Stragent, LLC v. Volvo Car USA LLC
Case Summary
On March 4, 2022, Stragent, LLC (“Stragent” or “Plaintiff”), represented by George Pazuniak of O'Kelly & Ernst, LLC, filed an intellectual property lawsuit against Volvo Car USA LLC (“Volvo” or “Defendant”), seeking damages for alleged infringement of U.S. patents owned by the plaintiff. This case was filed in the U.S. District Court for the District of Delaware, with Judge Joshua D. Wolson presiding.
Plaintiff filed this complaint for the alleged infringement of U.S. patent Nos. 10,248,477 (“the ‘477 Patent”); 10,031,790 (“the ‘790 Patent”); 10,002,036 (“the ‘036 Patent”); and 9,705,765 (“the ‘765 Patent”) (collectively, the “patents-in-suit”) owned by the plaintiff.
In the complaint, the plaintiff alleged, “Defendant has directly infringed at least independent claim 23 and its dependent claims 26 and 27 of the ‘477 Patent, literally and/or under the doctrine of equivalents, by making, using, offering for sale, selling, and/or importing Accused Instrumentalities, on and after April 2, 2019, without license or authority. The Accused Instrumentalities infringe because any automotive vehicle containing at least one ECU that operates according to, or in compliance with, Autosar 4.x.x standards inherently and necessarily infringes the above claims of this Patent of the ‘477 Patent. Defendant’s acts of infringement have caused and continue to cause damage to Plaintiff.”
Plaintiff also alleged, “Defendant has been and is now directly infringing at least independent claim 1 and its dependent claims 2, 4, 5, 6, 8 and 9, and independent claim 15 and its dependent claims 16, 18, 19, 20, 22, 23 and 24 of the ‘790 Patent, literally and/or under the doctrine of equivalents, by making, using, offering for sale, selling, and/or importing Volvo Cars without license or authority. Any Volvo Car containing at least one ECU that operates according to, or in compliance with, Autosar 4.x.x standards inherently and necessarily infringes the above claims of this Patent. Defendant has been aware of the ‘790 Patent and its application to Volvo Cars since at least June 22, 2018. Defendant’s acts of infringement have caused and continue to cause damage to Plaintiff.”
The plaintiff further alleged, “Defendant has been and is now directly infringing at least independent claim 1 and its dependent claims 9, 19, 34, 38, 72, 79, 82 and 98; and independent claim 102 and its dependent claims 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 117, 121 and 122, of the ‘036 Patent, literally and/or under the doctrine of equivalents, by making, using, offering for sale, selling, and/or importing the Accused Instrumentalities without license or authority. Any Volvo Car containing at least one ECU that operates according to, or in compliance with, Autosar 4.x.x standards inherently and necessarily infringes the above claims of the ‘036 Patent. Defendant’s acts of infringement have caused and continue to cause damage to Plaintiff.”
Similar allegations have been made by the plaintiff with respect to all the Patents owned by the Plaintiff.
Plaintiff listed four claims for relief from alleged infringement of the patents-in-suit.
In the prayer for relief, the plaintiff requested an award of damages, costs, expenses, pre- and post-judgment interest, and post-judgment royalties for Defendant’s infringement of the patents-in-suit.
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Case Details
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Case Number:
1:22-CV-00293
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Filing Date:
03/04/2022
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Case Status:
Pending - Other Pending
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Case Type:
Intellectual Property - Patent
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Court:
-
Courthouse:
Judge Details
Presiding Judge
Joshua D. Wolson
Party Details
Plaintiff
Stragent, LLC
Defendant
Volvo Car USA LLC
Attorney/Law Firm Details
Plaintiff Attorney
George Pazuniak
Defendant Attorneys
Lewis E. Hudnell, III
Stamatios Stamoulis
Nicolas S. Gikkas
Stanley Thompson
Court Documents
(#40) PROTECTIVE ORDER. Signed by Judge Joshua D. Wolson on 03/08/2023. (smg) (Entered: 03/08/2023)
(#39) Joint PROPOSED ORDER Protective Order by Stragent, LLC. (Pazuniak, George) (Entered: 03/07/2023)
(#38) NOTICE OF SERVICE of Expert Report of Michael Nranian Regarding Invalidity of Patents-in-Suit filed by Volvo Car USA LLC.(Stamoulis, Stamatios) (Entered: 03/03/2023)
(#37) NOTICE OF SERVICE of a.The Expert Report of Eileen Davidson together with Exhibits 1-7; and The Expert Report of Dr. Cleve Tyler together with attachments and schedules filed by Stragent, LLC.(Pazuniak, George) (Entered: 03/02/2023)
(#36) ORDER, in light of changes made to Section II.B.5 of Judge Wolson's Policies and Procedures, it is ORDERED that motions for summary judgment, if any, shall be filed on or before June 9, 2023. The Amended Scheduling Order (D.I. #35 ) is amended accordingly. Signed by Judge Joshua D. Wolson on 2/28/2023. (twk) (Entered: 02/28/2023)
(#35) SO ORDERED, regarding D.I. #34 Joint MOTION for Extension of Time to Complete Discovery filed by Stragent, LLC. Signed by Judge Joshua D. Wolson on 2/14/2023. (apk) (Entered: 02/14/2023)
(#34) Joint MOTION for Extension of Time to Complete Discovery - filed by Stragent, LLC. (Pazuniak, George) (Entered: 02/13/2023)
(#33) NOTICE OF SERVICE of Updated Rule 26 disclosure on January 13, 2023 and updated claim charts on January 15, 2023 filed by Stragent, LLC.(Pazuniak, George) (Entered: 01/16/2023)
(#32) NOTICE OF SERVICE of a.Stragents Response To Volvos First Set Of Requests For Admission; b. Stragents Response To Volvos First Set Of Authentication Requests For Admission; and c. Stragents Response To Volvos Second Set Of Interrogatories filed by Stragent, LLC.(Pazuniak, George) (Entered: 12/21/2022)
(#4) Summons Issued as to Volvo Car USA LLC on 3/4/2022. (smg) (Entered: 03/04/2022)
(#3) Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) 10,248,477 ; 10,031,790 ; 10,002,036 ; 9,705,765. (smg) (Entered: 03/04/2022)
(#2) Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (smg) (Entered: 03/04/2022)
Civil Cover Sheet
Exhibit D
Exhibit C
Exhibit B
Exhibit A
(#1) COMPLAINT for PATENT INFRINGEMENT - filed with Jury Demand against Volvo Car USA LLC - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3817188.) - filed by Stragent, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Civil Cover Sheet)(smg) (Entered: 03/04/2022)
Docket Entries
Docket(#40) PROTECTIVE ORDER. Signed by Judge Joshua D. Wolson on 03/08/2023. (smg) (Entered: 03/08/2023)
[-] Read LessDocket(#39) Joint PROPOSED ORDER Protective Order by Stragent, LLC. (Pazuniak, George) (Entered: 03/07/2023)
[-] Read LessDocket(#38) NOTICE OF SERVICE of Expert Report of Michael Nranian Regarding Invalidity of Patents-in-Suit filed by Volvo Car USA LLC.(Stamoulis, Stamatios) (Entered: 03/03/2023)
[-] Read LessDocket(#37) NOTICE OF SERVICE of a.The Expert Report of Eileen Davidson together with Exhibits 1-7; and The Expert Report of Dr. Cleve Tyler together with attachments and schedules filed by Stragent, LLC.(Pazuniak, George) (Entered: 03/02/2023)
[-] Read LessDocket(#36) ORDER, in light of changes made to Section II.B.5 of Judge Wolson's Policies and Procedures, it is ORDERED that motions for summary judgment, if any, shall be filed on or before June 9, 2023. The Amended Scheduling Order (D.I. #35 ) is amended accordingly. Signed by Judge Joshua D. Wolson on 2/28/2023. (twk) (Entered: 02/28/2023)
[-] Read LessDocket(#35) SO ORDERED, regarding D.I. #34 Joint MOTION for Extension of Time to Complete Discovery filed by Stragent, LLC. Signed by Judge Joshua D. Wolson on 2/14/2023. (apk) (Entered: 02/14/2023)
[-] Read LessDocket(#34) Joint MOTION for Extension of Time to Complete Discovery - filed by Stragent, LLC. (Pazuniak, George) (Entered: 02/13/2023)
[-] Read LessDocket(#33) NOTICE OF SERVICE of Updated Rule 26 disclosure on January 13, 2023 and updated claim charts on January 15, 2023 filed by Stragent, LLC.(Pazuniak, George) (Entered: 01/16/2023)
[-] Read LessDocket(#32) NOTICE OF SERVICE of a.Stragents Response To Volvos First Set Of Requests For Admission; b. Stragents Response To Volvos First Set Of Authentication Requests For Admission; and c. Stragents Response To Volvos Second Set Of Interrogatories filed by Stragent, LLC.(Pazuniak, George) (Entered: 12/21/2022)
[-] Read LessDocket(#31) NOTICE OF SERVICE of VCUSAs Final Invalidity Contentions filed by Volvo Car USA LLC.(Stamoulis, Stamatios) (Entered: 12/13/2022)
[-] Read LessDocket(#8) STIPULATION AND ORDER, the deadline for Defendant Volvo Car USA, LLC to answer, move, or otherwise respond to the Complaint in this action is extended forty-five (45) days from March 24, 2022 to May 9, 2022. Signed by Judge Joshua D. Wolson on 3/24/2022. (nmg) (Entered: 03/24/2022)
[-] Read LessDocket(#7) STIPULATION TO EXTEND TIME to answer, move, or otherwise respond to the Complaint to May 9, 2022 - filed by Volvo Car USA LLC. (Stamoulis, Stamatios) (Entered: 03/23/2022)
[-] Read LessDocketCase Reassigned to Judge Joshua D. Wolson, of the United States District Court for the Eastern District of Pennsylvania. Please include the initials of the Judge (JDW) after the case number on all documents filed. Associated Cases: 1:20-cv-00510-JDW, 1:20-cv-00511-JDW, 1:20-cv-00512-JDW, 1:22-cv-00293-JDW (rjb) (Entered: 03/14/2022)
[-] Read LessDocket(#6) ORDER: DESIGNATION OF DISTRICT JUDGE TO HOLD A DISTRICT COURT WITHIN THE CIRCUIT, designating and assigning the Honorable Joshua D. Wolson of the United States District Court for the Eastern District of Pennsylvania. Signed by Judge Michael A Chagares, Chief Judge of the United States Court of Appeals for the Third Circuit on 3/14/2022. (rjb) (Entered: 03/14/2022)
[-] Read LessDocketCase Assigned to Judge Leonard P. Stark. Please include the initials of the Judge (LPS) after the case number on all documents filed. (rjb) (Entered: 03/09/2022)
[-] Read LessDocket(#5) SUMMONS Returned Executed by Stragent, LLC. Volvo Car USA LLC served on 3/3/2022, answer due 3/24/2022. (Pazuniak, George) (Entered: 03/08/2022)
[-] Read LessDocket(#4) Summons Issued as to Volvo Car USA LLC on 3/4/2022. (smg) (Entered: 03/04/2022)
[-] Read LessDocket(#3) Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) 10,248,477 ; 10,031,790 ; 10,002,036 ; 9,705,765. (smg) (Entered: 03/04/2022)
[-] Read LessDocket(#2) Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (smg) (Entered: 03/04/2022)
[-] Read LessDocket(#1) COMPLAINT for PATENT INFRINGEMENT - filed with Jury Demand against Volvo Car USA LLC - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3817188.) - filed by Stragent, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Civil Cover Sheet)(smg) (Entered: 03/04/2022)
[-] Read Less
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