Sequen AI, Inc. v. Fetch Rewards LLC
| Sequen AI, Inc. |
| Fetch Rewards LLC |
| Fetch Rewards LLC |
| Sequen AI, Inc. |
| 1:2026cv00731 |
| June 22, 2026 |
| U.S. District Court for the District of Delaware |
| Maryellen Noreika |
| Defend Trade Secrets Act (of 2016) |
| 18 U.S.C. § 1836 (b) Civil Action to Protect Trade Secrets |
| Plaintiff |
Docket Report
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| Filing 57 REDACTED VERSION of #56 Answer to Complaint, Counterclaim by Fetch Rewards LLC. (Poff, Adam) |
SO ORDERED, re #55 Unopposed MOTION for Leave to File Answer, Affirmative Defenses, and Counterclaims Under Seal. ORDERED by Judge Maryellen Noreika on 8/14/2026. (mdb)
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| Filing 56 [SEALED] ANSWER to #3 Complaint with Jury Demand , COUNTERCLAIM against Sequen AI, Inc. by Fetch Rewards LLC. (Attachments: #1 Exhibit 1-5)(Poff, Adam) |
| Filing 55 Unopposed MOTION for Leave to File Answer, Affirmative Defenses, and Counterclaims Under Seal - filed by Fetch Rewards LLC. (Poff, Adam) Modified on 8/14/2026 (mdb). |
| Filing 54 REDACTED VERSION of #30 Declaration by Fetch Rewards LLC. (Poff, Adam) Modified on 7/20/2026 (dlw). |
| Filing 53 REDACTED VERSION of #29 Declaration by Fetch Rewards LLC. (Poff, Adam) Modified on 7/20/2026 (dlw). |
| Filing 52 REDACTED VERSION of #28 Declaration by Fetch Rewards LLC. (Poff, Adam) Modified on 7/20/2026 (dlw). |
| Filing 51 REDACTED VERSION of #27 Declaration by Fetch Rewards LLC. (Poff, Adam) Modified on 7/20/2026 (dlw). |
| Filing 50 REDACTED VERSION of #26 Answering Brief in Opposition by Fetch Rewards LLC. (Poff, Adam) Modified on 7/20/2026 (dlw). |
| Filing 49 DECLARATION of Kathryn Bi in Further Support of Plaintiff's Motion to Seal its Reply Papers (DI 34) re #35 Reply Brief, #36 Declaration by Sequen AI, Inc.. (Brauerman, Stephen) |
| Filing 48 REDACTED VERSION of #36 Declaration by Sequen AI, Inc. (Brauerman, Stephen) Modified on 7/20/2026 (dlw). |
| Filing 47 REDACTED VERSION of #35 Reply Brief by Sequen AI, Inc. (Brauerman, Stephen) Modified on 7/20/2026 (dlw). |
| Pro Hac Vice Attorney Marja-Liisa Overbeck for Fetch Rewards LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
| Pro Hac Vice Attorney Michael Ardeljan for Fetch Rewards LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
| Pro Hac Vice Attorney Steven N. Feldman for Fetch Rewards LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
| Pro Hac Vice Attorney Carson D. Young for Fetch Rewards LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
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SO ORDERED, re #34 Unopposed MOTION to file Reply Brief in Support of Motion for a Temporary Restraining Order and Preliminary Injunction, and Related Filings Under Seal filed by Sequen AI, Inc.. ORDERED by Judge Maryellen Noreika on 7/13/2026. (mdb)
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SO ORDERED re #37 MOTION for Pro Hac Vice Appearance of Attorney Stephanie Sofer. Signed by Judge Maryellen Noreika on 7/13/2026. (as)
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SO ORDERED, re #39 STIPULATION TO EXTEND TIME for Defendant Fetch Rewards LLC to file public versions of its sealed filings (D.I. 26, 27, 28, 29, 30) to July 17, 2026 filed by Fetch Rewards LLC. ORDERED by Judge Maryellen Noreika on 7/13/2026. (mdb)
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| Filing 46 DECLARATION of Kathryn Bi in Further Support of Plaintiff's Motion to Seal by Sequen AI, Inc.. (Golden, Ronald) |
| Filing 45 REDACTED VERSION of #8 Declaration of Kathryn Bi in support of Motion for Temporary Restraining Order and Preliminary Injunction by Sequen AI, Inc.. (Golden, Ronald) Modified on 7/13/2026 (mdb). |
| Filing 44 REDACTED VERSION of #6 Declaration of Zoe Weil in support of Motion for Temporary Restraining Order and Preliminary Injunction by Sequen AI, Inc.. (Golden, Ronald) Modified on 7/13/2026 (mdb). |
| Filing 43 REDACTED VERSION of #7 Declaration of Raphael Louca in support of Motion for Temporary Restraining Order and Preliminary Injunction by Sequen AI, Inc.. (Golden, Ronald) Modified on 7/13/2026 (mdb). |
| Filing 42 REDACTED VERSION of #5 Opening Brief in Support of its Motion for a Temporary Restraining Order and Preliminary Injunction by Sequen AI, Inc.. (Golden, Ronald) Modified on 7/13/2026 (mdb). |
| Filing 41 REDACTED VERSION of #3 Complaint with Exhibits A-E by Sequen AI, Inc.. (Golden, Ronald) Modified on 7/13/2026 (mdb). |
| Filing 40 REQUEST for Oral Argument by Sequen AI, Inc. re #2 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction. (Golden, Ronald) |
| Filing 39 STIPULATION TO EXTEND TIME for Defendant Fetch Rewards LLC to file public versions of its sealed filings (D.I. 26, 27, 28, 29, 30) to July 17, 2026 - filed by Fetch Rewards LLC. (Poff, Adam) |
| Filing 38 Pro Hac Vice Fee - Credit Card Payment received for Stephanie Sofer. ( re #37 MOTION for Pro Hac Vice Appearance of Attorney Stephanie Sofer )( Payment of $ 50, receipt number ADEDC-5013633).(Golden, Ronald) |
| Filing 37 MOTION for Pro Hac Vice Appearance of Attorney Stephanie Sofer - filed by Sequen AI, Inc.. (Attachments: #1 Certification of Stephanie Sofer)(Golden, Ronald) |
| Filing 36 [SEALED] DECLARATION of Zoe Weil re #35 Reply Brief by Sequen AI, Inc.. (Attachments: #1 Exhibit A-C, #2 Certificate of Service)(Golden, Ronald) |
| Filing 35 [SEALED] REPLY BRIEF re #2 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by Sequen AI, Inc.. (Attachments: #1 Certificate of Service)(Golden, Ronald) |
| Filing 34 Unopposed MOTION to file Reply Brief in Support of Motion for a Temporary Restraining Order and Preliminary Injunction, and Related Filings Under Seal - filed by Sequen AI, Inc.. (Attachments: #1 Text of Proposed Order)(Golden, Ronald) |
| Filing 33 STIPULATION TO EXTEND TIME to move against, answer, or otherwise respond to the Complaint to August 13, 2026 - filed by Fetch Rewards LLC. (Poff, Adam) |
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SO ORDERED re #33 STIPULATION TO EXTEND TIME to move against, answer, or otherwise respond to the Complaint to August 13, 2026 (Set/Reset Answer Deadlines: Fetch Rewards LLC answer due 8/13/2026). ORDERED by Judge Maryellen Noreika on 7/10/2026. (dlw)
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SO ORDERED re #32 STIPULATION TO EXTEND TIME for Plaintiff Sequen AI, Inc. to file redactions to its sealed filings (D.I. 3, 5, 6, 7, 8) to July 10, 2026. No further extensions will be granted. ORDERED by Judge Maryellen Noreika on 7/8/2026. (dlw)
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| Filing 32 STIPULATION TO EXTEND TIME for Plaintiff Sequen AI, Inc. to file redactions to its sealed filings (D.I. 3, 5, 6, 7, 8) to July 10, 2026 - filed by Fetch Rewards LLC. (Poff, Adam) |
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SO ORDERED re #25 Unopposed MOTION for Leave to File Under Seal. ORDERED by Judge Maryellen Noreika on 7/7/2026. (dlw)
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SO ORDERED re #31 STIPULATION TO EXTEND TIME for Plaintiff Sequen AI, Inc. to file redactions to its June 22, 2026 sealed filings (D.I. 3,5,6,7,8) to July 7, 2026. ORDERED by Judge Maryellen Noreika on 7/7/2026. (dlw)
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| Filing 31 STIPULATION TO EXTEND TIME for Plaintiff Sequen AI, Inc. to file redactions to its June 22, 2026 sealed filings (D.I. 3,5,6,7,8) to July 7, 2026 - filed by Sequen AI, Inc.. (Golden, Ronald) |
| Filing 30 [SEALED] DECLARATION of Ryan Tecco re #26 Answering Brief in Opposition by Fetch Rewards LLC. (Poff, Adam) |
| Filing 29 [SEALED] DECLARATION of Wes Schroll re #26 Answering Brief in Opposition by Fetch Rewards LLC. (Poff, Adam) |
| Filing 28 [SEALED] DECLARATION of Marja-Liisa Overbeck re #26 Answering Brief in Opposition by Fetch Rewards LLC. (Poff, Adam) |
| Filing 27 [SEALED] DECLARATION of Wade Bruce re #26 Answering Brief in Opposition by Fetch Rewards LLC. (Poff, Adam) |
| Filing 26 [SEALED] ANSWERING BRIEF in Opposition re #2 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by Fetch Rewards LLC.Reply Brief due date per Local Rules is 7/10/2026. (Poff, Adam) |
| Filing 25 Unopposed MOTION for Leave to File Under Seal - filed by Fetch Rewards LLC. (Poff, Adam) Modified on 7/7/2026 (dlw). |
| Filing 24 NOTICE of Appearance by Parks Kingery on behalf of Fetch Rewards LLC (Kingery, Parks) |
| Filing 23 NOTICE of Appearance by Paul J. Loughman on behalf of Fetch Rewards LLC (Loughman, Paul) |
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SO ORDERED re #22 STIPULATION TO EXTEND TIME for Plaintiff Sequen AI, Inc. to file redactions to its June 22, 2026 sealed filings (D.I. 3, 5, 6, 7, 8) to through and including July 6, 2026. ORDERED by Judge Maryellen Noreika on 6/30/2026. (dlw)
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| Filing 22 STIPULATION TO EXTEND TIME Plaintiff Sequen AI, Inc. to file redactions to its June 22, 2026 sealed filings (D.I. 3, 5, 6, 7, 8) to through and including July 6, 2026 - filed by Sequen AI, Inc.. (Golden, Ronald) |
| Pro Hac Vice Attorney Kathryn Bi for Sequen AI, Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
| Filing 21 Letter to The Honorable Maryellen Noreika from Ronald P. Golden III regarding Defendant Fetch Rewards LLC's June 24, 2026 Letter - re #19 Letter,. (Golden, Ronald) |
| Filing 20 Pro Hac Vice Fee - Check received for Kathryn Bi and Margaret M. O'Neil. ( Payment of $ 100.00, receipt number# 5743) (oam) |
| Pro Hac Vice Attorney Margaret O'Neil for Sequen AI, Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (oam) |
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ORAL ORDER re #19 Letter - IT IS HEREBY ORDERED that Defendant's request is GRANTED (Set Briefing Schedule: re #2 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction - Answering Brief due 7/3/2026). ORDERED by Judge Maryellen Noreika on 6/25/2026. (dlw)
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SO ORDERED re #10 MOTION for Pro Hac Vice Appearance of Attorney Kathryn Bi and Margaret M. O'Neil filed by Sequen AI, Inc. ORDERED by Judge Maryellen Noreika on 6/25/2026. (dlw)
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| Filing 19 Letter to The Honorable Maryellen Noreika from Adam W. Poff regarding Request for Time to Oppose Plaintiffs Motion for Injunctive Relief - re #5 Opening Brief in Support, #2 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction. (Poff, Adam) |
| Filing 18 NOTICE of Appearance by Comrie Barr Flinn on behalf of Fetch Rewards LLC (Flinn, Comrie) |
| Filing 17 Pro Hac Vice Fee - Credit Card Payment received for Steven N. Feldman, Carson D. Young, Marja-Liisa Overbeck, and Michael Ardeljan. ( re #16 MOTION for Pro Hac Vice Appearance of Attorney Steven N. Feldman, Carson D. Young, Marja-Liisa Overbeck, and Michael Ardeljan )( Payment of $ 200, receipt number ADEDC-4999353).(Poff, Adam) |
| Filing 16 MOTION for Pro Hac Vice Appearance of Attorney Steven N. Feldman, Carson D. Young, Marja-Liisa Overbeck, and Michael Ardeljan - filed by Fetch Rewards LLC. (Poff, Adam) |
| Filing 15 Disclosure Statement pursuant to Rule 7.1: identifying Corporate Parent Fetch Rewards Holdings, Inc. for Fetch Rewards LLC filed by Fetch Rewards LLC. (Poff, Adam) |
| Filing 14 NOTICE of Appearance by Adam Wyatt Poff on behalf of Fetch Rewards LLC (Poff, Adam) |
| Case Assigned to Judge Maryellen Noreika. Please include the initials of the Judge (MN) after the case number on all documents filed. (alb) |
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SO ORDERED re #16 MOTION for Pro Hac Vice Appearance of Attorney Steven N. Feldman, Carson D. Young, Marja-Liisa Overbeck, and Michael Ardeljan filed by Fetch Rewards LLC. ORDERED by Judge Maryellen Noreika on 6/24/2026. (dlw)
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| Filing 13 SUMMONS Returned Executed by Sequen AI, Inc..Fetch Rewards LLC served on 6/23/2026, answer due 7/14/2026. (Golden, Ronald) |
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Filing 12
ORDER granting #1 MOTION to File Verified Complaint, Briefing in Support of Motion for a Temporary Restraining Order and Preliminary Injunction, and Related Filings Under Seal - filed by Sequen AI, Inc. Sequen shall file public versions of the Filings, with the confidential information redacted, within seven days of their respective deadlines. Signed by Judge Colm F. Connolly on 6/23/2026. (mws)
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| Filing 11 Summons Issued as to Fetch Rewards LLC on 6/23/2026. (mpb) |
| Remark: Exit electronic copies to Duty Judge (CFC). (mpb) |
| Filing 10 MOTION for Pro Hac Vice Appearance of Attorney Kathryn Bi and Margaret M. O'Neil - filed by Sequen AI, Inc. (mpb) |
| Filing 9 Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed - filed by Sequen AI, Inc. (mpb) |
| Filing 8 [SEALED] DECLARATION of Kathryn Bi in support of #2 MOTION for Temporary Restraining Order and Preliminary Injunction - filed by Sequen AI, Inc. (Attachments: #1 Exhibits 1-5)(mpb) |
| Filing 7 [SEALED] DECLARATION of Raphael Louca in support of #2 MOTION for Temporary Restraining Order and Preliminary Injunction - filed by Sequen AI, Inc. (Attachments: #1 Exhibit A)(mpb) |
| Filing 6 [SEALED] DECLARATION of Zoe Weil in support of #2 MOTION for Temporary Restraining Order and Preliminary Injunction - filed by Sequen AI, Inc. (Attachments: #1 Exhibits A-C)(mpb) |
| Filing 5 [SEALED] OPENING BRIEF in Support of #2 MOTION for Temporary Restraining Order and Preliminary Injunction - filed by Sequen AI, Inc. (mpb) |
| Filing 4 Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (mpb) |
| Filing 3 [SEALED] VERIFIED COMPLAINT with Jury Demand against Fetch Rewards LLC (Filing fee $ 405, receipt number 5738.) - filed by Sequen AI, Inc. (Attachments: #1 Exhibits A-E, #2 Verification, #3 Civil Cover Sheet)(mpb) |
| Filing 2 MOTION for Temporary Restraining Order and Preliminary Injunction - filed by Sequen AI, Inc. (Attachments: #1 Proposed Order)(mpb) Modified on 6/23/2026 (nms). |
| Filing 1 MOTION to File Verified Complaint, Briefing in Support of Motion for a Temporary Restraining Order and Preliminary Injunction, and Related Filings Under Seal - filed by Sequen AI, Inc. (Attachments: #1 Proposed Order)(mpb) |
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