Khoros, LLC v. Lenovo Singapore PTE LTD
| KHOROS, LLC |
| LENOVO SINGAPORE PTE LTD, Lenovo (Beijing) LTD, Lenovo (United States), Inc., Lenovo Group Limited and Lenovo HK Services, LTD |
| 3:2020cv03399 |
| May 19, 2020 |
| US District Court for the Northern District of California |
| William H Orrick |
| Other Statutory Actions |
| None |
Docket Report
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This docket was last retrieved on May 28, 2021. A more recent docket listing may be available from PACER.
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| Filing 50 OPPOSITION/RESPONSE (re #32 MOTION to Dismiss (LENOVO US'S MOTION TO DISMISS COMPLAINT), #39 MOTION to Dismiss and Joinder in Lenovo (United States), Inc.'s Motion to Dismiss Complaint for Failure to State a Claim; Memo of P&A in support ) filed byKhoros, LLC. (Boyd, Matthew) (Filed on 7/15/2020) |
| Filing 49 AMENDED COMPLAINT against Lenovo (United States), Inc., Lenovo Group Limited, Lenovo (Beijing) LTD. Filed byKhoros, LLC. (Attachments: #1 Exhibit A - Lenovo Annual Report (2018-19), #2 Exhibit B - Declaration of Chen Li, #3 Exhibit C - Declaration of M. Potosky, #4 Exhibit D - 2007 MSA Contract and SO (redacted), #5 Exhibit E - 2013 Novation Agreement, #6 Exhibit F - 2016 Novation Agreement, #7 Exhibit G - 2015.03.25 SO (redacted), #8 Exhibit H - 2916.01.25 SO (redacted), #9 Exhibit I - 2016.01.28 SO (redacted), #10 Exhibit J - 2016.03.23 SO (redacted), #11 Exhibit K - 2016.03.28 SO (redacted), #12 Exhibit L - 2016.03.28 SO (redacted), #13 Exhibit M - 2016.03.30 (redacted), #14 Exhibit N - 2016.03.30 (redacted), #15 Exhibit O - 2016.06.23 (redacted), #16 Exhibit P - 2016.11.16 SO (redacted), #17 Exhibit Q - 2018.04.25 SO (redacted), #18 Exhibit R - 2018.09.20 (redacted), #19 Exhibit S - 2019.11.26 SO (redacted), #20 Exhibit T - Screenshot (redacted), #21 Exhibit U - Side by Side Comparison, #22 Exhibit V - 2019.08 SO (redacted))(Boyd, Matthew) (Filed on 7/15/2020) |
| Filing 48 Administrative Motion to File Under Seal Exhibits to First Amended Complaint filed by Khoros, LLC. (Attachments: #1 Declaration of Alifya Curtin, #2 Declaration of Nicholas Hill, #3 Certificate/Proof of Service of Declarations of Alifya Curtin and Nicholas Hill, #4 Stipulation in Support of Motion to Seal, #5 Proposed Order, #6 Exhibit D (redacted), #7 Exhibit D (unredacted), #8 Exhibit G (redacted), #9 Exhibit G (unredacted), #10 Exhibit H (redacted), #11 Exhibit H (unredacted), #12 Exhibit I (redacted), #13 Exhibit I (unredacted), #14 Exhibit J (redacted), #15 Exhibit J (unredacted), #16 Exhibit K (redacted), #17 Exhibit K (unredacted), #18 Exhibit L (redacted), #19 Exhibit L (unredacted), #20 Exhibit M (redacted), #21 Exhibit M (unredacted), #22 Exhibit N (redacted), #23 Exhibit N (unredacted), #24 Exhibit O (redacted), #25 Exhibit O (unredacted), #26 Exhibit P (redacted), #27 Exhibit P (unredacted), #28 Exhibit Q (redacted), #29 Exhibit Q (unredacted), #30 Exhibit R (redacted), #31 Exhibit R (unredacted), #32 Exhibit S (redacted), #33 Exhibit S (unredacted), #34 Exhibit T (redacted), #35 Exhibit T (unredacted), #36 Exhibit V (redacted), #37 Exhibit V (unredacted))(Boyd, Matthew) (Filed on 7/15/2020) |
| Filing 47 Notice of Withdrawal of Motion for Preliminary Injunction and Request for Expedited Discovery (Boyd, Matthew) (Filed on 7/13/2020) |
| Filing 46 Declaration of Alifya Curtin in Support of #43 Administrative Motion to File Under Seal (Defendants' Administrative Motion to Seal Portions of Their Memorandum of Points and Authorities and the Potosky Declaration in Support of Their Opposition to Plaintiffs Motion for Preliminary Injuncti filed byKhoros, LLC. (Related document(s) #43 ) (Presson, Ashley) (Filed on 7/10/2020) |
Filing 45
Order by Judge William H. Orrick granting #38 Motion for Pro Hac Vice by Joshua M. Rychlinski. (jmdS, COURT STAFF) (Filed on 7/7/2020)
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| Filing 44 OPPOSITION/RESPONSE (re #22 First MOTION for Preliminary Injunction ) filed byLenovo (United States), Inc., Lenovo HK Services, LTD. (Attachments: #1 Declaration of Michael Potosky ISO Opposition to Plaintiff's Motion for Preliminary Injunction, #2 Exhibit A (REDACTED VERSION), #3 Exhibit B, #4 Declaration of ChenLi ISO Opposition to Plaintiff's Motion for Preliminary Injunction, #5 Proposed Order Denying Khoros' Motion for Preliminary Injunction and Request for Expedited Discovery)(Goo, Valerie) (Filed on 7/6/2020) |
| Filing 43 Administrative Motion to File Under Seal (Defendants' Administrative Motion to Seal Portions of Their Memorandum of Points and Authorities and the Potosky Declaration in Support of Their Opposition to Plaintiffs Motion for Preliminary Injunction) filed by Lenovo (United States), Inc., Lenovo HK Services, LTD. (Attachments: #1 Declaration of Chun iso Defendants Administrative Motion to File Under Seal, #2 Certificate/Proof of Service of Declaration of Chun iso Defendants Administrative Motion to File Under Seal, #3 Signature Page (Declarations/Stipulations) Stipulation iso Defendants' Administrative Motion to File Under Seal, #4 Proposed Order Granting Defendants Administrative Motion to File Under Seal, #5 Redacted Version of Defendants Opposition to Motion for Preliminary Injunction, #6 Unredacted Version of Defendants Opposition to Motion for Preliminary Injunction, #7 Declaration Redacted Version of Declaration of Potosky iso Defendants Opposition to Motion for Preliminary Injunction, #8 Declaration Unredacted Version of Redacted Version of Declaration of Potosky iso Defendants Opposition to Motion for Preliminary Injunction, #9 Exhibit Redacted Version of Exhibit A to Declaration of Potosky, #10 Exhibit Unredacted Version of Exhibit A to Declaration of Potosky)(Chun, A.) (Filed on 7/6/2020) |
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Filing 42
ORDER TO AMEND BRIEFING SCHEDULE as to #22 First MOTION for Preliminary Injunction. Responses due by 7/6/2020. Replies due by 7/13/2020. Signed by Judge William H. Orrick on 07/05/2020. (jmdS, COURT STAFF) (Filed on 7/6/2020) Modified on 7/7/2020 (jlgS, COURT STAFF).
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Filing 41
STIPULATION AND ORDER Resetting Deadlines as to #39 MOTION to Dismiss. Responses due by 7/15/2020. Replies due by 7/22/2020. Motion Hearing set for 8/19/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Signed by Judge William H. Orrick on 07/06/2020. (jmdS, COURT STAFF) (Filed on 7/6/2020)
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| Filing 40 STIPULATION re #32 MOTION to Dismiss (LENOVO US'S MOTION TO DISMISS COMPLAINT) Joint Stipulation to Amend Briefing Schedule on Mo. to Dismiss filed by Khoros, LLC. (Attachments: #1 Proposed Order)(Presson, Ashley) (Filed on 7/3/2020) |
| Filing 39 MOTION to Dismiss and Joinder in Lenovo (United States), Inc.'s Motion to Dismiss Complaint for Failure to State a Claim; Memo of P&A in support filed by Lenovo HK Services, LTD. Motion Hearing set for 8/19/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Responses due by 7/16/2020. Replies due by 7/23/2020. (Attachments: #1 Proposed Order)(Chun, A.) (Filed on 7/2/2020) |
| Filing 38 MOTION for leave to appear in Pro Hac Vice for Joshua M. Rychlinski ( Filing fee $ 310, receipt number 0971-14651386.) filed by Lenovo (United States), Inc., Lenovo HK Services, LTD. (Rychlinski, Joshua) (Filed on 7/2/2020) |
| Filing 37 NOTICE of Voluntary Dismissal of Lenovo Singapore PTE Ltd ONLY by Khoros, LLC (Montoya, Phil) (Filed on 7/2/2020) |
| Filing 36 EXHIBITS re #23 First Administrative Motion to File Under Seal , #2 First Administrative Motion to File Under Seal Plaintiff's Complaint filed byKhoros, LLC. (Attachments: #1 Supplement Complaint and Unredacted Exhibits (file under seal), #2 Supplement Motion for PI with unredacted Keaney Exhibits)(Related document(s) #23 , #2 ) (Montoya, Phil) (Filed on 6/30/2020) |
| Filing 35 Amended ADMINISTRATIVE MOTION Administrative Motion re #2 First Administrative Motion to File Under Seal Plaintiff's Complaint, #23 First Administrative Motion to File Under Seal filed by Khoros, LLC. Responses due by 7/6/2020. (Attachments: #1 Declaration Curtin, #2 Certificate/Proof of Service certificate of service, #3 Supplement Joint Stip ISO amended mtn to seal, #4 Proposed Order proposed order, #5 Supplement Complaint and redacted Exhibits, #6 Supplement Motion for PI Redacted Keaney Exhibits)(Montoya, Phil) (Filed on 6/30/2020) |
| Filing 34 STIPULATION WITH PROPOSED ORDER re #22 First MOTION for Preliminary Injunction JOINT Stipulation and [Proposed] Order to Amend Briefing Schedule for Plaintiff Khoros, LLC's Motion for Preliminary Injunction and Request for Expedited Discovery; Declaration of Marisa Chun filed by Lenovo (United States), Inc., Lenovo Singapore PTE LTD. (Chun, A.) (Filed on 6/25/2020) |
| Filing 33 STIPULATION re #31 Administrative Motion to File Under Seal (LENOVO US'S ADMINISTRATIVE MOTION TO SEAL PORTIONS OF MEMORANDUM OF POINTS AND AUTHORITIES ISO MOTION TO DISMISS COMPLAINT) (STIPULATION ISO LENOVO US'S ADMINISTRATIVE MOTION TO SEAL) filed by Lenovo (United States), Inc.. (Chun, A.) (Filed on 6/24/2020) |
| Filing 32 MOTION to Dismiss (LENOVO US'S MOTION TO DISMISS COMPLAINT) filed by Lenovo (United States), Inc.. Motion Hearing set for 8/19/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Responses due by 7/8/2020. Replies due by 7/15/2020. (Attachments: #1 Lenovo US Request for Judicial Notice iso Motion to Dismiss Complaint, #2 Exhibit A to Lenovo US Request for Judicial Notice iso Motion to Dismiss Complaint, #3 Proposed Order Granting Lenovo US Motion to Dismiss Complaint)(Chun, A.) (Filed on 6/24/2020) |
| Filing 31 Administrative Motion to File Under Seal (LENOVO US'S ADMINISTRATIVE MOTION TO SEAL PORTIONS OF MEMORANDUM OF POINTS AND AUTHORITIES ISO MOTION TO DISMISS COMPLAINT) filed by Lenovo (United States), Inc.. (Attachments: #1 Declaration of A. Marisa Chun iso Lenovo US Administrative Motion to Seal, #2 Certificate/Proof of Service of Declaration of A. Marisa Chun iso Lenovo US Administrative Motion to Seal, #3 Proposed Order Granting US Lenovo Administrative Motion to Seal, #4 Redacted Version of Lenovo US Motion to Dismiss Complaint, #5 Unredacted Version of Lenovo US Motion to Dismiss Complaint)(Chun, A.) (Filed on 6/24/2020) |
| Filing 30 STIPULATION re #1 Complaint (Joint Stipulation to Extend Time for Lenovo Singapore Pte Ltd. to Answer or Otherwise Respond to Complaint) filed by Lenovo Singapore PTE LTD. (Chun, A.) (Filed on 6/23/2020) |
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Filing 29
Order by Judge William H. Orrick denying #24 Motion to Shorten Time. The Court finds the matter suitable for resolution without oral argument and vacates the hearing set for July 22, 2020. (jmdS, COURT STAFF) (Filed on 6/22/2020)
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| Filing 28 OPPOSITION/RESPONSE (re #24 First MOTION to Shorten Time ) (Lenovo's Opposition to Plaintiff's Motion to Shorten Time) filed byLenovo (United States), Inc.. (Attachments: #1 Proposed Order)(Chun, A.) (Filed on 6/19/2020) |
| Filing 27 CERTIFICATE OF SERVICE by Khoros, LLC Summons and complaint and other documents (Montoya, Phil) (Filed on 6/17/2020) |
| Filing 26 CERTIFICATE OF SERVICE by Khoros, LLC re #1 Complaint summons filed against Lenovo (Montoya, Phil) (Filed on 6/16/2020) |
| Filing 25 Second Administrative Motion to File Under Seal filed by Khoros, LLC. (Attachments: #1 Declaration Mark Keaney)(Montoya, Phil) (Filed on 6/16/2020) |
| Filing 24 First MOTION to Shorten Time filed by Khoros, LLC. (Attachments: #1 Declaration Matthew Boyd, #2 Proposed Order)(Montoya, Phil) (Filed on 6/15/2020) |
| Filing 23 First Administrative Motion to File Under Seal filed by Khoros, LLC. (Attachments: #1 Declaration A. Curtin, #2 Proposed Order PROPOSED ORDER)(Montoya, Phil) (Filed on 6/15/2020) |
| Filing 22 First MOTION for Preliminary Injunction filed by Khoros, LLC. Motion Hearing set for 8/12/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Responses due by 7/29/2020. Replies due by 8/5/2020. (Attachments: #1 Declaration Nicholas Hill w exhibits, #2 Declaration Mark Keany, #3 Proposed Order Proposed Order)(Montoya, Phil) (Filed on 6/15/2020) |
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Filing 21
Order by Judge William H. Orrick granting #18 Motion for Pro Hac Vice by Astor H.L. Heavan. (jmdS, COURT STAFF) (Filed on 6/13/2020)
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Filing 20
Order by Judge William H. Orrick granting #17 Motion for Pro Hac Vice by Mark Klanow. (jmdS, COURT STAFF) (Filed on 6/13/2020)
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| Filing 19 NOTICE of Appearance by Valerie Meiling Goo (Goo, Valerie) (Filed on 6/11/2020) |
| Filing 18 MOTION for leave to appear in Pro Hac Vice (Astor Henry Lloyd Heaven) ( Filing fee $ 310, receipt number 0971-14547499.) filed by Lenovo (United States), Inc.. (Attachments: #1 Certificate/Proof of Service Certificate of Good Standing)(Chun, A.) (Filed on 6/5/2020) |
| Filing 17 MOTION for leave to appear in Pro Hac Vice (Mark A. Klapow) ( Filing fee $ 310, receipt number 0971-14547213.) filed by Lenovo (United States), Inc.. (Attachments: #1 Certificate/Proof of Service Certificate of Good Standing)(Chun, A.) (Filed on 6/5/2020) |
| Filing 16 STIPULATION re #1 Complaint Joint Stipulation to Extend Time for Defendant to Answer or Otherwise Respond Under Civil L.R. 6-1(a) filed by Lenovo (United States), Inc.. (Chun, A.) (Filed on 6/5/2020) |
| Filing 15 CERTIFICATE OF SERVICE by Khoros, LLC Proof of Service of Standing orders and other documents (Montoya, Phil) (Filed on 6/3/2020) |
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Filing 14
CASE MANAGEMENT CONFERENCE ORDER - Case Management Conference set for 8/25/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor. Case Management Statement due by 8/18/2020. Signed by Judge William H. Orrick on 06/01/2020. (jmdS, COURT STAFF) (Filed on 6/1/2020)
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Filing 13
ORDER REASSIGNING CASE. Case reassigned using a proportionate, random, and blind system pursuant to General Order No. 44 to Judge William H. Orrick for all further proceedings. Magistrate Judge Donna M. Ryu no longer assigned to case, Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order No. 65 and http://cand.uscourts.gov/cameras. Signed by the Clerk on 6/1/2020. (Attachments: #1 Notice of Eligibility for Video Recording)(ajsS, COURT STAFF) (Filed on 6/1/2020)
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| Filing 12 CLERK'S NOTICE OF IMPENDING REASSIGNMENT TO A U.S. DISTRICT COURT JUDGE: The Clerk of this Court will now randomly reassign this case to a District Judge because either (1) a party has not consented to the jurisdiction of a Magistrate Judge, or (2) time is of the essence in deciding a pending judicial action for which the necessary consents to Magistrate Judge jurisdiction have not been secured. You will be informed by separate notice of the district judge to whom this case is reassigned. ALL HEARING DATES PRESENTLY SCHEDULED BEFORE THE CURRENT MAGISTRATE JUDGE ARE VACATED AND SHOULD BE RE-NOTICED FOR HEARING BEFORE THE JUDGE TO WHOM THIS CASE IS REASSIGNED. This is a text only docket entry; there is no document associated with this notice. (ig, COURT STAFF) (Filed on 5/29/2020) |
| Filing 11 PROOF OF SERVICE OF SUMMONS AND COMPLAINT AND OTHER DOCUMENTS by Khoros, LLC. (Montoya, Phil) (Filed on 5/28/2020) Modified on 5/29/2020 (cjlS, COURT STAFF). |
| Filing 10 CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by Khoros, LLC.. (Montoya, Phil) (Filed on 5/28/2020) |
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Filing 9
ORDER by Magistrate Judge Donna M. Ryu granting #5 Matthew A. Boyd's Motion for admission Pro Hac Vice. (ig, COURT STAFF) (Filed on 5/22/2020)
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Filing 8
ORDER by Magistrate Judge Donna M. Ryu granting #4 Ashley R. Presson's Motion for admission Pro Hac Vice. (ig, COURT STAFF) (Filed on 5/22/2020)
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| Filing 7 Summons Issued as to Lenovo (United States), Inc., Lenovo HK Services, LTD, Lenovo Singapore PTE LTD. (cjlS, COURT STAFF) (Filed on 5/21/2020) |
| Filing 6 Initial Case Management Scheduling Order with ADR Deadlines: Case Management Statement due by 8/12/2020. Initial Case Management Conference set for 8/19/2020 01:30 PM in Oakland, Courtroom 4, 3rd Floor. (cjlS, COURT STAFF) (Filed on 5/21/2020) |
| Filing 5 First MOTION for leave to appear in Pro Hac Vice Re: Matthew Boyd (Filing fee $ 310, receipt number 0971-14490136) filed by KHOROS, LLC. (Attachments: #1 Appendix Certificative of Good Standing)(Montoya, Phil) (Filed on 5/20/2020) Modified on 5/21/2020 (cjlS, COURT STAFF). |
| Filing 4 First MOTION for leave to appear in Pro Hac Vice Re: Ashley R. Presson (Filing fee $ 310, receipt number 0971-14490083) filed by KHOROS, LLC. (Attachments: #1 Appendix Certificate of Good Standing)(Montoya, Phil) (Filed on 5/20/2020) Modified on 5/21/2020 (cjlS, COURT STAFF). |
| Filing 3 Case assigned to Magistrate Judge Donna M. Ryu. 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. Counsel is required to send chambers a copy of the initiating documents pursuant to L.R. 5-1(e)(7). A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 6/3/2020. (haS, COURT STAFF) (Filed on 5/20/2020) |
| Filing 2 First Administrative Motion to File Under Seal Plaintiff's Complaint filed by KHOROS, LLC. (Attachments: #1 Declaration Alifa Curtin ISO Plaintiff's motion to file unredacted version of complaint, #2 Proposed Order PROPOSED ORDER, #3 Appendix PLAINTIFF'S COMPLAINT REDACTED VERSION, #4 Appendix PLAINTIFF'S COMPLAINT UNREDACTED VERSION)(Montoya, Phil) (Filed on 5/19/2020) |
| Filing 1 COMPLAINT REDACTED VERSION OF against All Plaintiffs ( Filing fee $ 400, receipt number 0971-14486360.). Filed byKHOROS, LLC. (Attachments: #1 Civil Cover Sheet, #2 Summons)(Montoya, Phil) (Filed on 5/19/2020) |
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