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This case was last updated from PACER on 06/11/2021 at 17:01:17 (UTC).

Sonrai Memory Limited v. Dell Technologies, Inc.

Case Summary

On April 12, 2021, Sonrai Memory Limited (“Plaintiff” or “Sonrai”), represented by Reza Mirzaie of Russ August & Kabat, filed an intellectual property lawsuit against Dell Technologies, Inc. (“Defendant” or “Dell”), seeking permanent injunction, damages with both pre- and post- judgement interest for allegedly unlawfully infringing improvements in charge pump circuits, portable memory devices with both volatile and non-volatile memory, and regenerative clock repeating. This case was filed in the U.S. District Court for the Western District of Texas with Judge Alan D. Albright presiding. 

 

The Plaintiff asserted that Sonrai owns by assignment all rights, title, and interest in the U.S. Patent No. 6,724,241, entitled “Variable Charge Pump Circuit with Dynamic Load.” The ’241 Patent was duly and legally issued by the United States Patent and Trademark Office on April 20, 2004, U.S. Patent No. 6,920,527, entitled “Portable RAM drive.” The ’527 Patent was duly and legally issued by the United States Patent and Trademark Office on July 19, 2005 and U.S. Patent No. 7,436,232, entitled “Regenerative clock repeater.” The ’232 Patent was duly and legally issued by the United States Patent and Trademark Office on October 14, 2008.”

 

In its complaint, the Plaintiff alleged that, “Dell knowingly and intentionally induces infringement of one or more claims of the ’241 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this Complaint, Dell has had knowledge of the ’241 Patent and the infringing nature of the Accused Products. Despite this knowledge of the ’241 Patent, Dell continues to actively encourage and instruct its customers and end users to use the Accused Products in ways that directly infringe the ’241 Patent. Dell does so knowing and intending that its customers and end users will commit these infringing acts. Dell also continues to make, use, offer for sale, sell, and/or import the Accused Products, despite its knowledge of the ’241 Patent, thereby specifically intending for and inducing its customers to infringe the ’241 Patent through the customers’ normal and customary use of the Accused Products.”

 

The Plaintiff also alleged that, “On information and belief, Dell makes, uses, offers for sale, sells, and/or imports certain products and services, including without limitation laptops, desktop computers, and servers with SSDs including Silicon Motion SSD Controllers, including without limitation the Dell/EMC Vostro 15 5568 P62F (“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’527 Patent. Dell has also infringed, and continues to infringe, one or more claims of the ’232 Patent by selling, offering for sale, or importing into the United States, the Accused Products, knowing that the Accused Products constitute a material part of the inventions claimed in the ’232 Patent, are especially made or adapted to infringe the ’232 Patent, and are not staple articles or commodities of commerce suitable for non-infringing use. Dell has been, and currently is, contributorily infringing the ’232 Patent in violation of 35 U.S.C. §§ 271(c) and (f).”

 

There are three claims for relief laid down by the Plaintiff. The first claim is for the alleged infringement of U.S. patent no. 6,724,241. The second claim is for the alleged infringement of U.S. patent no. 6,920,527. The third claim is for the alleged infringement of U.S. patent no. 7,436,232. 

 

In its prayer for relief, the Plaintiff has requested the court for a judgment in favor of Plaintiff that Dell has infringed, the ’241, ’527, and ’232 Patents, permanent injunction prohibiting Dell from further acts of infringement, damages, and any other relief as the Court may deem appropriate and just under the circumstances.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-00361

  • Filing Date:

    04/12/2021

  • 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

Sonrai Memory Limited

Defendant

Dell Technologies, 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

Marc A. Fenster

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

James Milkey

Attorney at Russ August & Kabat

12424 Wilshire Boulevard, 12Th Floor

Los Angeles, CA 90025

Christian W. Conkle

Attorney at Russ August & Kabat

12424 Wilshire Boulevard, 12Th Floor

Los Angeles, CA 90025

Jonathan Ma

Attorney at Russ August & Kabat

12424 Wilshire Blvd., 12Th Floor

Los Angeles, CA 90025

Defendant Attorneys

Brady Randall Cox

Attorney at Alston & Bird, LLP - Dallas

2200 Ross Avenue, Suite 2300

Dallas, TX 75201

Michael J Newton

Attorney at Alston & Bird LLP

2200 Ross Avenue, Suite 2300

Dallas, TX 75201

 

Court Documents

12 #1

Proposed Order

#12

(#12) Unopposed MOTION for Extension of Time to File Answer or otherwise respond by Dell Technologies, Inc.. (Attachments: #1 Proposed Order)(Newton, Michael) (Entered: 06/01/2021)

#11

(#11) NOTICE of Attorney Appearance by Brady Randall Cox on behalf of Dell Technologies, Inc.. Attorney Brady Randall Cox added to party Dell Technologies, Inc.(pty:dft) (Cox, Brady) (Entered: 05/06/2021)

#10

(#10) NOTICE of Attorney Appearance by Michael J Newton on behalf of Dell Technologies, Inc. (Newton, Michael) (Entered: 05/06/2021)

9 #1

Proposed Order

#9

(#9) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint, by Dell Technologies, Inc.. (Attachments: #1 Proposed Order)(Newton, Michael) (Entered: 05/05/2021)

#8

(#8) SUMMONS Returned Executed by Sonrai Memory Limited. Dell Technologies, Inc. served on 4/21/2021, answer due 5/12/2021. (Ma, Jonathan) (Entered: 04/22/2021)

#7

(#7) MOTION to Appear Pro Hac Vice by Jonathan Ma for James A. Milkey ( Filing fee $ 100 receipt number 0542-14702014) by on behalf of Sonrai Memory Limited. (Ma, Jonathan) (Entered: 04/15/2021)

#6

(#6) Summons Issued as to Dell Technologies, Inc.. (lad) (Entered: 04/13/2021)

#5

(#5) Pro Hac Vice Letter to atty Milkey. (lad) (Entered: 04/13/2021)

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 ( Filing fee $ 402 receipt number 0542-14689121), filed by Sonrai Memory Limited. (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: 04/12/2021)

12 More Documents Available
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Docket Entries

  • 06/01/2021
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  • Docket(#12) Unopposed MOTION for Extension of Time to File Answer or otherwise respond by Dell Technologies, Inc.. (Attachments: #1 Proposed Order)(Newton, Michael) (Entered: 06/01/2021)

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  • 05/20/2021
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  • DocketText Order GRANTING #9 Motion for Extension of Time to Answer entered by Judge Alan D Albright. Came on for consideration is Defendant's unopposed motion for extension of time to answer. Noting that the motion is unopposed, the Court GRANTS the Motion. Defendant shall have up to and including June 11, 2021 to answer or otherwise respond to the Complaint. (This is a text-only entry generated by the court. There is no document associated with this entry.) (hs) (Entered: 05/20/2021)

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  • 05/06/2021
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  • Docket(#11) NOTICE of Attorney Appearance by Brady Randall Cox on behalf of Dell Technologies, Inc.. Attorney Brady Randall Cox added to party Dell Technologies, Inc.(pty:dft) (Cox, Brady) (Entered: 05/06/2021)

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  • 05/06/2021
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  • Docket(#10) NOTICE of Attorney Appearance by Michael J Newton on behalf of Dell Technologies, Inc. (Newton, Michael) (Entered: 05/06/2021)

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  • 05/05/2021
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  • Docket(#9) Unopposed MOTION for Extension of Time to File Answer re #1 Complaint, by Dell Technologies, Inc.. (Attachments: #1 Proposed Order)(Newton, Michael) (Entered: 05/05/2021)

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  • 04/27/2021
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  • DocketText Order GRANTING #7 Motion to Appear Pro Hac Vice for Attorney James Milkey for Sonrai Memory Limited. 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: 04/27/2021)

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  • 04/22/2021
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  • Docket(#8) SUMMONS Returned Executed by Sonrai Memory Limited. Dell Technologies, Inc. served on 4/21/2021, answer due 5/12/2021. (Ma, Jonathan) (Entered: 04/22/2021)

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  • 04/15/2021
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  • Docket(#7) MOTION to Appear Pro Hac Vice by Jonathan Ma for James A. Milkey ( Filing fee $ 100 receipt number 0542-14702014) by on behalf of Sonrai Memory Limited. (Ma, Jonathan) (Entered: 04/15/2021)

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  • 04/13/2021
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  • Docket(#6) Summons Issued as to Dell Technologies, Inc.. (lad) (Entered: 04/13/2021)

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  • 04/13/2021
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  • Docket(#5) Pro Hac Vice Letter to atty Milkey. (lad) (Entered: 04/13/2021)

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  • 04/12/2021
  • 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: 04/13/2021)

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  • 04/12/2021
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  • Docket(#4) REQUEST FOR ISSUANCE OF SUMMONS by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 04/12/2021)

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  • 04/12/2021
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  • Docket(#3) NOTICE of Related Cases by Sonrai Memory Limited (Mirzaie, Reza) (Entered: 04/12/2021)

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  • 04/12/2021
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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. (Mirzaie, Reza) (Entered: 04/12/2021)

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  • 04/12/2021
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  • Docket(#1) COMPLAINT ( Filing fee $ 402 receipt number 0542-14689121), filed by Sonrai Memory Limited. (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: 04/12/2021)

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