On June 1, 2021, Stingray IP Solutions, LLC (“Stingray” or “Plaintiff”), represented by Jack Wesley Hill of Ward, Smith & Hill, PLLC, filed an intellectual property lawsuit against Amazon.com, Inc., Amazon.com Services LLC, Ring LLC, eero LLC, and Immedia Semiconductor LLC (collectively, “Defendants” or “Amazon”), seeking declaratory and compensatory relief, for the alleged infringement of the Asserted Patents, owned by the Plaintiff. This case was filed in U.S. District Court in the Eastern District of Texas with Judge Rodney Gilstrap presiding.
The Plaintiff filed the complaint for the Defendant’s alleged infringement of U.S. Patent No. 7,082,117 (the “’117 patent”) entitled “Mobile ad-hoc network with intrusion detection features and related methods”, 7,224,678 (the “’678 patent”) entitled “Wireless local or metropolitan area network with intrusion detection features and related methods”, 7,440,572 (the “’572 patent”) entitled “Secure wireless LAN device and associated methods”, and 7,616,961 (“the “’961 patent”) entitled “Allocating channels in a mobile ad hoc network”, (collectively, the “Asserted Patents”).
In its complaint, the Plaintiff alleged that “Amazon has and continues to directly and/or indirectly infringe (by inducing infringement) one or more claims of the Asserted patents in this District and elsewhere in Texas and the United States.”
The Plaintiff further alleged that “On information and belief, Amazon designs, develops, manufactures, assembles, and markets smart home devices configured to utilize ZigBee, Z-Wave, and Wi-Fi protocols such as the Accused Products, including via Amazon.com’s subsidiaries, such as Defendants Amazon Services, Ring, eero, and Blink, affiliates, partners, distributors, retails, customers, and consumers.”
The Plaintiff lists out four claims for relief. Each claim is for the alleged infringement of ’117 patent, ’678 patent, ’572 patent and ’961 patent, respectively, wherein the Plaintiff claimed that, Amazon directly infringes the Asserted Patents via 35 U.S.C. § 271(a) by making, offering for sale, selling, and/or importing the Accused Products, their components, and/or products containing the same that incorporate the fundamental technologies covered by the ’678 patent to, for example, its alter egos, agents, intermediaries, distributors, importers, customers, subsidiaries, affiliates, and/or consumers and on information and belief, despite having knowledge of the Asserted patents and knowledge that it is directly and/or indirectly infringing one or more claims of the Asserted Patents, Amazon has nevertheless continued its infringing conduct and disregarded an objectively high likelihood of infringement.
In its prayer for relief, the Plaintiff requested the Court to adjudicate that the Defendants have infringed the Asserted Patents as alleged herein; order an accounting of damages sustained by Plaintiff as a result of the acts of infringement by Defendants; order Defendants to pay Plaintiff damages under 35 U.S.C. § 284, including up to treble damages as provided by 35 U.S.C. § 284, and any royalties determined to be appropriate; order Defendants to pay Plaintiff prejudgment and post-judgment interest on the damages awarded; and order finding this to be an exceptional case and requiring Defendants to pay the costs of this action.
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2:21-CV-00194
06/01/2021
Pending - Other Pending
Intellectual Property - Patent
Rodney Gilstrap
Stingray IP Solutions, LLC
Amazon.com, Inc.
Immedia Semiconductor LLC
Ring LLC
eero LLC
Amazon.com Services LLC
Jeffrey Ray Bragalone
Hunter Scott Palmer
Marcus Benavides
Terry Afif Saad
Jack Wesley Hill
J David Hadden
Deron R Dacus
Geoffrey Robert Miller
Min Wu
Ravi R Ranganath
Saina Shamilov
Summons(es) RING LLC
Summons(es) IMMEDIA SEMICONDUCTOR LLC
Summons(es) RING LLC
Summons(es) IMMEDIA SEMICONDUCTOR LLC
Summons(es) EERO LLC
Summons(es) AMAZON.COM, INC.
Docket(#28) NOTICE of Attorney Appearance by Saina Shamilov on behalf of All Defendants (Shamilov, Saina) (Entered: 07/30/2021)
[-] Read LessDocket(#27) CORPORATE DISCLOSURE STATEMENT filed by Immedia Semiconductor LLC identifying Corporate Parent Amazon.com, Inc. for Immedia Semiconductor LLC. (Ranganath, Ravi) (Entered: 07/30/2021)
[-] Read LessDocket(#26) CORPORATE DISCLOSURE STATEMENT filed by Ring LLC identifying Corporate Parent Amazon.com, Inc. for Ring LLC. (Ranganath, Ravi) (Entered: 07/30/2021)
[-] Read LessDocket(#25) CORPORATE DISCLOSURE STATEMENT filed by eero LLC identifying Corporate Parent Amazon.com, Inc. for eero LLC. (Ranganath, Ravi) (Entered: 07/30/2021)
[-] Read LessDocket(#24) CORPORATE DISCLOSURE STATEMENT filed by Amazon.com Services LLC, Amazon.com, Inc. identifying Corporate Parent Amazon.Com, Inc., for Amazon.com Services LLC. (Ranganath, Ravi) (Entered: 07/30/2021)
[-] Read LessDocket(#23) NOTICE of Attorney Appearance by Geoffrey Robert Miller on behalf of All Defendants (Miller, Geoffrey) (Entered: 07/30/2021)
[-] Read LessDocket(#22) NOTICE of Attorney Appearance by Ravi R Ranganath on behalf of All Defendants (Ranganath, Ravi) (Entered: 07/30/2021)
[-] Read LessDocket(#21) NOTICE of Attorney Appearance by J David Hadden on behalf of All Defendants (Hadden, J) (Entered: 07/30/2021)
[-] 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. (nkl, ) (Entered: 07/30/2021)
[-] Read LessDocket(#20) ANSWER to #1 Complaint, [Answer of Defendants Amazon.com, Inc. and Amazon.com Services LLC to Complaint for Patent Infringement] by Amazon.com Services LLC, Amazon.com, Inc..(Hadden, J) (Entered: 07/30/2021)
[-] Read LessDocket(#7) NOTICE of Attorney Appearance by Terry Afif Saad on behalf of Stingray IP Solutions, LLC (Saad, Terry) (Entered: 06/04/2021)
[-] Read LessDocket(#6) NOTICE of Attorney Appearance by Jeffrey Ray Bragalone on behalf of Stingray IP Solutions, LLC (Bragalone, Jeffrey) (Entered: 06/04/2021)
[-] Read LessDocket***FILED IN ERROR. Document # 4, SUMMONS Issued. PLEASE IGNORE.*** (nkl, ) (Entered: 06/01/2021)
[-] Read LessDocket(#5) SUMMONS Issued as to Amazon.com Services LLC c/o CORPORATION SERVICE COMPANY, Amazon.com, Inc. c/o CORPORATION SERVICE COMPANY, Immedia Semiconductor LLC c/o CORPORATION SERVICE COMPANY, Ring LLC c/o CORPORATION SERVICE COMPANY, eero LLC c/o CORPORATION SERVICE COMPANY. (Attachments: #1 Summons(es) AMAZON.COM, INC., #2 Summons(es) EERO LLC, #3 Summons(es) IMMEDIA SEMICONDUCTOR LLC, #4 Summons(es) RING LLC)(nkl, ) (Entered: 06/01/2021)
[-] Read LessDocket(#4) FILED IN ERROR SUMMONS Issued as to Amazon.com Services LLC c/o CORPORATION SERVICE COMPANY, Amazon.com, Inc. c/o CORPORATION SERVICE COMPANY, Immedia Semiconductor LLC c/o CORPORATION SERVICE COMPANY, Ring LLC c/o CORPORATION SERVICE COMPANY, eero LLC c/o CORPORATION SERVICE COMPANY. (Attachments: #1 Summons(es) AMAZON.COM, INC., #2 Summons(es) EERO LLC, #3 Summons(es) IMMEDIA SEMICONDUCTOR LLC, #4 Summons(es) RING LLC)(nkl, ) Modified on 6/1/2021 (nkl, ). (Entered: 06/01/2021)
[-] 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. (nkl, ) (Entered: 06/01/2021)
[-] Read LessDocketCase Assigned to District Judge Rodney Gilstrap. (nkl, ) (Entered: 06/01/2021)
[-] Read LessDocket(#3) CORPORATE DISCLOSURE STATEMENT filed by Stingray IP Solutions, LLC identifying Corporate Parent Acacia Research Corporation, Corporate Parent Acacia Research Group LLC for Stingray IP Solutions, LLC. (Hill, Jack) (Entered: 06/01/2021)
[-] 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. (Hill, Jack) (Entered: 06/01/2021)
[-] Read LessDocket(#1) COMPLAINT against Amazon.com Services LLC, Amazon.com, Inc., Immedia Semiconductor LLC, Ring LLC, eero LLC ( Filing fee $ 402 receipt number 0540-8434652.), filed by Stingray IP Solutions, LLC. (Attachments: #1 Civil Cover Sheet)(Hill, Jack) (Entered: 06/01/2021)
[-] Read Less