CAA Industries, Ltd. v. Recover Innovations, Inc.
| CAA Industries, Ltd. |
| Recover Innovations, Inc. d/b/a Recover Tactical and Recover Innovations, Inc. doing business as Recover Tactical |
| 2:2022cv00581 |
| April 6, 2022 |
| US District Court for the District of Nevada |
| Gloria M Navarro |
| Elayna J Youchah |
| Patent |
| 35 U.S.C. § 271 Patent Infringement |
| Both |
Docket Report
RSS Track this Docket
This docket was last retrieved on March 13, 2024. A more recent docket listing may be available from PACER.
| Document Text |
|---|
Filing 31
RESPONSE to #29 Motion to Dismiss,,,,,,,,,,, by Plaintiff CAA Industries, Ltd.. Replies due by 6/9/2022. (Konieczny, Joseph)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
Filing 23
RESPONSE to #17 Motion to Dismiss, by Plaintiff CAA Industries, Ltd.. Replies due by 5/18/2022. (Krieger, John)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
Filing 16
SUMMONS Returned Executed by CAA Industries, Ltd. re #7 Summons Issued. Recover Innovations, Inc. served on 4/8/2022. (Krieger, John)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
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)
|
|
Filing 7
SUMMONS ISSUED as to Recover Innovations, Inc.. (JQC)
|
|
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)
|
|
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)
|
|
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)
|
|
Filing 4
Submission of PROPOSED ORDER on #2 Motion for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. (Krieger, John)
|
|
Filing 3
DECLARATION of Moshe Oz re #2 Motion for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. (Krieger, John)
|
|
Filing 2
MOTION for Preliminary Injunction by Plaintiff CAA Industries, Ltd.. Responses due by 4/20/2022. (Krieger, John)
|
|
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.
|
Access additional case information on PACER
Use the links below to access additional information about this case on the US Court's PACER system. A subscription to PACER is required.
Access this case on the Nevada District Court's Electronic Court Filings (ECF) System
- Search for Party Aliases
- Associated Cases
- Attorneys
- Case File Location
- Case Summary
- Docket Report
- History/Documents
- Parties
- Related Transactions
- Check Status
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
