This case was last updated from U.S. District Courts on 06/25/2022 at 08:24:13 (UTC).

Synopsys, Inc. v. Khanh

Case Summary

On April 26, 2022, Synopsys, Inc. (“Plaintiff”), represented by Denise Marie Mingrone of Orrick, Herrington & Sutcliffe LLP, filed an intellectual property lawsuit against Phan Van Khanh, DOES 1-6 (“Defendants”), seeking monetary damages and declaratory relief, among other relief for the alleged copyright infringement by the Defendants. This case was filed in the U.S. District Court in the Northern District of California. 



In the complaint, the plaintiff claimed, “Since it was founded in 1986, Synopsys has been a leading provider of EDA solutions for the semiconductor industry. EDA generally refers to using computers to design, verify, and simulate the performance of electronic circuits.”



The plaintiff also claimed, “Synopsys’ EDA software applications are creative and original works subject to copyright protection under Title 17 of the United States Code.”



The plaintiff claimed, “Synopsys does not sell its ownership rights, copyrights, or other intellectual property rights to its EDA software, including Synopsys Tools, and associated services. Instead, Synopsys customers purchase licenses.”



The plaintiff alleged that “Defendant Phan Văn Khánh is an owner and/or operator of the ShareAppsCrack.com website, which contains counterfeit versions of software including Synopsys software and also provides assistance to its visitors regarding how to use these counterfeit versions of software and circumvent technological measures used to control access to the software.”



The plaintiff further alleged, “Synopsys software has been uploaded to ShareAppsCrack.com, the website operated by Defendants, without Synopsys’ authorization. Synopsys’ trademarks are also being used in association with the Synopsys software located on Defendants’ website without Synopsys’ authorization.”



The plaintiff thereon alleged, “On information and belief, Defendants started distributing illegal copies of Synopsys HSPICE software on March 10, 2020 and updated said illegal offering on February 13, 2021.”



The plaintiff further alleged, “Defendants knew or had reason to know that illegal and unauthorized distribution of hacked versions of Synopsys’ software is a violation of United States law, as Defendants’ own website claims protection under the DMCA.”



The plaintiff also alleged, “Defendants’ use of Synopsys’ trademarks and logos leads to customer confusion and is likely to mislead consumers into believing that Defendants are somehow endorsed, sponsored, or otherwise associated with Synopsys.”



The plaintiff also alleged, “Furthermore, Defendants’ use of Synopsys’ trademarks in connection with its offering of illegal software downloads and circumvention tools harms Synopsys’ reputation since Synopsys has no control over what the software provided actually does and Synopsys’ reputation is likely to be harmed if said files turn out to contain malicious software or code.”



The plaintiff made three claims for relief. The first claim is for alleged violations of the Digital Millennium Copyright Act, 17 U.S.C. § 1201(a)(2). The second claim is for alleged trademark infringement under 15 U.S.C. § 1114(1) and 15 U.S.C. § 1125(a)(1)(A). The third claim is for alleged civil RICO. 



In the prayer for relief, the plaintiff requested preliminary and permanent injunctive relief and damages including actual damages, statutory damages, specific damages, pre-and post-judgment interest, costs and attorneys’ fees, and any other relief the court deems just and proper.



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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    3:22-CV-02546

  • Filing Date:

    04/26/2022

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Copyright

Judge Details

Presiding Judge

James Donato

 

Party Details

Plaintiff

Synopsys, Inc.

Defendant

Phan Van Khanh

Attorney/Law Firm Details

Plaintiff Attorney

Denise Marie Mingrone

Attorney at Orrick, Herrington & Sutcliffe LLP

1000 Marsh Road

Menlo Park, CA 94025

 

Court Documents

#16

(#16) PRELIMINARY INJUNCTION. Signed by Judge James Donato on 6/15/2022. (jdlc1, COURT STAFF) (Filed on 6/15/2022) (Entered: 06/15/2022)

#14

(#14) Minute Entry for proceedings held before Judge James Donato: Preliminary Injunction Hearing held on 6/2/2022. (jdlc1, COURT STAFF) (Date Filed: 6/2/2022) (Entered: 06/02/2022)

#13

(#13) ORDER re #8 Motion for (1) Temporary Restraining Order; (2) Order to Show Cause re Preliminary Injunction; (3) Order for Expedited Discovery; and (4) Order Authorizing Alternative Service. Preliminary Injunction Hearing set for 6/2/2022 at 10:00 AM. Signed by Judge James Donato on 5/9/2022. (jdlc2, COURT STAFF) (Filed on 5/9/2022) (Entered: 05/09/2022)

#12

(#12) Minute Entry for proceedings held before Judge James Donato: Motion Hearing held on 5/9/2022. (jdlc2, COURT STAFF) (Date Filed: 5/9/2022) (Entered: 05/09/2022)

11 #1

Exhibit A

11 #11

Main Document

#10

(#10) NOTICE of Appearance by Robert Luis Uriarte (Uriarte, Robert) (Filed on 5/4/2022) (Entered: 05/04/2022)

8 #5

Proposed Order

8 #4

Declaration Daniel E. Roffman Declaration ISO Synopsys, Inc. Ex Parte Motion for

8 #3

Declaration Norman F. Kelly Declaration ISO Synopsys, Inc. Ex Parte Motion for T

8 #2

Exhibit A to D. Mingrone Declaration ISO Synopsys, Inc. Ex Parte Motion for TRO

8 #1

Declaration Denise Mingrone Declaration ISO Synopsys, Inc.s Ex Parte Motion for

8 #8

Main Document

#6

(#6) Summons Issued as to Phan Van Khanh. (far, COURT STAFF) (Filed on 4/27/2022) (Entered: 04/27/2022)

#5

(#5) Initial Case Management Scheduling Order with ADR Deadlines: Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order No. 65 and http://cand.uscourts.gov/cameras. Case Management Statement due by 7/21/2022. Initial Case Management Conference set for 7/28/2022 10:00 AM in San Francisco, Courtroom 11, 19th Floor. (far, COURT STAFF) (Filed on 4/27/2022) (Entered: 04/27/2022)

#3

(#3) Certificate of Interested Entities by Synopsys, Inc. (Mingrone, Denise) (Filed on 4/26/2022) (Entered: 04/26/2022)

#2

(#2) Proposed Summons. (Mingrone, Denise) (Filed on 4/26/2022) (Entered: 04/26/2022)

1 #1

Main Document

7 More Documents Available
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Docket Entries

  • 06/15/2022
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  • Docket(#16) PRELIMINARY INJUNCTION. Signed by Judge James Donato on 6/15/2022. (jdlc1, COURT STAFF) (Filed on 6/15/2022) (Entered: 06/15/2022)

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  • 06/08/2022

  • Docket(#15) ORDER. Synopsys is directed to email a Microsoft Word version of a proposed preliminary injunction order to jdpo@cand.uscourts.gov by June 16, 2022. Signed by Judge James Donato on 6/8/2022. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jdlc1, COURT STAFF) (Filed on 6/8/2022) (Entered: 06/08/2022)

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  • 06/02/2022
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  • Docket(#14) Minute Entry for proceedings held before Judge James Donato: Preliminary Injunction Hearing held on 6/2/2022. (jdlc1, COURT STAFF) (Date Filed: 6/2/2022) (Entered: 06/02/2022)

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  • 05/09/2022
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  • Docket(#13) ORDER re #8 Motion for (1) Temporary Restraining Order; (2) Order to Show Cause re Preliminary Injunction; (3) Order for Expedited Discovery; and (4) Order Authorizing Alternative Service. Preliminary Injunction Hearing set for 6/2/2022 at 10:00 AM. Signed by Judge James Donato on 5/9/2022. (jdlc2, COURT STAFF) (Filed on 5/9/2022) (Entered: 05/09/2022)

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  • 05/09/2022
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  • Docket(#12) Minute Entry for proceedings held before Judge James Donato: Motion Hearing held on 5/9/2022. (jdlc2, COURT STAFF) (Date Filed: 5/9/2022) (Entered: 05/09/2022)

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  • 05/04/2022
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  • Docket(#11) Declaration of Denise M. Mingrone in Support of #8 MOTION for Temporary Restraining Order (2) Order to Show Cause Re Preliminary Injunction; (3) Order For Expedited Discovery; and (4) Order Authorizing Service Of Process; Memorandum Of Points And Authorities In Support Thereof [Supplemental Mingrone Decl. ISO Plaintiff's Ex Parte Motion TRO] filed bySynopsys, Inc.. (Attachments: #1 Exhibit A)(Related document(s) #8 ) (Mingrone, Denise) (Filed on 5/4/2022) (Entered: 05/04/2022)

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  • 05/04/2022
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  • Docket(#10) NOTICE of Appearance by Robert Luis Uriarte (Uriarte, Robert) (Filed on 5/4/2022) (Entered: 05/04/2022)

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  • 05/03/2022
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  • Docket(#9) ORDER. A hearing on the motion for temporary restraining order, Dkt. No. #8 , is set for May 9, 2022, at 11:30 a.m. in Courtroom 11. Signed by Judge James Donato on 5/3/2022. (This is a text-only entry generated by the court. There is no document associated with this entry.) (jdlc1, COURT STAFF) (Filed on 5/3/2022) (Entered: 05/03/2022)

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  • 04/29/2022
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  • Docket(#8) MOTION for Temporary Restraining Order (2) Order to Show Cause Re Preliminary Injunction; (3) Order For Expedited Discovery; and (4) Order Authorizing Service Of Process; Memorandum Of Points And Authorities In Support Thereof filed by Synopsys, Inc.. (Attachments: #1 Declaration Denise Mingrone Declaration ISO Synopsys, Inc.s Ex Parte Motion for TRO; Order to Show Cause Re Preliminary Injunction, #2 Exhibit A to D. Mingrone Declaration ISO Synopsys, Inc. Ex Parte Motion for TRO, #3 Declaration Norman F. Kelly Declaration ISO Synopsys, Inc. Ex Parte Motion for TRO, #4 Declaration Daniel E. Roffman Declaration ISO Synopsys, Inc. Ex Parte Motion for TRO, #5 Proposed Order)(Mingrone, Denise) (Filed on 4/29/2022) (Entered: 04/29/2022)

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  • 04/27/2022

  • Docket(#7) CLERK'S NOTICE REGARDING THE FILING OF AN ACTION REGARDING A COPYRIGHT. The provisions of17 U.S.C. 508 require the submission of a report to theRegister of Copyrights. Please e-file a proposed Report onthe Filing or Determination of an Action or Appeal Regardinga Copyright form AO 121 using the event Civil Events Other Filings Notices Notice (Other), within five daysof this notice. (This is a text-only entry generated by the court. There is no document associated with this entry.) (far, COURT STAFF) (Filed on 4/27/2022) (Entered: 04/27/2022)

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  • 04/27/2022
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  • Docket(#6) Summons Issued as to Phan Van Khanh. (far, COURT STAFF) (Filed on 4/27/2022) (Entered: 04/27/2022)

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  • 04/27/2022
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  • Docket(#5) Initial Case Management Scheduling Order with ADR Deadlines: Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order No. 65 and http://cand.uscourts.gov/cameras. Case Management Statement due by 7/21/2022. Initial Case Management Conference set for 7/28/2022 10:00 AM in San Francisco, Courtroom 11, 19th Floor. (far, COURT STAFF) (Filed on 4/27/2022) (Entered: 04/27/2022)

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  • 04/26/2022

  • Docket(#4) Case assigned to Judge James Donato. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. (jlg, COURT STAFF) (Filed on 4/26/2022) (Entered: 04/26/2022)

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  • 04/26/2022
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  • Docket(#3) Certificate of Interested Entities by Synopsys, Inc. (Mingrone, Denise) (Filed on 4/26/2022) (Entered: 04/26/2022)

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  • 04/26/2022
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  • Docket(#2) Proposed Summons. (Mingrone, Denise) (Filed on 4/26/2022) (Entered: 04/26/2022)

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  • 04/26/2022
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  • Docket(#1) COMPLAINT against Phan Van Khanh ( Filing fee $ 402, receipt number ACANDC-17121287.). Filed bySynopsys, Inc.. (Attachments: #1 Civil Cover Sheet)(Mingrone, Denise) (Filed on 4/26/2022) (Entered: 04/26/2022)

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