CAA Industries, Ltd. v. Recover Innovations, Inc.
Plaintiff: CAA Industries, Ltd.
Defendant: Recover Innovations, Inc. d/b/a Recover Tactical and Recover Innovations, Inc. doing business as Recover Tactical
Case Number: 2:2022cv00581
Filed: April 6, 2022
Court: US District Court for the District of Nevada
Presiding Judge: Gloria M Navarro
Referring Judge: Elayna J Youchah
Nature of Suit: Patent
Cause of Action: 35 U.S.C. ยง 271 Patent Infringement
Jury Demanded By: Both
Docket Report

This docket was last retrieved on May 10, 2024. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 2, 2022 Opinion or Order Filing 31 RESPONSE to #29 Motion to Dismiss,,,,,,,,,,, by Plaintiff CAA Industries, Ltd.. Replies due by 6/9/2022. (Konieczny, Joseph)
May 31, 2022 Opinion or Order Filing 30 RESPONSE to #27 Motion to Strike,,,,,,,,, by Plaintiff CAA Industries, Ltd.. Replies due by 6/7/2022. (Attachments: #1 Appendix of Exhibits, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4) (Konieczny, Joseph)
May 19, 2022 Opinion or Order Filing 29 MOTION to Dismiss #28 Amended Complaint by Defendant Recover Innovations, Inc.. Responses due by 6/2/2022. (Attachments: #1 Appendix of Exhibits, #2 Exhibit 1 (Ingram v. Sterling, 14-cv-02691-GPC (DHB) (S.D. Cal. Aug. 16, 2016)), #3 Exhibit 2 (Ferrantino v. Stanford Univ. 21-cv-07757-LB (N.D. Cal. Oct. 12, 2021)), #4 Exhibit 3 (JS Prods., Inc. v. Kabo Tool Co., 2:11-cv-1856-RCJ-GWF (D. Nev. Feb. 24, 2012)), #5 Exhibit 4 ( Trs. of Columbia Univ. in City of New York v. NortonLifeLock Inc., 3:13cv808 (E.D. Va. Jan. 13, 2022)), #6 Exhibit 5 (In re Xyrem (Sodium Oxybate) Antitrust Litig., 20-MD-02966-LHK (N.D. Cal. Aug. 13, 2021)), #7 Exhibit 6 Lyden v. Nike Inc., 3:13-cv-00662-HZ (D. Or. June 6, 2014)), #8 Exhibit 7 (Champion Labs. Inc. v. Parker-Hannifin Corp., 1:10-CV-02371-OWW-DLB (E.D. Cal. May 16, 2011)), #9 Exhibit 8 Lyden v. Nike Inc., 3:13-cv-00662-HZ (D. Or. Oct. 22, 2013)), #10 Exhibit 9 (No. 8 Mine v. Eljen Grp., 3:18-cv-00104 (D. Nev. Oct. 26, 2020)), #11 Exhibit 10 (Emseal Joint Sys., Ltd. v. Schul Int'l Co., 2018 DNH 159 (D.N.H. Aug. 6, 2018)), #12 Exhibit 11 Leitner-Wise v. LWRC Int'l, GJH-16-2430 (D. Md. Feb. 28, 2017)), #13 Exhibit 12 (Tropical Paradise Resorts, LLC v. JBSHBM, LLC, 18-cv-60912-BLOOM/Valle (S.D. Fla. Jan. 2, 2019)), #14 Exhibit 13 (Heat Techs. v. Koehler, 1:18-cv-01229 (N.D. Ga. June 5, 2020)), #15 Exhibit 14 (FLS Transp. Servs. (USA) v. Casillas, 17-00013 (D. Nev. Sep. 18, 2017)), #16 Exhibit 15 (Xiamen Baby Pretty Prods. Co. v. Talbots Pharm. Family Prods., 3:21-CV-00409 (W.D. La. Dec. 8, 2021)), #17 Exhibit 16 (Sanh v. Opportunity Fin., LLC, C20-0310RSL (W.D. Wash. Jan. 12, 2021), #18 Exhibit 17 (Sunrise Hosp. & Med. Ctr., LLC v. Ariz. Physicians IPA, Inc., 2:18-CV-341 JCM (GWF) (D. Nev. July 13, 2018)), #19 Exhibit 18 (SVI, Inc. v. Supreme Corp., 16-01098 (D. Nev. Dec. 12, 2016)), #20 Exhibit 19 (Global Advanced Metals USA v. Kemet Blue Powder, 11-00793 (D. Nev. Sep. 6, 2012)), #21 Exhibit 20 (Jenny Yoo Collection v. Watters Design Inc., 2017 WL 4997838, 16-2205, slip op. (S.D.N.Y. Oct. 20, 2017)), #22 Exhibit 21 (Oracle Corp. v. DrugLogic, Inc., C 11-00910 JCS (N.D. Cal. Nov. 16, 2011)), #23 Exhibit 22 (Modern Font Applications v. PetSmart, 2:19-cv-00613-BSJ (D. Utah Jan. 4, 2021)), #24 Exhibit 23 (De La Vega v. Microsoft Corp., W-19-CV-00612-ADA (W.D. Tex. Feb. 7, 2020)), #25 Exhibit 24 (Nissim v. Wells Fargo Bank, N.A., 12-1201 CW (N.D. Cal. Apr. 8, 2013)), #26 Exhibit 25 (Gibson v. Credit Suisse AG, CV 10-1-EJL-REB (D. Idaho Feb. 17, 2012)), #27 Exhibit 26 (Dragasits v. Yu, 16-cv-01998 (S.D. Cal. June 21, 2018)), #28 Exhibit 27 (PRB Supply LLC v. Pale Horse GRS (D. Nev. Jan. 10, 2022)), #29 Exhibit 28 (Pilkington v. Abuela's Cocina LLC, CV-18-00281 (D. Ariz. July 23, 2019))) (Motolenich-Salas, Kenneth)
May 18, 2022 Opinion or Order Filing 28 AMENDED COMPLAINT with Jury Demand against Recover Innovations, Inc. by CAA Industries, Ltd.. No changes to parties. (Attachments: #1 Exhibit 1-3) (Konieczny, Joseph)
May 16, 2022 Opinion or Order Filing 27 MOTION to Strike #25 Notice of Manual Filing, #24 Reply, by Defendant Recover Innovations, Inc.. Responses due by 5/30/2022. (Attachments: #1 Appendix of Exhibits to Motion to Strike, #2 Exhibit 1 (Declaration of Oz filed in the NY Action at Doc. 11-2 filed August 19, 2019), #3 Exhibit 2 (Command Arms Accessories v. ME Techn., 19-06982 (S.D.N.Y. Oct. 31, 2019)), #4 Exhibit 3 (Docket Sheet, Judgment for $2,059,128.30, and Satisfaction of Judgment from ME Technology Inc. v. Moshe Oz and CAA Industries, 0:21-cv-61540-AHS (S.D. Fla.)), #5 Exhibit 4 (Order in ME Technology Inc. v. Moshe Oz and CAA Industries, 19-cv-61907-SINGHAL/Nalle (S.D. Fla. Feb. 7, 2020)), #6 Exhibit 5 (Vertigo Media v. Earbuds Inc., 1-21-cv-00120 (D. Del. Oct. 14, 2021)), #7 Exhibit 6 (Amazon.com Search of CAA Industries dated May 16, 2022), #8 Exhibit 7 (Amazon.com Search of RONI gun dated May 16, 2022), #9 Exhibit 8 (FDIC v. Lewis, 10-439 (D. Nev. July 29, 2015)), #10 Exhibit 9 (Pacquiao v. Mayweather, 2:09-cv-2448(D. Nev. Dec. 15, 2010)), #11 Exhibit 10 (US v. Rudd, C14-5434 BHS (W.D. Wash. Nov. 24, 2014)), #12 Exhibit 11 (Evans v. Scribe One Ltd., 19-04339 (D. Ariz. Jan. 20, 2022)), #13 Exhibit 12 (Salazar v. Driver Provider Phx. LLC, CV-19-05760-PHX-SMB (D. Ariz. 2020)), #14 Exhibit 13 (Thermapure, Inc. v. Water Out Or., Inc., C11-5958 BHS (W.D. Wash. Jan. 16, 2013)), #15 Exhibit 14 (Rawson v. Recovery Innovations, Inc., C17-5342 BHS (W.D. Wash. Nov. 27, 2018)), #16 Exhibit 15 (Quillar v. CDCR, 2:04-cv-01203 (E.D. Cal. Sep. 19, 2012)), #17 Exhibit 16 (Dickinson Frozen Foods v. FPS Food Process Sols., 17-cv-00519 (D. Idaho Nov. 29, 2021)), #18 Exhibit 17 (V5 Techs. v. Switch, Ltd., 2:17-cv-02349-KJD-NJK (D. Nev. Jan. 15, 2021)), #19 Exhibit 18 (Joe Hand Promotions, Inc. v. Manzo, 2:15-cv-00313 (D. Ariz. Sep. 21, 2016)), #20 Exhibit 19 (Oracle v. Rimini St., 10-0106 (D. Nev. Oct. 24, 2016)), #21 Exhibit 20 (Davis v. Penzone, 17-01946-PHX-SMB (BSB) (D. Ariz. Feb. 22, 2019)), #22 Exhibit 21 (SMC Constr. Co. v. Rex Moore Grp., Inc., 3:17-cv-00470-LRH-VPC (D. Nev. Aug. 30, 2017)), #23 Exhibit 22 (Net-Inspect v. U.S. Citizenship & Immigration Servs., 14-1514 (W.D. Wash. Feb. 28, 2015)), #24 Exhibit 23 (Titaness Light Shop, LLC v. Sunlight Supply Inc., 3:12-cv-0620 (D. Nev. May 9, 2013))) (Motolenich-Salas, Kenneth)
May 14, 2022 Opinion or Order Filing 26 REPLY to Response to #17 Motion to Dismiss, by Defendant Recover Innovations, Inc.. (Attachments: #1 Appendix of Exhibits to Reply to Response to Motion to Dismiss, #2 Exhibit 1 (Emazing Lights LLC v. Montes De Oca, SACV 15-1561-AG(Ex) (C.D. Cal. June 20, 2016)), #3 Exhibit 2 (IPS Group, Inc. v. Duncan Solutions, Inc., 3-15-cv-01526 (S.D. Cal. Mar. 18, 2016)), #4 Exhibit 3 (Woodhouse v. United States Gov't, 2:22-cv-00285-CAS (C.D. Cal. May 2, 2022)), #5 Exhibit 4 (Williams v. Kommunikare Therapy, P.C., 21-909 GJF/KRS (D.N.M. May 5, 2022)), #6 Exhibit 5 (Gainesville Inv'r v. Astronergy Solar, 21-CV-02654 (C.D. Cal. Apr. 22, 2022)), #7 Exhibit 6 (Nossk, Inc. v. Fitness Anywhere LLC, 21-cv-08914-BLF (N.D. Cal. May 11, 2022)), #8 Exhibit 7 (Studio 010 Inc. v. Dig. Cashflow, C20-1018-DGE (W.D. Wash. Apr. 4, 2022)), #9 Exhibit 8 (InSync Training, LLC v. Am. Soc'y for Training & Dev., 21-cv-594-JL, Opinion No. 2022 DNH 055 (D.N.H. Apr. 13, 2022)), #10 Exhibit 9 (TMC Aerospace, Inc. v. Elbit Systems of America, LLC, 2-15-cv-07595 (C.D. Cal. Jan. 29, 2016)), #11 Exhibit 10 (Rosenshine v. A. Meshi Cosmetics Indus., 18-cv-3572 (LDH) (E.D.N.Y. Mar. 30, 2020)), #12 Exhibit 11 (Cannarella v. Volvo Car USA LLC, 2-16-cv-06195 (C.D. Cal. Dec. 12, 2016)), #13 Exhibit 12 (Narrative Ark Entertainment LLC v. Archie Comic Publications, Inc., 16 CV 6109 (VB), *13 (S.D.N.Y. Sep. 5, 2017)), #14 Exhibit 13 (Apple v. Samsung, 12-CV-00630-LHK (N.D. Cal. Aug. 27, 2014)), #15 Exhibit 14 (The Redd Group, LLC v. The Glass Guru Franchise Sys., 3-12-cv-04070, *9 (N.D. Cal. July 8, 2013)), #16 Exhibit 15 (Wright v. Allstate Fire & Cas. Ins. Co., 2:21-cv-00335-DGE (W.D. Wash. Apr. 25, 2022)), #17 Exhibit 16 (Control Tech. & Sols. v. Omni Energy Partners, 4:21-686 (E.D. Mo. Dec. 21, 2021))) (Motolenich-Salas, Kenneth)
May 12, 2022 Opinion or Order Filing 25 NOTICE of Manual Filing by Plaintiff CAA Industries, Ltd. re #24 Reply,. Object: DVD, Volume(s): 1, Description: A demonstrative video of the invention at issue, manually filed with the Clerk's Office. (Konieczny, Joseph)
May 12, 2022 Opinion or Order Filing 24 REPLY to Response to #2 Motion for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. (Attachments: #1 Exhibit Notice of Manual Filing - Ex. 29, #2 Declaration Decl., #3 Exhibit Ex. 26-28, #4 Exhibit Ex. 29 Placeholder, #5 Exhibit Ex. 30, #6 Exhibit Ex. 31, #7 Exhibit Ex. 32, #8 Exhibit Ex. 33, #9 Exhibit Ex. 34, #10 Exhibit Ex. 35) (Konieczny, Joseph)
May 11, 2022 Opinion or Order Filing 23 RESPONSE to #17 Motion to Dismiss, by Plaintiff CAA Industries, Ltd.. Replies due by 5/18/2022. (Krieger, John)
May 2, 2022 Opinion or Order Filing 22 ORDER Granting #21 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Kenneth M. Motolenich-Salas for Recover Innovations, Inc. and approving Designation of Local Counsel Shlomo S. Sherman. Signed by Judge Gloria M. Navarro on 5/2/2022. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - JQC)
May 2, 2022 Opinion or Order Filing 21 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Kenneth M. Motolenich-Salas and DESIGNATION of Local Counsel Shlomo S. Sherman (Filing fee $ 250 receipt number ANVDC-6887892) by Defendant Recover Innovations, Inc.. (Attachments: #1 Certificate of Good Standing) (Sherman, Shlomo)
April 28, 2022 Opinion or Order Filing 20 DECLARATION of Ron Rosenberg re #18 Response,,, by Defendant Recover Innovations, Inc.. (Attachments: #1 Index of Exhibits, #2 Exhibit I, #3 Exhibit II, #4 Exhibit III, #5 Exhibit IV, #6 Exhibit V, #7 Exhibit VI, #8 Exhibit VII, #9 Exhibit VIII, #10 Exhibit IX, #11 Exhibit X, #12 Exhibit XI, #13 Exhibit XII) (Sherman, Shlomo)
April 28, 2022 Opinion or Order Filing 19 DECLARATION re #18 Response,,, by Defendant Recover Innovations, Inc.. (Attachments: #1 Index of Exhibits, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I) (Sherman, Shlomo)
April 28, 2022 Opinion or Order Filing 18 RESPONSE to #2 Motion for Preliminary Injunction by Defendant Recover Innovations, Inc.. Replies due by 5/5/2022. (Attachments: #1 Appendix of Exhibits, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Exhibit 9, #11 Exhibit 10, #12 Exhibit 11, #13 Exhibit 12, #14 Exhibit 13, #15 Exhibit 14, #16 Exhibit 15, #17 Exhibit 16, #18 Exhibit 17, #19 Exhibit 18, #20 Exhibit 19, #21 Exhibit 20, #22 Exhibit 21, #23 Exhibit 22, #24 Exhibit 23, #25 Exhibit 24, #26 Exhibit 25, #27 Exhibit 26, #28 Exhibit 27, #29 Exhibit 28, #30 Exhibit 29, #31 Exhibit 30, #32 Exhibit 31, #33 Exhibit 32, #34 Exhibit 33, #35 Exhibit 34, #36 Exhibit 35, #37 Exhibit 36, #38 Exhibit 37, #39 Exhibit 38, #40 Exhibit 39, #41 Exhibit 40, #42 Exhibit 41, #43 Exhibit 42) (Sherman, Shlomo)
April 27, 2022 Opinion or Order Filing 17 MOTION to Dismiss #1 Complaint,, by Defendant Recover Innovations, Inc.. Responses due by 5/11/2022. (Attachments: #1 Appendix Appendix of Exhibits, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Exhibit 9, #11 Exhibit 10, #12 Exhibit 11, #13 Exhibit 12, #14 Exhibit 13, #15 Exhibit 14, #16 Exhibit 15, #17 Exhibit 16) (Sherman, Shlomo)
April 20, 2022 Opinion or Order Filing 16 SUMMONS Returned Executed by CAA Industries, Ltd. re #7 Summons Issued. Recover Innovations, Inc. served on 4/8/2022. (Krieger, John)
April 19, 2022 Opinion or Order Filing 15 ORDER Granting #12 Motion to Extend Time re #2 Motion for Preliminary Injunction. Responses due by 4/28/2022. Replies due by 5/12/2022. Signed by Magistrate Judge Elayna J. Youchah on 4/19/2022. (Copies have been distributed pursuant to the NEF - JQC)
April 18, 2022 Opinion or Order Filing 14 ORDER Granting #11 Verified Petition for Permission to Practice Pro Hac Vice Joeseph Konieczny, Sr and approving Designation of Local Counsel John L. Krieger. Signed by Judge Gloria M. Navarro on 4/18/2022. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov (Copies have been distributed pursuant to the NEF - JQC)
April 18, 2022 Opinion or Order Filing 13 CERTIFICATE of Interested Parties by Recover Innovations, Inc. that identifies all parties that have an interest in the outcome of this case. Corporate Parent RT Recover Innovations Ltd. for Recover Innovations, Inc. added. (Sherman, Shlomo)
April 18, 2022 Opinion or Order Filing 12 Consent MOTION to Extend Time (First Request) for (i) Defendant Recover Innovations, Inc. dba Recover Tacticals Response and (ii) Plaintiffs Reply re #2 Motion for Preliminary Injunction by Defendant Recover Innovations, Inc.. (Attachments: #1 Index Index of Exhibits, #2 Exhibit Exhibit 1, #3 Exhibit Exhibit 2, #4 Exhibit Exhibit 3) (Sherman, Shlomo)
April 13, 2022 Opinion or Order Filing 11 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Joseph M. Konieczny, Sr. and DESIGNATION of Local Counsel John L. Krieger (Filing fee $ 250 receipt number ANVDC-6866981) by Plaintiff CAA Industries, Ltd.. (Krieger, John)
April 7, 2022 Opinion or Order Filing 10 CERTIFICATE of Interested Parties by CAA Industries, Ltd.. There are no known interested parties other than those participating in the case (Krieger, John)
April 7, 2022 Opinion or Order Filing 9 CLERK'S NOTICE re #1 -4 Certificate of Interested Parties filed by attorney John L. Krieger. The document should not be filed as an attachment to the Complaint. Instead, it should be filed as a separate document.Counsel is advised to refile the Certficate of Interested Parties using the event "Certificate Interested Parties" under the Commencement of an Action category. (no image attached) (SLD)
April 7, 2022 Opinion or Order Filing 8 NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Joseph Konieczny, Sr to comply with completion and filing of the Verified Petition and Designation of Local Counsel. For your convenience, click on the following link to obtain the form from the Court's website - #www.nvd.uscourts.gov. Upon approval of the Verified Petition, counsel is required to register for the Court's Case Management and Electronic Case Filing (CM/ECF) system and the electronic service of documents. Please visit the Court's website www.nvd.uscourts.gov to register Attorney. Verified Petition due by 4/21/2022. (no image attached) (JQC)
April 7, 2022 Opinion or Order Filing 7 SUMMONS ISSUED as to Recover Innovations, Inc.. (JQC)
April 7, 2022 Opinion or Order Filing 6 STANDING ORDER. This case has been assigned to the Honorable Judge Gloria M. Navarro. Judge Navarro's Chambers Practices, which are posted on the U.S. District Court, District of Nevada public website, may also be accessed directly via this hyperlink #www.nvd.uscourts.gov. (Copies have been distributed pursuant to the NEF - JQC)
April 7, 2022 Opinion or Order Filing 5 AO 120 - REPORT on the filing or determination of an action regarding a patent or trademark. E-mailed to the US Patent and Trademark Office. (Attachments: #1 Complaint) (JQC)
April 7, 2022 Opinion or Order Case randomly assigned to Judge Gloria M. Navarro and Magistrate Judge Elayna J. Youchah. ***Emergency motion previously filed in case.*** Nature of Suit: 830/835 Patent Case (JQC)
April 6, 2022 Opinion or Order Filing 4 Submission of PROPOSED ORDER on #2 Motion for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. (Krieger, John)
April 6, 2022 Opinion or Order Filing 3 DECLARATION of Moshe Oz re #2 Motion for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. (Krieger, John)
April 6, 2022 Opinion or Order Filing 2 MOTION for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. Responses due by 4/20/2022. (Krieger, John)
April 6, 2022 Opinion or Order Filing 1 COMPLAINT against Recover Innovations, Inc. d/b/a Recover Tactical (Filing fee $402 receipt number ANVDC-6858697) by CAA Industries, Ltd.. Proof of service due by 7/5/2022. (Attachments: #1 Civil Cover Sheet, #2 Summons, #3 Certificate of Interested Parties) (Krieger, John) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court.

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Plaintiff: CAA Industries, Ltd.
Represented By: John L. Krieger
Represented By: Joseph M Konieczny, Sr
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Defendant: Recover Innovations, Inc. d/b/a Recover Tactical
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Defendant: Recover Innovations, Inc. doing business as Recover Tactical
Represented By: Kenneth M. Motolenich-Salas
Represented By: Shlomo S. Sherman
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