Complex Memory, LLC v. Motorola Mobility LLC
Plaintiff: COMPLEX MEMORY, LLC
Defendant: Motorola Mobility LLC
Case Number: 1:2018cv06255
Filed: September 13, 2018
Court: US District Court for the Northern District of Illinois
Presiding Judge: Edmond E Chang
Nature of Suit: Patent
Cause of Action: 35 U.S.C. § 271
Jury Demanded By: Both
Docket Report

This docket was last retrieved on April 18, 2019. A more recent docket listing may be available from PACER.

Date Filed Document Text
April 18, 2019 Filing 39 MAILED Patent report with certified copy of minute order dated 4/17/2019 to Patent Trademark Office, Alexandria VA. (Attachments: #1 Minute Order)(pk, )
April 17, 2019 Filing 38 MINUTE entry before the Honorable Edmond E. Chang: The agreed motion #36 to dismiss is granted. The case is dismissed with prejudice, each side to bear its own fees and costs. Status hearing of 04/18/2019 is vacated. Civil case terminated. Emailed notice (slb, )
April 17, 2019 Filing 37 NOTICE of Motion by David Randolph Bennett for presentment of motion to dismiss #36 before Honorable Edmond E. Chang on 4/18/2019 at 01:30 PM. (Bennett, David)
April 17, 2019 Filing 36 MOTION by Plaintiff Complex Memory, LLC to dismiss Motorola Mobility LLC (Joint Motion) (Attachments: #1 Text of Proposed Order)(Bennett, David)
April 3, 2019 Filing 35 MINUTE entry before the Honorable Edmond E. Chang: The joint extension motion #33 is granted, but no further extensions will be granted absent extraordinary circumstances. The response to the invalidity contentions is now due by 04/26/2019. All other litigation deadlines [R.26] are extended by another 14 days (beyond the 35-day extension). Status hearing of 04/04/2019 is reset for 04/18/2019 at 1:30 PM.Emailed notice (slb, )
April 1, 2019 Filing 34 NOTICE of Motion by David Randolph Bennett for presentment of extension of time #33 before Honorable Edmond E. Chang on 4/4/2019 at 09:00 AM. (Bennett, David)
April 1, 2019 Filing 33 MOTION by Plaintiff Complex Memory, LLC for extension of time to Extend Litigation Deadlines and Move the Status Hearing by Fourteen Days (Attachments: #1 Text of Proposed Order)(Bennett, David)
February 27, 2019 Filing 32 MINUTE entry before the Honorable Edmond E. Chang: Status hearing held. Both sides reported that there is an agreement in principle to settle the case. In light of the anticipated settlement, the response to the invalidity contentions is now due by 04/12/2019. All other litigation deadlines [R.26] are extended by 35 days. Status hearing set for 04/04/2019 at 9:00 a.m. Emailed notice (slb, )
February 12, 2019 Filing 31 MINUTE entry before the Honorable Edmond E. Chang: In light of the Court's illness, the status hearing of 02/13/2019 is vacated and reset to 02/27/2019 at 8:30 a.m.Emailed notice (slb, )
December 12, 2018 Filing 30 PROTECTIVE Order Signed by the Honorable Edmond E. Chang on 12/12/2018:Emailed notice(slb, )
December 12, 2018 Filing 29 MINUTE entry before the Honorable Edmond E. Chang: The motion #27 to file stipulated protective order is granted. The Court notes, however, that Local Rule 26.2 applies to the filing of under-seal material, meaning that the parties must show good cause for filing material under seal (not the other way around; there is no presumption in favor of sealing -- it is the opposite). Emailed notice (slb, )
December 6, 2018 Filing 28 NOTICE of Motion by David Randolph Bennett for presentment of motion for miscellaneous relief #27 before Honorable Edmond E. Chang on 12/13/2018 at 08:30 AM. (Bennett, David)
December 6, 2018 Filing 27 MOTION by Plaintiff Complex Memory, LLCfor Entry of Stipulated Protective Order (Joint) (Attachments: #1 Exhibit A - Text of Proposed Stipulated Protective Order)(Bennett, David)
November 20, 2018 Filing 26 MINUTE entry before the Honorable Edmond E. Chang: Status hearing held. After discussing the inapplicability of the MID Standing Order to utility-patent cases, the Court adopted the schedule proposed by both parties in R. 24, with the warning that extensions will not be granted without good cause taking into account the already-elongated dates. Local Patent Rule 2.1 Initial Disclosures are due 12/07/2018. Plaintiff's Initial Infringement Contentions due 12/05/2018. Initial Non-Infringement, Unenforceability, and Invalidity Contentions due 01/18/2019. Initial Response to Invalidity Contentions due 03/01/2019. Final Infringement and Final Unenforceability/Invalidity Contentions due 05/29/2019. Exchange of Claim Terms due 06/12/2019. Opening claim construction brief due 07/17/2019; Responsive claim construction brief due 08/14/2019; Reply claim construction brief due 09/06/2019; Joint claim construction chart due 09/13/2019. The claim-construction hearing will be set at a later date. Status hearing set for 02/13/2019 at 09:00 a.m. Mailed notice. (jjr, )
November 16, 2018 Filing 25 MINUTE entry before the Honorable Edmond E. Chang: Application by Matthew Frontz to appear pro hac vice #21 on behalf of Defendant Motorola Mobility LLC is granted.Emailed notice (slb, )
November 13, 2018 Filing 24 STATUS Report (Joint Initial Status Report) by Complex Memory, LLC (Bennett, David)
November 7, 2018 Filing 23 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Motorola Mobility LLC (Berezowskyj, Helena)
November 7, 2018 Filing 22 ANSWER to Complaint with Jury Demand by Motorola Mobility LLC(Berezowskyj, Helena)
November 7, 2018 Filing 21 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-15157652. (Frontz, Matthew)
November 6, 2018 Filing 20 NOTICE by Taras A. Gracey of Change of Address (Gracey, Taras)
November 6, 2018 Filing 19 ATTORNEY Appearance for Defendant Motorola Mobility LLC by Taras A. Gracey (Gracey, Taras)
November 6, 2018 Filing 18 ATTORNEY Appearance for Defendant Motorola Mobility LLC by Helena Oksana Berezowskyj (Berezowskyj, Helena)
October 19, 2018 Filing 17 MINUTE entry before the Honorable Edmond E. Chang: Application by Hanna Glomska Cohen to appear pro hac vice #16 on behalf of Plaintiff Complex Memory, LLC is granted.Emailed notice (slb, )
October 17, 2018 Filing 16 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-15069497. (Cohen, Hanna)
October 3, 2018 Filing 15 MINUTE entry before the Honorable Edmond E. Chang: Plaintiff's agreed extension motion #13 to answer is granted to 11/07/2018, but the deadline is firm (unless the parties reach a settlement), because the case should start moving forward and defense counsel should file an appearance by that date. The status hearing of 10/30/2018 is reset to 11/20/2018 at 9:30 a.m., with the joint status report due by 11/13/2018. Emailed notice (slb, )
October 1, 2018 Filing 14 NOTICE of Motion by David Randolph Bennett for presentment of motion for extension of time to file answer #13 before Honorable Edmond E. Chang on 10/4/2018 at 08:30 AM. (Bennett, David)
October 1, 2018 Filing 13 MOTION by Plaintiff Complex Memory, LLC for extension of time to file answer regarding complaint,,,,,,,,, #1 (Agreed) (Bennett, David)
September 21, 2018 Filing 12 MINUTE entry before the Honorable Edmond E. Chang:Application by Andrey Belenky to appear pro hac vice #10 is granted. Emailed notice (slb, )
September 18, 2018 Filing 11 NOTICE of Motion by David Randolph Bennett for presentment of motion to appear pro hac vice #10 before Honorable Edmond E. Chang on 9/27/2018 at 08:30 AM. (Bennett, David)
September 18, 2018 Filing 10 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14958039. (Belenky, Andrey)
September 17, 2018 Filing 9 MINUTE entry before the Honorable Edmond E. Chang: Application by Dmitry Kheyfits to appear pro hac vice #6 on behalf of Plaintiff is granted.Emailed notice (slb, )
September 17, 2018 Filing 8 MAILED Patent report to Patent Trademark Office, Alexandria VA. (pk, )
September 14, 2018 Filing 7 NOTICE of Motion by David Randolph Bennett for presentment of motion to appear pro hac vice #6 before Honorable Edmond E. Chang on 9/20/2018 at 08:30 AM. (Bennett, David)
September 14, 2018 Filing 6 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14946349. (Kheyfits, Dmitry)
September 13, 2018 Filing 5 MINUTE entry before the Honorable Edmond E. Chang: Initial status hearing set for 10/30/2018 at 8:30 a.m. The parties must file a joint initial status report with the content described in the attached status report requirements at least 3 business days before the initial status hearing. Plaintiff must still file the report even if not all Defendants have been served or have responded to requests to craft a joint report. Because the Procedures are occasionally revised, counsel must read them anew even if counsel has appeared before Judge Chang in other cases. Emailed notice (Attachments: #1 Status Report Requirements) (slb, )
September 13, 2018 Filing 4 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by COMPLEX MEMORY, LLC (Bennett, David)
September 13, 2018 Filing 3 ATTORNEY Appearance for Plaintiff COMPLEX MEMORY, LLC by David Randolph Bennett (Bennett, David)
September 13, 2018 Filing 2 CIVIL Cover Sheet (Bennett, David)
September 13, 2018 Filing 1 COMPLAINT for Patent Infringement filed by COMPLEX MEMORY, LLC; Jury Demand. Filing fee $ 400, receipt number 0752-14943511. (Attachments: #1 Exhibit Exhibit List, #2 Exhibit Attachment A - Accused Motorola Mobility Products, #3 Exhibit A - U.S. Patent No. 5,890,195, #4 Exhibit B - U.S. Patent No. 5,963,481, #5 Exhibit C - U.S. Patent No. 6,658,576, #6 Exhibit D - U.S. Patent No. 6,968,469, #7 Exhibit E - U.S. Patent No. 7,730,330, #8 Exhibit 1 - Portion of the Moto G5 Plus webpage (retrieved from www.motorola.com/us/products/moto-g-plus), #9 Exhibit 2 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 11.1 Cache terminology, #10 Exhibit 3 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 11.2 Cache controller, #11 Exhibit 4 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 11.1.3. Inclusive and exclusive caches., #12 Exhibit 5 - ARM Cortex-A53 MPCore Processor Technical Reference Manual, Chapter 6.6.2 Data prefetching and monitoring, #13 Exhibit 6 - ARM Cortex-A15 MPCore Processor Technical Reference Manual, Chapter 7.4, L2 cache prefetcher, #14 Exhibit 7 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 15 Power Management, #15 Exhibit 8 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 10.6 The Generic Interrupt Controller, #16 Exhibit 9 - ARM Cortex-A Series Programmers Guide for ARMv8-A, Chapter 15.3 Assembly language power instructions, #17 Exhibit 10 - ARM Cortex-A53 MPCore Processor Technical Reference Manual, Section 2.4.2 Power modes, #18 Exhibit 11 - Excerpt from LPDDR3 Standard, JEDEC JSD209-3C, #19 Exhibit 12 - Excerpt from LPDDR3 Standard, JEDEC JSD209-3C, #20 Exhibit 13 - Excerpt from LPDDR3 Standard, JEDEC JSD209-3C, #21 Exhibit 14 - Qualcomm Snapdragon 625 Processor Datasheet, #22 Exhibit 15 - ARM Cortex-A53 MPCore Technical Reference Manual, Chapter 2.1 About the Cortex-A53 processor functions, #23 Exhibit 16 - ARM Cortex-A53 MPCore Technical Reference Manual, Chapter 7.3.3 Snoop channel properties, #24 Exhibit 17 - ARM Cortex-A53 MPCore Technical Reference Manual, Chapter 2.4.1 Power domains, #25 Exhibit 18 - ARM Cortex-A53 MPCore Processor Technical Reference Manual, Chapter 1.2.1 ARM architecture, #26 Exhibit 19 - ARM Cortex-A53 MPCore Processor Technical Reference Manual, Chapter 2.4.2 Power modes)(Bennett, David)
September 13, 2018 CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. (pj, )
September 13, 2018 SUMMONS Issued as to Defendant Motorola Mobility LLC (pj, )

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Plaintiff: COMPLEX MEMORY, LLC
Represented By: David Randolph Bennett
Represented By: Andrey Belenky
Represented By: Hanna Glomska Cohen
Represented By: Dmitry Kheyfits
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Defendant: Motorola Mobility LLC
Represented By: Matthew Frontz
Represented By: Helena Oksana Berezowskyj
Represented By: Taras A. Gracey
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