542-14716693) by on behalf of Juniper Networks, Inc.. (Attachments: #1 Proposed Order)(Smith, Melissa) (Entered: 04/20/2021)

9 #1

Proposed Order

#9

(#9) Unopposed MOTION for Extension of Time to File Answer , MOVE OR OTHERWISE RESPOND TO COMPLAINT by Juniper Networks, Inc.. (Attachments: #1 Proposed Order)(Smith, Melissa) (Entered: 04/20/2021)

#8

(#8) NOTICE of Attorney Appearance by Melissa Richards Smith on behalf of Juniper Networks, Inc.. Attorney Melissa Richards Smith added to party Juniper Networks, Inc.(pty:dft) (Smith, Melissa) (Entered: 04/20/2021)

#7

(#7) SUMMONS Returned Executed by Proven Networks, LLC. Juniper Networks, Inc. served on 4/5/2021, answer due 4/26/2021. (Mirzaie, Reza) (Entered: 04/07/2021)

#6

(#6) Summons Issued as to Juniper Networks, Inc.. (bw) (Entered: 03/29/2021)

#5

(#5) RULE 7 DISCLOSURE STATEMENT filed by Proven Networks, LLC. (Mirzaie, Reza) (Entered: 03/29/2021)

#4

(#4) NOTICE OF RELATED CASES by Proven Networks, LLC re #1 Complaint, (Mirzaie, Reza) (Entered: 03/29/2021)

#3

(#3) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Mirzaie, Reza) (Entered: 03/29/2021)

1 #7

Civil Cover Sheet

1 #6

Exhibit 6

1 #5

Exhibit 5

1 #4

Exhibit 4

1 #3

Exhibit 3

1 #2

Exhibit 2

1 #1

Exhibit 1

#1

(#1) COMPLAINT FOR PATENT INFRINGEMENT AGAINST JUNIPER NETWORKS, INC. ( Filing fee $ 402 receipt number 0542-14641512), filed by Proven Networks, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Civil Cover Sheet)(Mirzaie, Reza) (Entered: 03/29/2021)

10 More Documents Available
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Docket Entries

  • 05/06/2021
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  • DocketText Order GRANTING #10 Motion to Appear Pro Hac Vice for Attorney Megan Whyman Olesek for Juniper Networks, 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: 05/06/2021)

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  • 04/20/2021
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  • Docket(#10) MOTION to Appear Pro Hac Vice by Melissa Richards Smith for M. Olesek ( Filing fee $ 100 receipt number 0542-14716693) by on behalf of Juniper Networks, Inc.. (Attachments: #1 Proposed Order)(Smith, Melissa) (Entered: 04/20/2021)

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  • 04/20/2021
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  • Docket(#9) Unopposed MOTION for Extension of Time to File Answer , MOVE OR OTHERWISE RESPOND TO COMPLAINT by Juniper Networks, Inc.. (Attachments: #1 Proposed Order)(Smith, Melissa) (Entered: 04/20/2021)

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  • 04/20/2021
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  • Docket(#8) NOTICE of Attorney Appearance by Melissa Richards Smith on behalf of Juniper Networks, Inc.. Attorney Melissa Richards Smith added to party Juniper Networks, Inc.(pty:dft) (Smith, Melissa) (Entered: 04/20/2021)

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  • 04/07/2021
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  • Docket(#7) SUMMONS Returned Executed by Proven Networks, LLC. Juniper Networks, Inc. served on 4/5/2021, answer due 4/26/2021. (Mirzaie, Reza) (Entered: 04/07/2021)

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  • 03/30/2021
  • DocketAll parties shall comply with the Standing Orders of Judge Alan D. Albright located at https://www.txwd.uscourts.gov/judges-information/standing-orders/ (Entered: 03/30/2021)

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  • 03/29/2021
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  • Docket(#6) Summons Issued as to Juniper Networks, Inc.. (bw) (Entered: 03/29/2021)

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  • 03/29/2021
  • 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. (bw) (Entered: 03/29/2021)

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  • 03/29/2021
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  • Docket(#5) RULE 7 DISCLOSURE STATEMENT filed by Proven Networks, LLC. (Mirzaie, Reza) (Entered: 03/29/2021)

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  • 03/29/2021
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  • Docket(#4) NOTICE OF RELATED CASES by Proven Networks, LLC re #1 Complaint, (Mirzaie, Reza) (Entered: 03/29/2021)

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  • 03/29/2021
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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. (Mirzaie, Reza) (Entered: 03/29/2021)

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  • 03/29/2021
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  • Docket(#2) REQUEST FOR ISSUANCE OF SUMMONS by Proven Networks, LLC. (Mirzaie, Reza) (Entered: 03/29/2021)

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  • 03/29/2021
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  • Docket(#1) COMPLAINT FOR PATENT INFRINGEMENT AGAINST JUNIPER NETWORKS, INC. ( Filing fee $ 402 receipt number 0542-14641512), filed by Proven Networks, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Civil Cover Sheet)(Mirzaie, Reza) (Entered: 03/29/2021)

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