This case was last updated from PACER on 04/23/2021 at 10:06:01 (UTC).

Symbology Innovations LLC v. United HealthCare Services, Inc.

Case Summary

On February 22, 2021, Symbology Innovations LLC (“Plaintiff” or “Symbology”), self represented, filed an intellectual property lawsuit against United HealthCare Services, Inc. (hereinafter “Defendant”) seeking injunctive relief, damages, attorney fees and costs for alleged infringing and profiting, in an illegal and unauthorized manner, and without authorization and/or consent from Plaintiff from U.S. Patent No 8,424,752 (“the ‘752 Patent” or the “Patent-in-Suit”) pursuant to 35 U.S.C. §271. This case was filed in the U.S. District Court in the Western District of Texas with Judge Lee Yeakel presiding.

 

In its complaint, the Plaintiff alleged that “the invention claimed in the ‘752 Patent comprises systems and methods for enabling portable electronic devices to present information about a selected object” and that the “Defendant commercializes, inter alia, methods that perform all the steps recited in at least one claim of the ‘752 Patent. More particularly, Defendant commercializes, inter alia, methods that perform all the steps recited in Claim 1 of the ‘752 Patent. Specifically, Defendant makes, uses, sells, offers for sale, or imports a method that encompasses that which is covered by Claim 1 of the ‘752 Patent.”

 

Plaintiff further alleged that “Defendant offers solutions, such as a QR code associated with the website for UMR Insurance Company (the “Accused Product”),1 that enables systems and methods for enabling portable electronic devices to present information about a selected object. For example, the Accused Product, at least in internal usage and testing, performs the method for enabling portable electronic devices to present information about a selected object.” and that “the Accused Product was made by or with authorization from the Defendant.”

 

The only claim for relief laid down by Symbology is for the alleged infringement of the ‘752 Patent wherein it has been alleged that “Defendant has directly infringed and continues to directly infringe at least one claim of the ‘752 Patent by using, at least through internal testing or otherwise, the Accused Product without authority in the United States, and will continue to do so unless enjoined by this Court. As a direct and proximate result of Defendant’s direct infringement of the ‘752 Patent, Plaintiff has been and continues to be damaged. Defendant has contributed and induced others to infringe the ‘752 Patent by encouraging infringement, knowing that the acts Defendant induced constituted patent infringement, and its encouraging acts actually resulted in direct patent infringement.”

 

In its prayer for relief the Plaintiff has requested the court to adjudge that the Defendant has directly infringed the ‘752 Patent either literally or under the doctrine of equivalents and to order for an accounting of all alleged infringing sales and damages. The Plaintiff further requested the court to pass an order for an injunctive relief and an award of damages pursuant to 35 U.S.C. §284 sufficient to compensate Plaintiff for the Defendant’s alleged past infringement and any alleged continuing or future infringement with prejudgment and post judgment interests to be assessed and awarded in accordance with 35 U.S.C. §284. Plaintiff also requested that the Defendants be directed to pay enhanced damages, including Plaintiff’s attorneys’ fees incurred in connection with this lawsuit pursuant to 35 U.S.C. §285.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    1:21-CV-00171

  • Filing Date:

    02/22/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Lee Yeakel

 

Party Details

Plaintiff

Symbology Innovations LLC

Defendant

United HealthCare Services, Inc.

Attorney/Law Firm Details

Plaintiff Attorney

Jay B. Johnson

Attorney at Kizzia Johnson PLLC

1910 Pacific Avenue, Suite 13000

Dallas, TX 75201

Defendant Attorney

Ryan E. Dornberger

Attorney at Robins Kaplan LLP

800 Lasalle Ave, Ste 2800

Minneapolis, MN 55402

 

Court Documents

#1

#11

10 #1

Exhibit A-Courts of Admission

#10

#9

8 #1

Proposed Order

#8

#7

#6

#5

#4

#3

#2

1 #3

Civil Cover Sheet Civil Cover Sheet

1 #2

Exhibit Exhibit B

1 #1

Exhibit Exhibit A

7 More Documents Available
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Docket Entries

  • 04/07/2021
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  • Docket(#11) DEFICIENCY NOTICE: re #10 MOTION to Appear Pro Hac Vice by Andrew S. Curfman ( Filing fee $ 100 receipt number 0542-14668700) (jv2) (Entered: 04/07/2021)

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  • 04/07/2021
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  • Docket(#10) MOTION to Appear Pro Hac Vice by Andrew S. Curfman ( Filing fee $ 100 receipt number 0542-14668700) by on behalf of Symbology Innovations LLC. (Attachments: #1 Exhibit A-Courts of Admission)(Curfman, Andrew) (Entered: 04/07/2021)

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  • 03/30/2021
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  • Docket(#9) ORDER GRANTING Agreed #8 Motion for Extension of Time to Respond to Plaintiff's Complaint; United HealthCare Services, Inc. answer due 4/28/2021. Signed by Judge Lee Yeakel. (jv2) (Entered: 03/30/2021)

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  • 03/29/2021
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  • Docket(#8) Agreed MOTION for Extension of Time to File Answer re #1 Complaint, by United HealthCare Services, Inc.. (Attachments: #1 Proposed Order)(Dornberger, Ryan) (Entered: 03/29/2021)

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  • 03/08/2021
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  • Docket(#7) Summons Issued as to United HealthCare Services, Inc. (jv2) (Entered: 03/08/2021)

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  • 03/08/2021
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  • Docket(#6) REQUEST FOR ISSUANCE OF SUMMONS by Symbology Innovations LLC. (Johnson, Jay) (Entered: 03/08/2021)

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  • 02/23/2021
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  • Docket(#5) Pro Hac Vice Letter mailed to Andrew S. Curfman re: non-admitted status. (cj) (Entered: 02/23/2021)

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  • 02/23/2021
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  • Docket(#4) Report on Patent sent to U.S. Patent and Trademark Office, along with a copy of the Complaint. (cj) (Entered: 02/23/2021)

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  • 02/23/2021
  • DocketDEMAND for Trial by Jury by Symbology Innovations LLC. (cj) (Entered: 02/23/2021)

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  • 02/23/2021
  • DocketIf ordered by the court, all referrals and consents in this case will be assigned to Magistrate Judge Austin (cj) (Entered: 02/23/2021)

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  • 02/23/2021
  • DocketCase assigned to Judge Lee Yeakel. 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. (cj) (Entered: 02/23/2021)

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  • 02/23/2021
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  • 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. (Johnson, Jay) (Entered: 02/23/2021)

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  • 02/23/2021
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  • Docket(#2) RULE 7 DISCLOSURE STATEMENT filed by Symbology Innovations LLC . (Johnson, Jay) (Entered: 02/23/2021)

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  • 02/23/2021
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  • Docket(#1) COMPLAINT ( Filing fee $ 402 receipt number 0542-14515596). No Summons requested at this time, filed by Symbology Innovations LLC. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Civil Cover Sheet Civil Cover Sheet)(Johnson, Jay) (Entered: 02/23/2021)

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