On November 29, 2021, R2 Solutions LLC (“R2 Solutions” or “Plaintiff”), represented by Edward R. Nelson, III of Nelson Bumgardner Conroy PC, filed an intellectual property lawsuit against Booking.com B.V. (“Booking.com” or “Defendant”), seeking damages, supplemental damages and royalties, among other reliefs, 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 Eastern District of Texas with Judge Amos L. Mazzant, III presiding.
The Plaintiff filed this complaint for the alleged infringement of the United States Patents: United States Patent No. 8,190,610 (“the ’610 patent”), United States Patent No. 8,341,157 (“the ’157 patent”), United States Patent No. 7,698,329 (“the ’329 patent”), and United States Patent No. 8,209,317 (“the ’317 patent”) (collectively, the “Patents-in-suit) owned by the Plaintiff.
In their complaint, the Plaintiff alleged that, “R2 Solutions is the owner of the ’610 patent with all substantial rights to the ’610 patent, including the exclusive right to enforce, sue, and recover damages for past and future infringements.”
The Plaintiff further alleged that, “The inventions described and claimed in the ’610 patent improve the speed, efficiency, effectiveness, and functionality of computer systems. Moreover, the inventions provide an improvement in computer functionality rather than economic or other tasks for which a computer is used in its ordinary capacity. For example, the ’610 patent states that the disclosed inventions “enhance[] the utility of the MapReduce programming methodology.” Id. at Abstract, 1:31–33, 1:66–2:2.””
The Plaintiff also alleged that, “Booking.com has directly infringed and continues to directly infringe one or more claims of the ’610 patent in this District and elsewhere in Texas and the United States. 40. To this end, Booking.com has infringed and continues to infringe, either by itself or via an agent, at least claims 1–5, 17–21, 33–34, and 40–41 of the ’610 patent by, among other things, making, offering to sell, selling, testing and/or using the Booking.com data analytics system built on Apache Hadoop.”
Similar allegations have been made by the Plaintiff with reference to the alleged infringement of other Patents-in-suit.
There are four 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 a judgement that the Defendant directly infringed one or more claims of each of the Patents-in-suit and an award for past and future damages under 35 U.S.C. § 284, including supplemental damages together with reasonable ongoing royalties and pre- and post-judgment interest including attorneys’ fees and costs of suit and any other relief the Court deems just.
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4:21-CV-00942
11/29/2021
Pending - Other Pending
Intellectual Property - Patent
Amos L. Mazzant, III
R2 Solutions LLC
Booking.com B.V.
Edward R Nelson, III
Brent Nelson Bumgardner
Carder W. Brooks
Christopher G Granaghan
John Paul Murphy
(#1) COMPLAINT For Patent Infringement against Booking.com B.V. ( Filing fee $ 402 receipt number 0540-8688994.), filed by R2 Solutions LLC. (Attachments: #1 Civil Cover Sheet, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8)(Nelson, Edward) (Entered: 11/29/2021)
Civil Cover Sheet
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
(#2) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 mailed to the Director of the U.S. Patent and Trademark Office. (Nelson, Edward) (Entered: 11/29/2021)
(#3) CORPORATE DISCLOSURE STATEMENT filed by R2 Solutions LLC identifying Corporate Parent Acacia Research Group LLC for R2 Solutions LLC. (Nelson, Edward) (Entered: 11/29/2021)
(#4) SUMMONS Issued as to Booking.com B.V. (rpc, ) (Entered: 11/30/2021)
(#5) WAIVER OF SERVICE Returned Executed by R2 Solutions LLC. Booking.com B.V. waiver sent on 1/1/2022, answer due 4/1/2022. (Nelson, Edward) (Entered: 01/06/2022)
Docket(#5) WAIVER OF SERVICE Returned Executed by R2 Solutions LLC. Booking.com B.V. waiver sent on 1/1/2022, answer due 4/1/2022. (Nelson, Edward) (Entered: 01/06/2022)
[-] Read LessDocket(#4) SUMMONS Issued as to Booking.com B.V. (rpc, ) (Entered: 11/30/2021)
[-] Read LessDocketIn accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form #Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice Regarding Consent to Proceed Before Magistrate Judge. (rpc, ) (Entered: 11/30/2021)
[-] Read LessDocketCase Assigned to District Judge Amos L. Mazzant, III. (rpc, ) (Entered: 11/30/2021)
[-] Read LessDocket(#3) CORPORATE DISCLOSURE STATEMENT filed by R2 Solutions LLC identifying Corporate Parent Acacia Research Group LLC for R2 Solutions LLC. (Nelson, Edward) (Entered: 11/29/2021)
[-] Read LessDocket(#2) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 mailed to the Director of the U.S. Patent and Trademark Office. (Nelson, Edward) (Entered: 11/29/2021)
[-] Read LessDocket(#1) COMPLAINT For Patent Infringement against Booking.com B.V. ( Filing fee $ 402 receipt number 0540-8688994.), filed by R2 Solutions LLC. (Attachments: #1 Civil Cover Sheet, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8)(Nelson, Edward) (Entered: 11/29/2021)
[-] Read Less