True Return Systems, LLC v. MakerDAO
| True Return Systems, LLC |
| MakerDAO |
| 1:2022cv08478 |
| October 5, 2022 |
| US District Court for the Southern District of New York |
| Vernon S Broderick |
| Patent |
| 35 U.S.C. § 271 Patent Infringement |
| Plaintiff |
Docket Report
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This docket was last retrieved on October 2, 2023. A more recent docket listing may be available from PACER.
| Document Text |
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| Filing 47 LETTER addressed to Judge Vernon S. Broderick from Dustin F. Guzior dated March 16, 2023 re: Letter Submitted on March 14, 2023. Document filed by Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 46 LETTER from @makerDAOdai re: "DATA QUERY IN RESPONSE TO JUDGE'S 15/02/22 ORDER & PLAINTIFF'S LETTER 44" -MakerDAO governance asks the Court if it may submit CCI member's holdings data in response to Judge's Order and Plaintiff's Letter 44 on behalf of the proposed amicus curiae, without deeming to make an appearance, and without an obligation to corroborate the data etc. Document filed by MakerDAO.(sc) Modified on 3/15/2023 (sc). |
| Filing 45 LETTER addressed to Judge Vernon S. Broderick from Dustin F. Guzior dated March 10, 2023 re: Plaintiff's March 9, 2023 Letter. Document filed by Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 44 LETTER addressed to Judge Vernon S. Broderick from David A. Boag dated March 9, 2023 re: Opposition to Motion for Leave to Participate as Amicus Curiae. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 43 LETTER addressed to Judge Vernon S. Broderick from Dustin F. Guzior dated March 9, 2023 re: Letter Submitted on March 8, 2023. Document filed by Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 42 LETTER from MakerDAO, re: "PROVISIONAL REQUEST FOR DELAY" - If the Council is not admitted to defend our case, MakerDAO asks that the Court delay a determination of Default Judgment so that we can revise our strategy and seek alternative representation etc. Prior to any adverse ruling, MakerDAO's administrators would like the opportunity to reconsider our legal resources in the interest of delaying and vacating any Court ruling. to Document filed by MakerDAO.(sc) Modified on 3/8/2023 (nb). |
| ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #41 Proposed Order was reviewed and approved as to form. (km) |
| Filing 41 PROPOSED ORDER. Document filed by Crypto Council for Innovation. Related Document Number: #38 ..(Guzior, Dustin) Proposed Order to be reviewed by Clerk's Office staff. |
| Filing 40 DECLARATION of Dustin F. Guzior in Support re: #38 MOTION for Leave to Participate as Amicus Curiae .. Document filed by Crypto Council for Innovation. (Attachments: #1 Exhibit A - OpenSea Listing for 797 Patent, #2 Exhibit B - Graph of WETH to USD, #3 Exhibit C - Businesswire Article, #4 Exhibit D - Bloomberg Law Article, #5 Exhibit E - Bitcoinist Article, #6 Exhibit F - OpenSea Listing for 860 Patent, #7 Exhibit G - PTAB Decision in Ex Parte Praveen Jayachandran, #8 Exhibit H - PTAB Decision in Ex Parte Steven Charles Davis, #9 Exhibit I - Eberhardt and Tai Article for 6th ESSOC).(Guzior, Dustin) |
| Filing 39 MEMORANDUM OF LAW in Support re: #38 MOTION for Leave to Participate as Amicus Curiae . . Document filed by Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 38 MOTION for Leave to Participate as Amicus Curiae . Document filed by Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 37 LETTER from makerDAOdai, re: "CRYPTO COUNCIL FOR INNOVATION - II" - We are writing to request that the Court withdraw its requirement for members of the Crypto Council for Innovation to disclose their holdings in MakerDAO or any other entities etc. Based on recent US SEC tactics, we fear that formal detailed crypto disclosures could be used to attribute liability in this matter, future matters, or unanticipated tax enforcement actions in the US or elsewhere. Document filed by Crypto Council for Innovation.(sc) |
Filing 36
MEMO ENDORSEMENT on re: #35 Letter filed by Crypto Council for Innovation. ENDORSEMENT: "While there is certainly no requirement that amici be totally disinterested, the partiality of an amicus is a factor to consider in deciding whether to allow participation." Picard v. Greiff, 797 F. Supp. 2d 451,452 (S.D.N.Y. 2011) (internal quotations omitted). Accordingly, it is hereby ordered that by February 20, 2023, Crypto Council for Innovation shall disclose whether any of its members own, hold, or owe cryptocurrency assets of MakerDAO or token interests in MakerDAO. Following review of these materials, I will address Crypto Council for Innovation's request to participate as amicus curiae with respect to any default judgment proceedings. SO ORDERED. (Signed by Judge Vernon S. Broderick on 2/15/2023) (vfr)
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| Filing 35 LETTER addressed to Judge Vernon S. Broderick from James M. McDonald dated February 15, 2023 re: True Return Systems LLC v. MakerDAO. Document filed by Crypto Council for Innovation..(McDonald, James) |
| Filing 34 NOTICE OF APPEARANCE by Stephen Joseph Elliott on behalf of Crypto Council for Innovation..(Elliott, Stephen) |
| Filing 33 NOTICE OF APPEARANCE by Dustin Francis Guzior on behalf of Crypto Council for Innovation..(Guzior, Dustin) |
| Filing 32 PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by True Return Systems, LLC..(Boag, David) Proposed Default Judgment to be reviewed by Clerk's Office staff. |
| Filing 31 MEMORANDUM OF LAW in Support re: #26 MOTION for Default Judgment as to Defendant MakerDAO. . Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 30 AFFIDAVIT of David A. Boag in Support re: #26 MOTION for Default Judgment as to Defendant MakerDAO.. Document filed by True Return Systems, LLC. (Attachments: #1 Exhibit A-MakerDAO TOU, #2 Exhibit B-Virtual Currency Businesses-NYS DFS, #3 Exhibit C-Are there too many cryptocurrencies? (article), #4 Exhibit D-GUSD & MakerDAO Partnership Update, #5 Exhibit E-USPTO Track One Grant, #6 Exhibit F-USPTO Notice of Allowance, #7 Exhibit G-What BlockChain and Ledger Technology Can Do For Exchange Traded Products (article), #8 Exhibit H- MIP40c3-SP67: Modify Core Unit Budget - Strategic Happiness (SH-001), #9 Exhibit I-MIP39c2-SP11: Strategic Happiness Core Unit, #10 Exhibit J-[The DAO needs a serious discussion about legal structure, #11 Exhibit K-MakerDAO Income, #12 Exhibit L-DAI Outstanding, #13 Exhibit M-LES Executive Summary, #14 Exhibit N-Patent Licensing: A Closer Look (Part 2), #15 Exhibit O-Patent Licensing Royalty Rates: Everything You Need to Know, #16 Exhibit P-The DAI Foundation, #17 Exhibit Q-How Much Is Your Invention Worth, #18 Exhibit R-Infringement of TRS's U.S. Patent No. 10,025,797 by MakerDao, #19 Exhibit S-Tweet @MakerDAO, #20 Exhibit T-Dai Foundation position on Patent infringement complaints against MakerDAO, #21 Exhibit U-Tweet @MakerDAO, #22 Exhibit V-MakerDAO's Use of USP 10,025,797, #23 Exhibit W-MakerDAO MIP84 Discussion, #24 Exhibit X-DAIF CU Update, #25 Exhibit Y-DefiLlama, #26 Exhibit Z-FRB Large Commcercial Banks).(Boag, David) |
| Filing 29 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - PROPOSED ORDER. Document filed by True Return Systems, LLC. Related Document Number: #26 ..(Boag, David) Proposed Order to be reviewed by Clerk's Office staff. Modified on 2/14/2023 (km). |
| Filing 28 STATEMENT OF DAMAGES. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 27 FILING ERROR - DEFICIENT DOCKET ENTRY - (SEE DOCUMENT#31) MEMORANDUM OF LAW in Support re: #26 MOTION for Default Judgment as to Defendant MakerDAO. . Document filed by True Return Systems, LLC. (Attachments: #1 Exhibit A-Sola Franchise Corp. (cited caselaw), #2 Exhibit B-Sexy Hair Concepts (cited caselaw), #3 Exhibit C-Krevat (cited caselaw), #4 Exhibit D-SEC (cited caselaw)).(Boag, David) Modified on 2/14/2023 (lb). |
| Filing 26 MOTION for Default Judgment as to Defendant MakerDAO. Document filed by True Return Systems, LLC..(Boag, David) |
| ***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. #32 Proposed Default Judgment was reviewed and approved as to form. (km) |
| ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Notice to Attorney David Boag to RE-FILE Document #29 Proposed Order. Use the event type Proposed Orders, Proposed Default Judgment. (km) |
| Filing 25 CLERK'S CERTIFICATE OF DEFAULT as to MakerDAO. (tp) |
| Filing 24 DECLARATION of David A. Boag in Support re: #21 Proposed Clerk's Certificate of Default. Document filed by True Return Systems, LLC. (Attachments: #1 Appendix REQUEST TO ENTER DEFAULT).(Boag, David) |
| Filing 23 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - AFFIDAVIT of David A. Boag re: #21 Proposed Clerk's Certificate of Default . Document filed by True Return Systems, LLC. (Attachments: #1 Appendix REQUEST TO ENTER DEFAULT).(Boag, David) Modified on 1/3/2023 (tp). |
| Filing 22 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 21 PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by True Return Systems, LLC..(Boag, David) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). |
| ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Notice to Attorney David Boag to RE-FILE Document #23 Affidavit. Use the event type Declaration in Support (non-motion) found under the event list Other Answers. (tp) |
| Filing 19 LETTER addressed to Judge Vernon S. Broderick from True Return Systems, LLC dated December 23, 2022 re: December 22, 2023 Letter from Crypto Council for Innovation. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 18 LETTER addressed to Judge Vernon S. Broderick from James M. McDonald dated December 22, 2022 re: True Return Systems LLC v. MakerDAO. Document filed by Crypto Council for Innovation..(McDonald, James) |
| Filing 17 NOTICE OF APPEARANCE by Jacob Michael Croke on behalf of Crypto Council for Innovation..(Croke, Jacob) |
| Filing 16 NOTICE OF APPEARANCE by James McDonald on behalf of Crypto Council for Innovation..(McDonald, James) |
| Filing 20 LETTER from MakerDAOdai, re: "CRYPTO COUNCIL FOR INNOVATION"- We are writing in support of the Court's selection of the Crypto Council for Innovation to represent MakerDAO in this matter etc. The Council and its members are more active in governance than many of our internal Core Units and, as MakerDAO moves toward its End-Game restructuring, the Council and members are expected to play an outsized role. Document filed by MakerDAO.(sc) |
| Filing 15 LETTER from MakerDAOdai, re: The plaintiff is misleading the Court with respect to the limitations which arise from MakerDAO's carefully protected organizational form etc. We ask the Court to respect the need for pseudo anonymity in the cryptocurrency field(pesonal risk, theft risk, revenue authorities, etcetera) and the principles of cryptocurrency's immaculate and unattributed origins. Document filed by True Return Systems, LLC.(sc) |
| Filing 14 CERTIFICATE OF SERVICE. MakerDAO served on 11/30/2022, answer due 12/21/2022. Service was made by Mail. Document filed by True Return Systems, LLC..(Boag, David) |
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Filing 13
ORDER granting in part and denying in part #9 Motion to Serve. It is hereby ORDERED that service of process on the Defendant may be made in this action by providing a copy of the Summons and Complaint by: (1) direct message to the @MakerDAO Twitter account; (2) posting to the official MakerDAO forum at forum.makerdao.com; (3) e-mail message to support@makerdao.com; and (4) hard copy to MakerDAO at 110 Cooper Street, Santa Cruz, CA 95060. IT IS FURTHER ORDERED that Plaintiff's request to approve these alternative methods of service, nunc pro tunc, as of October 12, 2022, is DENIED. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 11/23/2022) (kv)
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| Filing 12 DECLARATION of Jack Fonss in Support re: #9 EX PARTE MOTION to Serve Defendant MakerDAO by Electronic Means.. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 11 DECLARATION of David A. Boag in Support re: #9 EX PARTE MOTION to Serve Defendant MakerDAO by Electronic Means.. Document filed by True Return Systems, LLC. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M, #14 Exhibit Exhibit N, #15 Exhibit Exhibit O, #16 Exhibit Exhibit P).(Boag, David) |
| Filing 10 EX PARTE MEMORANDUM OF LAW in Support re: #9 EX PARTE MOTION to Serve Defendant MakerDAO by Electronic Means. . Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 9 EX PARTE MOTION to Serve Defendant MakerDAO by Electronic Means. Document filed by True Return Systems, LLC. (Attachments: #1 Text of Proposed Order Text of Proposed Order).(Boag, David) |
| Filing 8 ELECTRONIC SUMMONS ISSUED as to MakerDAO. (vf) |
| Filing 7 REQUEST FOR ISSUANCE OF SUMMONS as to MakerDAO, re: #1 Complaint,,,. Document filed by True Return Systems, LLC..(Boag, David) |
| Filing 6 CIVIL COVER SHEET filed..(Boag, David) |
| Filing 5 AO 120 FORM PATENT - CASE OPENING - SUBMITTED. In compliance with the provisions of 35 U.S.C. 290, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following patent(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF). (vf) |
| ***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney David A. Boag to RE-FILE Document No. #4 Civil Cover Sheet. The filing is deficient for the following reason(s): Form is Blank. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. (vf) |
| ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney David A. Boag. The following case opening statistical information was erroneously selected/entered: County code New York. The following correction(s) have been made to your case entry: the County code has been modified to XX Out of State. (vf) |
| ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney David A. Boag to RE-FILE Document No. #1 Complaint. The filing is deficient for the following reason(s): the All Defendant radio button was selected. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (vf) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Vernon S. Broderick. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #https://nysd.uscourts.gov/rules/ecf-related-instructions..(vf) |
| Magistrate Judge James L. Cott is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vf) |
| Case Designated ECF. (vf) |
| ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney David A. Boag to RE-FILE Document No. #2 Request for Issuance of Summons. The filing is deficient for the following reason(s): plaintiff or plaintiff's attorney information section of Summons PDF not provided. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (vf) |
| Filing 4 FILING ERROR - PDF ERROR - CIVIL COVER SHEET filed..(Boag, David) Modified on 10/6/2022 (vf). |
| Filing 3 AO 120 FORM PATENT - NOTICE OF SUBMISSION BY ATTORNEY. AO 120 Form Patent/Trademark for case opening submitted to court for review..(Boag, David) |
| Filing 2 FILING ERROR - DEFICIENT - SUMMONS REQUEST - ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to MakerDAO, re: #1 Complaint. Document filed by True Return Systems, LLC..(Boag, David) Modified on 10/6/2022 (vf). |
| Filing 1 FILING ERROR - DEFICIENT PLEADING - FILED AGAINST PARTY ERROR -COMPLAINT against All Defendants. (Filing Fee $ 402.00, Receipt Number ANYSDC-26777834)Document filed by True Return Systems, LLC. (Attachments: #1 Exhibit EX 1-'797 Patent, #2 Exhibit EX 2-"The Maker Protocol: MakerDAOs Multi-Collateral Dai (MCD) System", #3 Exhibit EX 3-"Security: How the Maker Protocol handles the security of oracles", #4 Exhibit EX 4-" MakerDAO Documentation", #5 Exhibit EX 5-" Median - Detailed Documentation", #6 Exhibit EX 6-" Maker Protocol 101", #7 Exhibit EX 7-"Transaction manager, #8 Exhibit EX 8-"Introducing Oracles V2 and DeFi Feeds", #9 Exhibit EX 9-"Oracle Security Module (OSM) - Detailed Documentation", #10 Exhibit EX 10-"makerdao / uniswap-price-feed", #11 Exhibit EX 11-Claim Charts).(Boag, David) Modified on 10/6/2022 (vf). |
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| Plaintiff: True Return Systems, LLC | |
| Represented By: | David A. Boag |
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