Case number 1:23-cv-10352
IOT Innovations LLC v. SimpliSafe, Inc. > Documents
| Date Field | Doc. No. | Description (Pages) |
|---|---|---|
| Sep 25, 2023 | 50 | Judge Richard G. Stearns: ORDER entered. 30-Day Settlement Order of Dismissal. Associated Cases: 1:23-cv-10352-RGS, 1:23-cv-10520-RGS, 1:23-cv-10879-RGS. (Pacho, Arnold) (Entered: 09/25/2023) (1) |
| Sep 25, 2023 | 49 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting in part 48 Joint MOTION to Stay. The court will enter a 30-day Settlement Order of Dismissal. If the parties are unable to complete the settlement in 30 days, they should ask the court to extend the dismissal period. (Pacho, Arnold) (Entered: 09/25/2023) (0) |
| Sep 22, 2023 | 48 | Joint MOTION to Stay All Deadlines and Notice of Settlement by IOT Innovations LLC. (Attachments: # 1 Text of Proposed Order)(McDonough, James) (Entered: 09/22/2023) (0) |
| Sep 6, 2023 | 47 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting in part and denying in part 44 Motion for Order.Preliminary infringement contentions are due 9/15/2023; non-infringement and invalidity contentions are due 10/13/2023. Without leave of court, the parties are permitted to serve 30 interrogatories, 30 requests for admissions, and 30 document requests, to be served within fourteen (14) days of non-infringement and invalidity contentions (i.e., by 10/27/2023). The court expects responses to be made in thirty days, unless a request for additional time is granted. By 12/8/2023, plaintiff must select no more than 85 claims upon which to proceed (unless plaintiff shows good cause for allowing additional claims to be included, e.g., because they present distinct factual or legal issues). The parties shall exchange terms and proposed constructions no later than 12/22/2023; conduct a meet and confer to finalize the list of terms to be construed by 12/29/2023; and submit a joint claim construction statement (ranking the terms in decreasing order of importance) to the court by 1/5/2024. Opening claim construction briefs are to be filed by 1/26/2024; responsive briefs by 2/16/2024; replies (if any) by leave of court only. The court will schedule a Markman hearing at its convenience. Within fourteen (14) days of the courts claim construction ruling, plaintiff must further narrow its case to 51 claims (unless plaintiff shows good cause for allowing additional claims to be included, e.g., because they present distinct factual or legal issues).Fact discovery to be completed by 6/7/2024. Opening expert reports to be exchanged by 7/12/2024; rebuttal reports by 8/16/2024; expert discovery closes 9/27/2024. Within fourteen (14) days of expert discovery closing, plaintiff must further narrow its case to 17 claims (unless plaintiff shows good cause for allowing additional claims to be included, e.g., because they present distinct factual or legal issues).Dispositive motions and Daubert motions to be filed by 11/1/2024; oppositions by 11/22/2024; replies (if any) by leave of court only. (RGS, law3) (Entered: 09/06/2023) (0) |
| Sep 1, 2023 | 46 | Opposition re 44 MOTION for Order to Require Plaintiff to Limit Asserted Patents and Claims and to Modify Docket Schedule filed by IOT Innovations LLC. (Attachments: # 1 Exhibit 1: Dataquill Order, # 2 Exhibit 2: Automated Merchandizing Sys., Order, # 3 Exhibit 3: Keep Truckin Order)(McDonough, James) (Entered: 09/01/2023) (0) |
| Aug 18, 2023 | 45 | MEMORANDUM in Support re 44 MOTION for Order to Require Plaintiff to Limit Asserted Patents and Claims and to Modify Docket Schedule filed by SimpliSafe, Inc.. (Bell, Cory) (Entered: 08/18/2023) (22) |
| Aug 18, 2023 | 44 | MOTION for Order to Require Plaintiff to Limit Asserted Patents and Claims and to Modify Docket Schedule by SimpliSafe, Inc..(Bell, Cory) (Entered: 08/18/2023) (7) |
| Aug 9, 2023 | 43 | ANSWER to Counterclaim (Dkt. 41) by IOT Innovations LLC.(McDonough, James) (Entered: 08/09/2023) (24) |
| Jul 19, 2023 | 42 | Judge Richard G. Stearns: ELECTRONIC ORDER entered. An Answer having been filed, the court sets the following pretrial schedule:Initial disclosures to be exchanged by 8/18/2023. Preliminary infringement contentions to be served by 9/15/2023; non-infringement and invalidity contentions by 10/13/2023. Contentions may be amended and supplemented up to 30 days prior to the Markman hearing, and thereafter with the leave of court for good cause shown. The parties shall exchange terms and proposed constructions no later than 11/3/2023; conduct a meet and confer to finalize the list of terms to be construed by 11/10/2023; and submit a joint claim construction statement (ranking the terms in decreasing order of importance) to the court by 11/17/2023. Opening claim construction briefs to be filed by 12/22/2023; responsive briefs by 1/26/2024; replies (if any) by leave of court only. The court will schedule a Markman hearing at its convenience.Fact discovery to be completed by 5/10/2024. Opening expert reports to be exchanged by 6/14/2024; rebuttal reports by 7/19/2024; expert discovery closes 8/30/2024. Dispositive motions and Daubert motions to be filed by 9/27/2024; oppositions by 10/25/2024; replies (if any) by leave of court only. (RGS, law3) (Entered: 07/19/2023) (0) |
| Jul 19, 2023 | 41 | ANSWER to 30 Amended Complaint,,,, , COUNTERCLAIM against IOT Innovations LLC by SimpliSafe, Inc..(Bell, Cory) (Entered: 07/19/2023) (30) |
| Jul 6, 2023 | 40 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 39 Motion for Extension of Time. SimpliSafe's Answer is due July 19, 2023. (RGS, law3) (Entered: 07/06/2023) (0) |
| Jul 5, 2023 | 39 | MOTION for Extension of Time to July 19, 2023 to File Answer re 30 Amended Complaint,,,, Unopposed by SimpliSafe, Inc..(Bell, Cory) (Entered: 07/05/2023) (4) |
| Jun 28, 2023 | 38 | Judge Richard G. Stearns: ORDER entered denying 35 Motion to Dismiss for Failure to State a Claim. (RGS, law3) (Entered: 06/28/2023) (5) |
| Jun 21, 2023 | 37 | MEMORANDUM in Opposition re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by IOT Innovations LLC. (Attachments: # 1 Exhibit 1: Statement of Facts, # 2 Exhibit 2. Letter to Lavenue, # 3 Exhibit 3: CyberSoft Case Order)(McDonough, James) (Entered: 06/21/2023) (0) |
| Jun 7, 2023 | 36 | MEMORANDUM in Support re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by SimpliSafe, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Bell, Cory) (Entered: 06/07/2023) (0) |
| Jun 7, 2023 | 35 | MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by SimpliSafe, Inc..(Bell, Cory) (Entered: 06/07/2023) (4) |
| May 30, 2023 | 34 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting in part 31 Motion for Leave to File Excess Pages. The parties may file briefs of no more than 30 pages each. To ensure that the parties have adequate room to fully address the legal issues in their briefs, the court will, in lieu of a fact section, allow the parties to separately attach as an exhibit a document providing technical background for the seventeen patents. The exhibit shall be no more than 15 pages total and will not count towards the page limit. (RGS, law3) (Entered: 05/30/2023) (0) |
| May 29, 2023 | 33 | Opposition re 31 MOTION for Leave to File Excess Pages (Opposed) filed by IOT Innovations LLC. (McDonough, James) (Entered: 05/29/2023) (5) |
| May 22, 2023 | 32 | Judge Richard G. Stearns: ELECTRONIC ORDER entered. re 31 MOTION for Leave to File Excess Pages. Given the due date for SimpliSafe's response to the Amended Consolidated Complaint, IOT Innovations shall file any opposition to the motion for leave to file excess pages by 5/29/2023. (RGS, law3) Modified on 5/23/2023. Notice regenerated to counsel. (Pacho, Arnold). (Entered: 05/22/2023) (0) |
| May 22, 2023 | 31 | MOTION for Leave to File Excess Pages (Opposed) by SimpliSafe, Inc..(Bell, Cory) (Entered: 05/22/2023) (4) |
| May 17, 2023 | 30 | Complaint* (1) |
| May 3, 2023 | 29 | Judge Richard G. Stearns: ELECTRONIC ORDER entered. Order of Consolidation. Case No. 23-cv-10352-RGS, 23-cv-10520-RGS, and 23-cv-10879-RGS are hereby consolidated. All further pleadings are to be filed in the lead case 23-cv-10352-RGS. Plaintiff is ordered to file a consolidated amended complaint within 14 days. Response is due 21 days thereafter. Associated Cases: 1:23-cv-10352-RGS, 1:23-cv-10520-RGS, 1:23-cv-10879-RGS (Pacho, Arnold) (Entered: 05/03/2023) (0) |
| May 2, 2023 | 28 | RESPONSE TO COURT ORDER by IOT Innovations LLC re 24 Order to Show Cause,,, re: Consolidation of Cases 1:23-cv-10352, 1:23-cv-10520, and 1:23-cv-10879. (McDonough, James) (Entered: 05/02/2023) (5) |
| May 2, 2023 | 27 | BRIEF by SimpliSafe, Inc. to 24 Order to Show Cause,,, in Support of Consolidation of Cases for Pre-Trial and Trial Matters. (Bell, Cory) (Entered: 05/02/2023) (7) |
| Apr 30, 2023 | 26 | Judge Richard G. Stearns: ELECTRONIC ORDER entered denying as moot 22 Motion to Dismiss for Failure to State a Claim in light of 25 Amended Complaint. (RGS, law3) (Entered: 04/30/2023) (0) |
| Apr 28, 2023 | 25 | Amended Complaint* (1) |
| Apr 25, 2023 | 24 | Judge Richard G. Stearns: ORDER entered. Case No. 23-cv-10352, Case No. 23-cv-10520, and Case No. 23-cv-10879 have been designated as related. Per L.R. 40.1(g)(1), cases are related only if "one or more of the following similarities exist: i. the cases involve the same or substantially similar issues of fact; ii. the cases arise out of the same occurrence, transaction or property; iii. the cases involve insurance coverage for the same property, transaction or occurrence." The parties are ordered to file briefs of no more than 5 pages by May 2, 2023 explaining how (if at all) these cases are related within the scope of L.R. 40.1(g)(1) and, if they are related, why these cases should proceed as separate actions rather than one consolidated action. (RGS, law3) (Entered: 04/25/2023) (0) |
| Apr 14, 2023 | 23 | MEMORANDUM in Support re 22 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by SimpliSafe, Inc.. (Bell, Cory) (Entered: 04/14/2023) (29) |
| Apr 14, 2023 | 22 | MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by SimpliSafe, Inc..(Bell, Cory) (Entered: 04/14/2023) (4) |
| Apr 7, 2023 | 21 | NOTICE of Appearance by Lionel M. Lavenue on behalf of SimpliSafe, Inc. (Lavenue, Lionel) (Entered: 04/07/2023) (2) |
| Apr 7, 2023 | 20 | NOTICE of Appearance by Kara A. Specht on behalf of SimpliSafe, Inc. (Specht, Kara) (Entered: 04/07/2023) (2) |
| Mar 7, 2023 | 19 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 15 Motion for Leave to Appear Pro Hac Vice. Added Lionel M. Lavenue, Kara A. Specht, and Clinton P. Greub. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Pacho, Arnold) (Entered: 03/07/2023) (0) |
| Mar 6, 2023 | 18 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 17 Motion for Extension of Time to Answer. Defendant's response to the Complaint is due 4/14/2023. (RGS, law3) (Entered: 03/06/2023) (0) |
| Mar 6, 2023 | 17 | MOTION for Extension of Time to April 14, 2023 to File Answer re 1 Complaint,, [UNOPPOSED] by SimpliSafe, Inc..(Bell, Cory) (Entered: 03/06/2023) (3) |
| Mar 6, 2023 | 16 | CORPORATE DISCLOSURE STATEMENT by SimpliSafe, Inc. identifying Corporate Parent SimpliSafe Holding Corporation for SimpliSafe, Inc... (Bell, Cory) (Entered: 03/06/2023) (3) |
| Mar 6, 2023 | 15 | MOTION for Leave to Appear Pro Hac Vice for admission of Lionel M. Lavenue; Kara A. Specht; Clinton P. Greub Filing fee: $ 375, receipt number AMADC-9746110 by SimpliSafe, Inc.. (Attachments: # 1 Ex. 1 - Certification of Lionel M. Lavenue, # 2 Ex. 2 - Certification of Kara A. Specht, # 3 Ex. 3 - Certification of Clinton P. Greub)(Bell, Cory) (Entered: 03/06/2023) (0) |
| Mar 6, 2023 | 14 | NOTICE of Appearance by Cory C. Bell on behalf of SimpliSafe, Inc. (Bell, Cory) (Entered: 03/06/2023) (2) |
| Mar 3, 2023 | 13 | SUMMONS Returned Executed SimpliSafe, Inc. served on 2/22/2023, answer due 3/15/2023. (Attachments: # 1 Exhibit A)(Rozier, Carey) (Entered: 03/03/2023) (0) |
| Feb 28, 2023 | 12 | NOTICE of Appearance by James F. McDonough, III on behalf of IOT Innovations LLC (McDonough, James) (Entered: 02/28/2023) (3) |
| Feb 28, 2023 | 11 | NOTICE of Appearance by Jonathan L. Hardt on behalf of IOT Innovations LLC (Hardt, Jonathan) (Entered: 02/28/2023) (3) |
| Feb 28, 2023 | 10 | NOTICE of Appearance by Carey Matthew Rozier on behalf of IOT Innovations LLC (Rozier, Carey) (Entered: 02/28/2023) (3) |
| Feb 28, 2023 | 9 | Judge Richard G. Stearns: ELECTRONIC ORDER entered granting 8 Motion for Leave to Appear Pro Hac Vice. Added James F. McDonough, III, Jonathan Lloyd Hardt, and Carey Matthey Rozier. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. (Pacho, Arnold) (Entered: 02/28/2023) (0) |
| Feb 27, 2023 | 8 | MOTION for Leave to Appear Pro Hac Vice for admission of James F. McDonough, III; Jonathan Lloyd Hardt; Carey Matthew Rozier Filing fee: $ 375, receipt number AMADC-9734495 by IOT Innovations LLC. (Attachments: # 1 Affidavit Attorney James F. McDonough, III, # 2 Affidavit Attorney Jonathan Lloyd Hardt, # 3 Affidavit Attorney Carey Matthew Rozier)(Godkin, David) (Entered: 02/27/2023) (0) |
| Feb 17, 2023 | 7 | Summons Issued as to SimpliSafe, Inc.. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (de Oliveira, Flaviana) (Entered: 02/17/2023) (2) |
| Feb 17, 2023 | 6 | ELECTRONIC NOTICE of Case Assignment. Judge Richard G. Stearns assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Jennifer C. Boal. (Finn, Mary) (Entered: 02/17/2023) (0) |
| Feb 17, 2023 | 5 | NOTICE of Appearance by David S. Godkin on behalf of IOT INNOVATIONS LLC (Godkin, David) (Entered: 02/17/2023) (3) |
| Feb 17, 2023 | 4 | REPORT ON THE FILING OF AN ACTION REGARDING PATENT OR TRADEMARK. (Kruzer, James) (Entered: 02/17/2023) (2) |
| Feb 17, 2023 | 3 | CORPORATE DISCLOSURE STATEMENT by IOT INNOVATIONS LLC. (Kruzer, James) (Entered: 02/17/2023) (2) |
| Feb 17, 2023 | 2 | NOTICE of Appearance by James E. Kruzer on behalf of IOT INNOVATIONS LLC (Kruzer, James) (Entered: 02/17/2023) (3) |
| Feb 17, 2023 | 1 | COMPLAINT against SIMPLISAFE, INC., Filing fee: $ 402, receipt number AMADC-9724581 (Fee Status: Filing Fee paid), filed by IOT INNOVATIONS LLC. (Attachments: # 1 Exhibit A.U.S. Patent No. 7,209,876, # 2 Exhibit B.U.S. Patent No. 7,263,102, # 3 Exhibit C.U.S. Patent No. 7,526,762, # 4 Exhibit D.U.S. Patent No. 7,983,282, # 5 Exhibit E.U.S. Patent No. 8,972,576, # 6 Exhibit F.U.S. Patent No. 9,008,055, # 7 Exhibit G.Webpage: https://simplisafe.com/, # 8 Exhibit H.Webpage: https://simplisafe.com/home-security-shop-packages, # 9 Exhibit I.Webpage: https://support.simplisafe.com, # 10 Civil Cover Sheet, # 11 Category Form)(Kruzer, James) (Entered: 02/17/2023) (0) |
