Stratum Law Firm

Illinois

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Cases33

Challenger50%

Patent Owner50%

NPE50%

stratum-conseil

stratum.fr

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DesignSemicond., OpticTransport., E-Comm.

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Patrick J. CoyneNeal S. CohenPeter Kinsella

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Entered	Case	Description
01/08/25	Bounce Curl LLC v. Partnerships Unincorp Associations 1:24-CV-06575 ( N.D. IL )	NOTICE of Motion by Kevin John Keener for presentment of motion for default judgment [92] before Honorable Georgia N Alexakis on 1/16/2025 at 09:30 AM. (Keener, Kevin) (Entered: 01/08/2025)
01/08/25	Bounce Curl LLC v. Partnerships Unincorp Associations 1:24-CV-06575 ( N.D. IL )	MEMORANDUM by Bounce Curl, LLC in support of motion for default judgment [92] (Attachments: # [1] Declaration of Kevin Keener, # [2] Exhibit 1 to Declaration of Kevin Keener)(Keener, Kevin) (Entered: 01/08/2025)
01/08/25	Bounce Curl LLC v. Partnerships Unincorp Associations 1:24-CV-06575 ( N.D. IL )	MOTION by Plaintiff Bounce Curl, LLC for default judgment as to Defendant Doe 94 Yam Idf [Unopposed] (Keener, Kevin) (Entered: 01/08/2025)
12/30/24	Shenzhen Gaiyatuopu Network Technology Co Ltd v. Individuals Corps Ltd 1:24-CV-05111 ( N.D. IL )	MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction [49] is granted as to the remaining defendants. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any remaining defendant. By 1/3/25, plaintiff shall submit an updated proposed preliminary injunction order reflecting only the remaining defendants to the Court's proposed order inbox (proposed_order_cummings@ilnd.uscourts.gov). Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. The 1/10/25 tracking status hearing is stricken and re-set to 2/10/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice (cc, ) (Entered: 12/30/2024) MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction [49] is granted as to the remaining defendants. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any remaining defendant. By 1/3/25, plaintiff shall submit an updated proposed preliminary injunction order reflecting only the remaining defendants to the Court's proposed order inbox (proposed_order_cummings@ilnd.uscourts.gov). Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. The 1/10/25 tracking status hearing is stricken and re-set to 2/10/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice (cc, ) (Entered: 12/30/2024)
12/22/24	Luo v. Partnerships Unincorp Organizations In Schedule A 1:24-CV-01977 ( N.D. IL )	ATTORNEY Appearance for Defendant Neodrop by Bole Yuan (Yuan, Bole) (Entered: 12/22/2024)
12/10/24	Dyson Technology Ltd v. Partnerships Unincorp Associations 1:24-CV-04085 ( N.D. IL )	FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/10/2024. Notices Mailed. (psm, ) (Entered: 12/10/2024)
12/10/24	Dyson Technology Ltd v. Partnerships Unincorp Associations 1:24-CV-04085 ( N.D. IL )	CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 12/10/2024. Notices Mailed. (psm, ) (Entered: 12/10/2024)
12/10/24	Dyson Technology Ltd v. Partnerships Unincorp Associations 1:24-CV-04085 ( N.D. IL )	MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motions to approve consent judgment [62] and for entry of default judgment [63] are granted. Enter Consent Judgment. Enter Default Judgment Order. Terminate civil case. Notices Mailed. (psm, ) (Entered: 12/10/2024)
11/15/24	Pathway IP LLC v. Individuals Corps Ltd 1:24-CV-05218 ( N.D. IL )	MINUTE entry before the Honorable Franklin U. Valderrama: This is a "Schedule A" case, which is a type of lawsuit typically filed against a group of sellers whose assumed names are listed on an attachment to the complaint, usually called "Schedule A." Oakley, Inc. v. P'ships & Unincorporated, 2021 WL 308882, at 1 (N.D. Ill. January 30, 2021). Before the Court is Plaintiff's motion for default judgment as to certain Defendants. R. 225, Mot. Default; R. 226, Memo. Default. The Court denies the motion [225] without prejudice for the following reasons. First, Plaintiff asserts it is entitled to a reasonable royalty of $10,000 plus 10% of defaulting Defendants sales of unauthorized products pursuant to 35 U.S.C. § 284. In support of the $10,000 licensing fee, Plaintiff cites to the Declaration of Sason Gabay. Decl. Gabay 8. However, Plaintiff does not explain its calculation of the 10% of defaulting Defendants' sales of unauthorized products. Instead, Plaintiff includes a table with a column titled "10% Royalty of Sales by Defendant" without explanation, citation, or supporting documentation. Memo. at 11-12. Further, by the title of the column, it appears that Plaintiff is including all sales by the Defaulting Defendant, and it is not limited to only sales of the authorized products. Second, Plaintiff requests transaction costs, and cites one out-of-district case supporting this request, while maintaining that "courts have routinely held that a hypothetical license negotiation would have required transaction costs, which would be paid by the Defaulting Defendants." Id. at 9. However, Plaintiff does not support this request with any in-district case law or additional supporting authority, or describe how it arrived at the $5,000 per Defaulting Defendant transaction cost amount. Instead, Plaintiff cites to the amount of attorney's fees incurred in this case. Id. (citing Decl. Lee 9). It does not follow that a hypothetical license negotiation estimate would be the amount of the attorney's fees incurred in this case, which involves prosecuting alleged patent infringement. Finally, Plaintiff requests treble damages for each Defaulting Defendant. Memo. at 9. True, enhanced damages up to three times the amount are allowed under Section 284, but the Court is not convinced such enhanced damages are necessarily appropriate here. Based on the Court's review of the two cases cited in Plaintiff's memorandum following its request for treble damages, both cases were out-of-district, and none concerned Schedule A patent infringement cases. In any renewed default motion, Plaintiff must support its request for each category of damages with supporting authority, and to explain its methodology and calculation of the royalty of sales per each Defaulting Defendant, with supporting documentation. If Plaintiff continues to request treble the amount of Defaulting Defendants' profits for the unauthorized sales, any renewed motion must further support the basis for the request for enhanced damages and cite other patent "Schedule A" cases from this District, in which the court has awarded enhanced damages. Mailed notice. (jcm) (Entered: 11/15/2024) MINUTE entry before the Honorable Franklin U. Valderrama: This is a "Schedule A" case, which is a type of lawsuit typically filed against a group of sellers whose assumed names are listed on an attachment to the complaint, usually called "Schedule A." Oakley, Inc. v. P'ships & Unincorporated, 2021 WL 308882, at 1 (N.D. Ill. January 30, 2021). Before the Court is Plaintiff's motion for default judgment as to certain Defendants. R. 225, Mot. Default; R. 226, Memo. Default. The Court denies the motion [225] without prejudice for the following reasons. First, Plaintiff asserts it is entitled to a reasonable royalty of $10,000 plus 10% of defaulting Defendants sales of unauthorized products pursuant to 35 U.S.C. § 284. In support of the $10,000 licensing fee, Plaintiff cites to the Declaration of Sason Gabay. Decl. Gabay 8. However, Plaintiff does not explain its calculation of the 10% of defaulting Defendants' sales of unauthorized products. Instead, Plaintiff includes a table with a column titled "10% Royalty of Sales by Defendant" without explanation, citation, or supporting documentation. Memo. at 11-12. Further, by the title of the column, it appears that Plaintiff is including all sales by the Defaulting Defendant, and it is not limited to only sales of the authorized products. Second, Plaintiff requests transaction costs, and cites one out-of-district case supporting this request, while maintaining that "courts have routinely held that a hypothetical license negotiation would have required transaction costs, which would be paid by the Defaulting Defendants." Id. at 9. However, Plaintiff does not support this request with any in-district case law or additional supporting authority, or describe how it arrived at the $5,000 per Defaulting Defendant transaction cost amount. Instead, Plaintiff cites to the amount of attorney's fees incurred in this case. Id. (citing Decl. Lee 9). It does not follow that a hypothetical license negotiation estimate would be the amount of the attorney's fees incurred in this case, which involves prosecuting alleged patent infringement. Finally, Plaintiff requests treble damages for each Defaulting Defendant. Memo. at 9. True, enhanced damages up to three times the amount are allowed under Section 284, but the Court is not convinced such enhanced damages are necessarily appropriate here. Based on the Court's review of the two cases cited in Plaintiff's memorandum following its request for treble damages, both cases were out-of-district, and none concerned Schedule A patent infringement cases. In any renewed default motion, Plaintiff must support its request for each category of damages with supporting authority, and to explain its methodology and calculation of the royalty of sales per each Defaulting Defendant, with supporting documentation. If Plaintiff continues to request treble the amount of Defaulting Defendants' profits for the unauthorized sales, any renewed motion must further support the basis for the request for enhanced damages and cite other patent "Schedule A" cases from this District, in which the court has awarded enhanced damages. Mailed notice. (jcm) (Entered: 11/15/2024)
11/15/24	Pathway IP LLC v. Individuals Corps Ltd 1:24-CV-05218 ( N.D. IL )	STATUS Report by Pathway IP LLC Presented before District Judge (Haque, Sameeul) (Entered: 11/15/2024)