This case was last updated from U.S. District Courts on 08/10/2021 at 09:16:33 (UTC).

Sonrai Memory Limited v. Western Digital Technologies, Inc

Case Summary

On June 11, 2021, Sonrai Memory Limited (“Sonrai” or “Plaintiff”), represented by Reza Mirzaie of Russ August and Kabat, filed an intellectual property lawsuit against Western Digital Corporation (“Western Digital” or “Defendant”), seeking injunctive relief, damages among other reliefs for alleged unlawful infringement of technology relating to improvements in charge pump circuits, and portable memory devices with both volatile and non-volatile memory. This case was filed in the U.S. District Court in the Central District of California. 

Sonrai asserted that the Plaintiff is the legal owner by assignment of all rights, title and interest in numerous United States and foreign patents and applications including United States Patent No. 6,724,241, (“the ’241 Patent”), entitled “Variable Charge Pump Circuit with Dynamic Load.”, was duly and legally issued by the United States Patent and Trademark Office on April 20, 2004 and U.S. Patent No. 6,920,527, (“the ’527 Patent”) , entitled “Portable RAM drive.” was duly and legally issued by the United States Patent and Trademark Office on July 19, 2005, (collectively, the “Asserted Patents”).

In its complaint, the Plaintiff alleged that, “On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products and services, including without limitation products with SanDisk/Toshiba 64L 3D NAND flash chips, for example, the WD Ultrastar SN630 WUS3BA196C7P3E3 (“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’241 Patent. Defendant also 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, Defendant has had knowledge of the ’241 Patent and the infringing nature of the Accused Products. Despite this knowledge of the ’241 Patent, Defendant continues to actively encourage and instruct its customers and end users.”

The Plaintiff further alleged that, “Defendant has also infringed, and continues to infringe, one or more claims of the ’527 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 ’527 Patent, are especially made or adapted to infringe the ’527 Patent, and are not staple articles or commodities of commerce suitable for non-infringing use. Defendant has been, and currently is, contributorily infringing the ’527 Patent in violation of 35 U.S.C. §§ 271(c) and (f).”



There are two claims for relief laid down by the Plaintiff. The first claim deals with alleged infringement of ’241 Patent because by making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has allegedly injured the Plaintiff and is liable for infringement of the ’241 Patent pursuant to 35 U.S.C. § 271.  The second claim deals with alleged infringement of ’527 Patent because Defendant makes, uses, offers for sale, sells, and/or imports certain products and services, including without limitation SSDs having Marvell SSD Controllers, (“Accused Products”), that allegedly directly infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’527 Patent.

In its prayer for relief, the Plaintiff has requested the Court for permanent injunction prohibiting the Defendant from further acts of infringement of the Asserted Patents, a judgment and order requiring Defendant to pay Plaintiff its damages, costs, expenses, and pre-judgment and post-judgment interest along with accounting of damages, and to order the Defendant to pay the Plaintiff compulsory ongoing licensing fees, supplemental damages and costs of litigation. 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    8:21-CV-01040

  • Filing Date:

    06/11/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Cormac J. Carney

Referral Judge

John D. Early

 

Party Details

Plaintiff and Counter Defendant

Sonrai Memory Limited

Defendants and Counter Claimants

Western Digital Corporation

Western Digital Technologies, Inc

Attorney/Law Firm Details

Plaintiff and Counter Defendant Attorneys

Reza Mirzaie

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

Amy Hayden

Attorney at Russ August and Kabat

12424 Wilshire Boulevard Suite 1200

Los Angeles, CA 90025

Brian D Ledahl

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

Christian W Conkle

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

James Anthony Milkey

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

Jonathan Ma

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

Marc A Fenster

Attorney at Russ August and Kabat

12424 Wilshire Boulevard 12Th Floor

Los Angeles, CA 90025

Defendant and Counter Claimant Attorneys

William C Rooklidge

Attorney at Gibson Dunn and Crutcher LLP

3161 Michelson Drive

Irvine, CA 92612-4412

Christopher Wang

Attorney at Gibson Dunn and Crutcher LLP

3161 Michelson Drive

Irvine, CA 92612-4412

Eric Tsai Syu

Attorney at Gibson Dunn and Crutcher LLP

3161 Michelson Drive

Irvine, CA 92612

Frank P Cote

Attorney at Gibson Dunn & Crutcher LLP

3161 Michelson Drive Suite 800

Irvine, CA 92612-4408

Kenneth G Parker

Attorney at Gibson Dunn and Crutcher LLP

3161 Michelson Drive

Irvine, CA 92612

 

Court Documents

#24

#23

#22

#21

#20

#19

18 #19

Exhibit 19

18 #15

Exhibit 15

18 #11

Exhibit 11

#9

#8

#7

#6

#5

#4

#3

#2

42 More Documents Available
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Docket Entries

  • 08/06/2021
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  • Docket(#24) Notice of Appearance or Withdrawal of Counsel: for attorney Christopher Wang counsel for Counter Claimant Western Digital Technologies, Inc, Defendant Western Digital Technologies, Inc. Adding Christopher Wang as counsel of record for Western Digital Technologies, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant and Counterclaimant Western Digital Technologies, Inc.. (Attorney Christopher Wang added to party Western Digital Technologies, Inc(pty:cc), Attorney Christopher Wang added to party Western Digital Technologies, Inc(pty:dft))(Wang, Christopher) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#23) Notice of Appearance or Withdrawal of Counsel: for attorney Eric Tsai Syu counsel for Counter Claimant Western Digital Technologies, Inc, Defendant Western Digital Technologies, Inc. Adding Eric Syu as counsel of record for Western Digital Technologies, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant and Counterclaimant Western Digital Technologies, Inc.. (Attorney Eric Tsai Syu added to party Western Digital Technologies, Inc(pty:cc), Attorney Eric Tsai Syu added to party Western Digital Technologies, Inc(pty:dft))(Syu, Eric) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#22) Notice of Appearance or Withdrawal of Counsel: for attorney Frank P Cote counsel for Counter Claimant Western Digital Technologies, Inc, Defendant Western Digital Technologies, Inc. Adding Frank Cote as counsel of record for Western Digital Technologies, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant and Counterclaimant Western Digital Technologies, Inc.. (Attorney Frank P Cote added to party Western Digital Technologies, Inc(pty:cc), Attorney Frank P Cote added to party Western Digital Technologies, Inc(pty:dft))(Cote, Frank) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#21) Notice of Appearance or Withdrawal of Counsel: for attorney Kenneth G Parker counsel for Counter Claimant Western Digital Technologies, Inc, Defendant Western Digital Technologies, Inc. Adding Kenneth G. Parker as counsel of record for Western Digital Technologies, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant and Counterclaimant Western Digital Technologies, Inc.. (Attorney Kenneth G Parker added to party Western Digital Technologies, Inc(pty:cc), Attorney Kenneth G Parker added to party Western Digital Technologies, Inc(pty:dft))(Parker, Kenneth) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#20) Certification and NOTICE of Interested Parties filed by Defendant and Counterclaimant Western Digital Technologies, Inc, (Rooklidge, William) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#19) CORPORATE DISCLOSURE STATEMENT filed by Counter Claimant Western Digital Technologies, Inc, Defendant Western Digital Technologies, Inc (Rooklidge, William) (Entered: 08/06/2021)

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  • 08/06/2021
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  • Docket(#18) ANSWER to Complaint (Attorney Civil Case Opening), #1 with JURY DEMAND , COUNTERCLAIM against Sonrai Memory Limited filed by Defendant and Counterclaimant Western Digital Technologies, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27)(Attorney William C Rooklidge added to party Western Digital Technologies, Inc(pty:dft))(Rooklidge, William) (Entered: 08/06/2021)

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  • 07/14/2021
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  • Docket(#17) ORDER Regarding Stipulation Regarding Substitution of Parties #16 by Judge Cormac J. Carney, the Court DOPTS the statements made in the Stipulation and GRANTS the relief requested. It is, therefore, SO ORDERED that Western Digital Technologies, Inc. is substituted for Western Digital Corporation in the above-captioned action. (jp) (Entered: 07/16/2021)

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  • 07/13/2021
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  • Docket(#16) Joint REQUEST to Substitute Defendant Western Digital Corporation for Defendant Western Digital Technologies, Inc. filed by Plaintiff Sonrai Memory Limited. (Attachments: #1 Proposed Order) (Mirzaie, Reza) (Entered: 07/13/2021)

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  • 07/12/2021
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  • Docket(#15) Notice of Appearance or Withdrawal of Counsel: for attorney Amy Hayden counsel for Plaintiff Sonrai Memory Limited. Adding Amy E. Hayden as counsel of record for Sonrai Memory Limited for the reason indicated in the G-123 Notice. Filed by Plaintiff Sonrai Memory Limited. (Attorney Amy Hayden added to party Sonrai Memory Limited(pty:pla))(Hayden, Amy) (Entered: 07/12/2021)

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4 More Docket Entries
  • 06/14/2021
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  • Docket(#10) 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening), #1 as to Defendant Western Digital Corporation. (lh) (Entered: 06/14/2021)

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  • 06/14/2021
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  • Docket(#9) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) (Entered: 06/14/2021)

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  • 06/14/2021
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  • Docket(#8) NOTICE OF ASSIGNMENT to District Judge James V. Selna and Magistrate Judge Autumn D. Spaeth. (lh) (Entered: 06/14/2021)

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  • 06/11/2021
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  • Docket(#7) Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening), #1 filed by Plaintiff Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#6) NOTICE of Related Cases filed by Plaintiff Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#5) REPORT ON THE FILING OF AN ACTION Regarding a Patent or a Trademark (Initial Notification) filed by Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#4) Certification And Notice of Interested Parties filed by Plaintiff Sonrai Memory Limited, (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#3) CORPORATE DISCLOSURE STATEMENT filed by Plaintiff Sonrai Memory Limited (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#2) CIVIL COVER SHEET filed by Plaintiff Sonrai Memory Limited. (Mirzaie, Reza) (Entered: 06/11/2021)

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  • 06/11/2021
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  • Docket(#1) COMPLAINT Receipt No: ACACDC-31455746 - Fee: $402, filed by Plaintiff Sonrai Memory Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4) (Attorney Reza Mirzaie added to party Sonrai Memory Limited(pty:pla))(Mirzaie, Reza) (Entered: 06/11/2021)

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