On January 7, 2022, Sonrai Memory Limited (“Plaintiff” or “Sonrai”), represented by Amy Hayden, Brian D. Ledahl, Christian W. Conkle, James Milkey, Jonathan Ma, Marc A. Fenster and Reza Mirzaie of Russ August & Kabat, filed an intellectual property lawsuit against Lenovo Group Ltd. and Motorola Mobility LLC (“Defendants”), seeking damages, costs and expenses along with pre- and post-judgement interest for the Defendants’ alleged infringement of the United States Patent 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 United States Patent No. 6,874,014 (“’014 Patent” or the “Asserted Patent”) entitled “Chip Multiprocessor with Multiple Operating Systems.” owned by the Plaintiff.
In the complaint the Plaintiff alleged that, “Plaintiff Sonrai Memory Limited is a limited liability company organized and existing under the law of Ireland, with its principal place of business at The Hyde Building, Suite 23, The Park, Carrickmines, Dublin 18, Ireland. Sonrai is the sole owner by assignment of all right, title, and interest in the Asserted Patent. On information and belief, Defendant Lenovo Group Ltd. is organized under the laws of the People’s Republic of China, with its principal place of business at 6 Chuang ye Road, Haidan District, Beijing 100085, China. On information and belief, Defendant Motorola Mobility LLC is a limited liability company organized under the laws of the State of Delaware, with its principal office at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654. This complaint arises from Defendants’ unlawful infringement of the following United States patent owned by Plaintiff, which relates to improvements in computer chip architecture having multiple processors on a single die: United States Patent No. 6,874,014.”
The Plaintiff also alleged that, “On information and belief, Defendants make, use, offer for sale, sell, and/or import certain products and services, including without limitation mobile phones with Qualcomm Snapdragon SoCs containing at least one Hexagon DSP, including without limitation the Motorola Edge (“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’014 Patent. The Accused Products satisfy all claim limitations of one or more claims of the ’014 Patent. By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendants have injured Plaintiff and is liable for infringement of the ’014 Patent pursuant to 35 U.S.C. § 271.”
The only claim for relief laid down by the Plaintiff deals with the alleged infringement of United States Patent No. 6,874,014, owned by the Plaintiff.
In their prayer for relief, the Plaintiff requested the Court for a judgment in favor of Plaintiff that each Defendant has infringed, either literally and/or under the doctrine of equivalents, the ’014 Patent; an order requiring each Defendant, jointly and severally, to pay Plaintiff its damages, costs, expenses, and pre- and post-judgment interest for Defendants’ infringement of the ’014 Patent; and an order finding that this is an exceptional case within the meaning of 35 U.S.C. § 285 and award to Plaintiff its reasonable attorneys’ fees against Defendants, jointly and severally, along with any and all other relief as the Court may deem appropriate and just under the circumstances.
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6:22-CV-00029
01/07/2022
Pending - Other Pending
Intellectual Property - Patent
Alan D Albright
Sonrai Memory Limited
Lenovo Group Ltd.
Motorola Mobility LLC
James Milkey
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
Marc A. Fenster
Attorney at Russ August & Kabat
12424 Wilshire Blvd., 12Th Floor
Los Angeles, CA 90025
Reza Mirzaie
Attorney at Russ August & Kabat
12424 Wilshire Blvd., 12Th Floor
Los Angeles, CA 90025
Amy Hayden
Attorney at Russ August & Kabat
12424 Wilshire Blvd. Floor 12
Los Angeles, CA 90025
Brian D. Ledahl
Attorney at Russ August & Kabat
12424 Wilshire Blvd., 12Th Floor
Los Angeles, CA 90025
Christian W. Conkle
Attorney at Russ August & Kabat
12424 Wilshire Boulevard, 12Th Floor
Los Angeles, CA 90025
John Michael Guaragna
Attorney at DLA Piper LLP (US)
303 Colorado Street, Suite 3000
Austin, TX 78701
(#1) COMPLAINT ( Filing fee $ 402 receipt number 0542-15594638), filed by Sonrai Memory Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Civil Cover Sheet)(Mirzaie, Reza) (Entered: 01/07/2022)
Exhibit 1
Exhibit 2
Exhibit 3
Civil Cover Sheet
(#2) RULE 7 DISCLOSURE STATEMENT filed by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 01/07/2022)
(#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: 01/07/2022)
(#4) NOTICE of Related Cases by Sonrai Memory Limited (Mirzaie, Reza) (Entered: 01/07/2022)
(#5) REQUEST FOR ISSUANCE OF SUMMONS by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 01/07/2022)
(#6) Summons Issued as to Lenovo Group Ltd.. (lad) (Entered: 01/07/2022)
(#7) Summons Issued as to Motorola Mobility LLC. (lad) (Entered: 01/07/2022)
(#8) SUMMONS Returned Executed by Sonrai Memory Limited. Motorola Mobility LLC served on 1/21/2022, answer due 2/11/2022. (Hayden, Amy) (Entered: 01/25/2022)
(#9) NOTICE of Unopposed Extension of Deadline to Answer or Otherwise Respond by Motorola Mobility LLC re #1 Complaint (Guaragna, John) (Entered: 02/01/2022)
DocketReset Deadlines: Motorola Mobility LLC answer due 3/28/2022. (jc5) (Entered: 02/01/2022)
Docket(#9) NOTICE of Unopposed Extension of Deadline to Answer or Otherwise Respond by Motorola Mobility LLC re #1 Complaint (Guaragna, John) (Entered: 02/01/2022)
Docket(#8) SUMMONS Returned Executed by Sonrai Memory Limited. Motorola Mobility LLC served on 1/21/2022, answer due 2/11/2022. (Hayden, Amy) (Entered: 01/25/2022)
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: 01/07/2022)
Docket(#7) Summons Issued as to Motorola Mobility LLC. (lad) (Entered: 01/07/2022)
Docket(#6) Summons Issued as to Lenovo Group Ltd.. (lad) (Entered: 01/07/2022)
DocketAll parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 01/07/2022)
Docket(#5) REQUEST FOR ISSUANCE OF SUMMONS by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 01/07/2022)
Docket(#4) NOTICE of Related Cases by Sonrai Memory Limited (Mirzaie, Reza) (Entered: 01/07/2022)
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: 01/07/2022)
Docket(#2) RULE 7 DISCLOSURE STATEMENT filed by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 01/07/2022)
Docket(#1) COMPLAINT ( Filing fee $ 402 receipt number 0542-15594638), filed by Sonrai Memory Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Civil Cover Sheet)(Mirzaie, Reza) (Entered: 01/07/2022)
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