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Case number 6:22-cv-00299

International Business Machines Corporation v. LzLabs GmbH et al > Documents

Date Field Doc. No.Description (Pages)
Oct 11, 2023 226 Sealed Motion filed: LZLABSS MOTION TO COMPEL A COMPLETE RESPONSE TO ITS INTERROGATORY REQUESTING AN IDENTIFICATION OF ALLEGED TRADE SECRETS. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Proposed Order) (zv) (Entered: 10/11/2023) (0)
Oct 10, 2023 224 Sealed Motion filed: PLAINTIFF IBMS MOTION TO COMPEL DISCOVERY. (Attachments: # 1 Proposed Order, # 2 Declaration, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6) (zv) (Entered: 10/10/2023) (0)
Oct 10, 2023 225 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Exhibit SEALED, # 2 Exhibit SEALED, # 3 Exhibit SEALED, # 4 Exhibit SEALED, # 5 Exhibit SEALED, # 6 Exhibit SEALED, # 7 Exhibit SEALED, # 8 Proposed Order) (Reynolds, Chris) (Entered: 10/10/2023) (0)
Oct 6, 2023 223 Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 Brief IBMS MOTION TO COMPEL DISCOVERY, # 3 Proposed Order, # 4 DECLARATION OF SUMEET DANG IN SUPPORT OF IBMS MOTION TO COMPEL DISCOVERY, # 5 Exhibit 1, # 6 Exhibit 2, # 7 Exhibit 3, # 8 Exhibit 4, # 9 Exhibit 5, # 10 Exhibit 6) (Dang, Sumeet) (Entered: 10/06/2023) (0)
Oct 4, 2023 222 REPLY to Response to Motion, filed by International Business Machines Corporation, re 219 MOTION for Issuance of Letter Rogatory filed by International Business Machines Corporation (Attachments: # 1 Exhibit 4)(Wilcox, Justin) (Entered: 10/04/2023) (0)
Sep 29, 2023 221 RESPONSE to Motion, filed by LzLabs GmbH, re 219 MOTION for Issuance of Letter Rogatory filed by International Business Machines Corporation (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Proposed Order)(Reynolds, Chris) (Entered: 09/29/2023) (0)
Sep 26, 2023 220 Joint MOTION for Extension of Time to File Response/Reply as to 219 MOTION for Issuance of Letter Rogatory by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 09/26/2023) (0)
Sep 20, 2023 219 MOTION for Issuance of Letter Rogatory by International Business Machines Corporation. (Attachments: # 1 Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3)(Wilcox, Justin) (Entered: 09/20/2023) (0)
Sep 18, 2023 218 Sealed ORDER REGARDING DEFENDANTS SEALED MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION [ECF NO. 181 ]. Signed by Judge Derek T. Gilliland. (zv) (Entered: 09/18/2023) (0)
Aug 30, 2023 217 Sealed Document filed: PLAINTIFF IBMS REPLY IN SUPPORT OF ITS MOTION TO COMPEL DISCOVERY [DKT. 213 ] (Attachments: # 1 DECLARATION OF JORDAN OWENS, # 2 Exhibit J) (zv) (Entered: 08/30/2023) (0)
Aug 29, 2023 216 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 IBMS REPLY IN SUPPORT OF ITS MOTION TO COMPEL DISCOVERY [Dkt. 213], # 3 DECLARATION OF JORDAN OWENS, # 4 Exhibit J) (Owens, Jordan) (Entered: 08/29/2023) (0)
Aug 24, 2023 215 Sealed Document filed: LZLABSS RESPONSE TO IBMS MOTION TO COMPEL DISCOVERY re 213 Sealed Motion filed: PLAINTIFF IBMS MOTION TO COMPEL DISCOVERY. (Attachments: # 1 Proposed Order, # 2 Declaration of T.R., # 3 Declaration of A.S., # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E) (zv) (Entered: 08/24/2023) (0)
Aug 22, 2023 214 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order Granting Motion to File Under Seal, # 2 LZLabs's Response to IBM's Motion to Compel, # 3 Proposed Order Denying Motion to Compel, # 4 Declaration of Thilo Rockman, # 5 Declaration of Adi Sirkes, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Exhibit D, # 10 Exhibit E) (Reynolds, Chris) (Entered: 08/22/2023) (0)
Aug 16, 2023 213 Sealed Motion filed: PLAINTIFF IBMS MOTION TO COMPEL DISCOVERY. (Attachments: # 1 Proposed Order, # 2 Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I) (zv) (Entered: 08/16/2023) (0)
Aug 15, 2023 212 Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 Brief SEALED DOCUMENT, # 3 Proposed Order, # 4 SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Exhibit SEALED DOCUMENT, # 8 Exhibit SEALED DOCUMENT, # 9 Exhibit SEALED DOCUMENT, # 10 Exhibit SEALED DOCUMENT, # 11 Exhibit SEALED DOCUMENT, # 12 Exhibit SEALED DOCUMENT, # 13 Exhibit SEALED DOCUMENT) (Owens, Jordan) (Entered: 08/15/2023) (0)
Aug 8, 2023 211 REPLY to Response to Motion, filed by LzLabs GmbH, re 208 MOTION to Strike 205 Sealed Document, EXHIBITS H-J to IBM's Motion to Compel filed by Defendant LzLabs GmbH (Reynolds, Chris) (Entered: 08/08/2023) (7)
Aug 1, 2023 210 Response in Opposition to Motion, filed by International Business Machines Corporation, re 208 MOTION to Strike 205 Sealed Document, EXHIBITS H-J to IBM's Motion to Compel filed by Defendant LzLabs GmbH (Attachments: # 1 Proposed Order)(Dang, Sumeet) (Entered: 08/01/2023) (0)
Jul 28, 2023 209 REPLY to Response to Motion, filed by LzLabs GmbH, re 203 Sealed Motion filed filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC in Support of its Motion to Modify the Protective Order (Reynolds, Chris) (Entered: 07/28/2023) (7)
Jul 25, 2023 208 MOTION to Strike 205 Sealed Document, EXHIBITS H-J to IBM's Motion to Compel by LzLabs GmbH. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order)(Reynolds, Chris) (Entered: 07/25/2023) (0)
Jul 24, 2023 207 Sealed Document filed: PLAINTIFF IBMS RESPONSE IN OPPOSITION TO 203 LZLABS MOTION TO MODIFY THE PROTECTIVE ORDER TO ALLOW DISCLOSURE OF CERTAIN DESIGNATED MATERIAL TO NON-PARTY DEPONENT ADRIAN HUDSON OR, IN THE ALTERNATIVE, LIMIT THE SCOPE OF THE DEPOSITION. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D) (zv) (Entered: 07/24/2023) (0)
Jul 21, 2023 205 Sealed Document filed : IBMS REPLY IN SUPPORT OF 188 ITS MOTION TO COMPEL DISCOVERY REGARDING LZLABS CLEAN ROOM PROCESS AND DISCOVERY REQUEST PROCEDURES (Attachments: # 1 Affidavit, # 2 Exhibit H, # 3 Exhibit I, # 4 Exhibit J, # 5 Exhibit K, # 6 Exhibit L, # 7 Exhibit M, # 8 Exhibit N) (lad) (Entered: 07/21/2023) (0)
Jul 21, 2023 206 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order SEALED DOCUMENT, # 2 Brief SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Proposed Order SEALED DOCUMENT) (Zhu, Peter) (Entered: 07/21/2023) (0)
Jul 20, 2023 204 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order SEALED DOCUMENT, # 2 Brief SEALED DOCUMENT, # 3 Affidavit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Exhibit SEALED DOCUMENT, # 8 Exhibit SEALED DOCUMENT, # 9 Exhibit SEALED DOCUMENT, # 10 Exhibit SEALED DOCUMENT) (Zhu, Peter) (Entered: 07/20/2023) (0)
Jul 18, 2023 202 [STIPULATED] AMENDED ORDER REGARDING E-DISCOVERY. Signed by Judge Derek T. Gilliland. (zv) (Entered: 07/18/2023) (10)
Jul 18, 2023 203 Sealed Motion filed: LZLABSS MOTION TO MODIFY THE PROTECTIVE ORDER TO ALLOW DISCLOSURE OF CERTAIN DESIGNATED MATERIAL TO NON-PARTY DEPONENT ADRIAN HUDSON OR, IN THE ALTERNATIVE, LIMIT THE SCOPE OF THE DEPOSITION. (Attachments: # 1 Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5) (zv) (Entered: 07/18/2023) (0)
Jul 17, 2023 201 CORRECTED Motion for leave to File Sealed Document re 200 (Attachments: # 1 Exhibit SEALED DOCUMENT, # 2 Exhibit SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Exhibit SEALED DOCUMENT, # 8 Proposed Order SEALED DOCUMENT) (Reynolds, Chris) (Entered: 07/17/2023) (0)
Jul 14, 2023 200 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Exhibit SEALED DOCUMENT, # 2 Exhibit SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Exhibit SEALED DOCUMENT, # 8 Proposed Order SEALED DOCUMENT) (Reynolds, Chris) Modified on 7/17/2023. Defendant's Counsel Office informed Clerk's Office of an error with Exhibit #1 being an incomplete filing. Counsel will be refiling corrected Motion with complete exhibits. Instant Motion is being terminated (zv). (Entered: 07/14/2023) (0)
Jul 10, 2023 199 RESPONSE to Motion, filed by LzLabs GmbH, re 195 Opposed MOTION for Leave to File PLAINTIFF IBMS SUR-REPLY TO LZLABS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRAD filed by International Business Machines Corporation (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 07/10/2023) (0)
Jul 7, 2023 198 Sealed Document filed: LZLABSS RESPONSE TO 188 IBMS MOTION TO COMPEL DISCOVERY REGARDING LZLABS CLEAN ROOM PROCESS AND DISCOVERY REQUEST PROCEDURES. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Order) (zv) (Entered: 07/07/2023) (0)
Jul 6, 2023 196 ATTACHMENT Proposed Order to 195 Opposed MOTION for Leave to File PLAINTIFF IBMS SUR-REPLY TO LZLABS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRAD by International Business Machines Corporation. (Wilcox, Justin) (Entered: 07/06/2023) (2)
Jul 6, 2023 197 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Brief SEALED DOCUMENT, # 2 Exhibit SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Proposed Order SEALED DOCUMENT, # 8 Proposed Order SEALED DOCUMENT) (Reynolds, Chris) (Entered: 07/06/2023) (0)
Jul 5, 2023 195 Opposed MOTION for Leave to File PLAINTIFF IBMS SUR-REPLY TO LZLABS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRADE SECRETS by International Business Machines Corporation. (Attachments: # 1 Exhibit A [PLAINTIFF IBMS SUR-REPLY])(Wilcox, Justin) (Entered: 07/05/2023) (0)
Jun 28, 2023 192 Sealed Order Granting 191 LZLABSS UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL ITS REPLY IN SUPPORT OF ITS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRADE SECRETS.Signed by Judge David A. Ezra. (zv) (Entered: 06/28/2023) (0)
Jun 28, 2023 193 Sealed Document filed: LZLABSS REPLY IN SUPPORT OF ITS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRADE SECRETS re 181 . (zv) (Entered: 06/28/2023) (0)
Jun 28, 2023 194 ORDER GRANTING 190 Motion for Extension of Time to File Response/Reply re 190 Joint MOTION for Extension of Time to File Response/Reply Joint Motion to Modify Motion to Compel Briefing Schedule and Page Limits. Signed by Judge David A. Ezra. (zv) (Entered: 06/28/2023) (1)
Jun 27, 2023 190 Joint MOTION for Extension of Time to File Response/Reply Joint Motion to Modify Motion to Compel Briefing Schedule and Page Limits by LzLabs GmbH. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 06/27/2023) (0)
Jun 27, 2023 191 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Exhibit SEALED DOCUMENT, # 2 Proposed Order SEALED DOCUMENT) (Reynolds, Chris) (Entered: 06/27/2023) (0)
Jun 23, 2023 186 ORDER ([STIPULATED] ORDER REGARDING E-DISCOVERY) GRANTING 163 Joint Motion For Entrance of Order Governing Electronic Discovery. Signed by Judge Derek T. Gilliland. (zv) (Entered: 06/23/2023) (10)
Jun 23, 2023 187 Sealed Order Granting 185 Unopposed Motion for leave to File Sealed Document. Signed by Judge David A. Ezra. (zv) (Entered: 06/23/2023) (0)
Jun 23, 2023 188 Sealed Motion filed: IBMS MOTION TO COMPEL DISCOVERY REGARDING LZLABS CLEAN ROOM PROCESS AND DISCOVERY REQUEST PROCEDURES. (Attachments: # 1 Declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G) (zv) (Entered: 06/23/2023) (0)
Jun 23, 2023 189 AMENDED SCHEDULING ORDER: Dispositive Motions due by 3/14/2024. Final Pretrial Conference set for 5/6/2024 before Judge David A. Ezra. Motions terminated: 182 Joint MOTION for Entry of Scheduling Order Deadlines JOINT MOTION FOR ENTRANCE OF MODIFIED SCHEDULING ORDER filed by International Business Machines Corporation. Signed by Judge Derek T. Gilliland. (zv) (Entered: 06/23/2023) (3)
Jun 22, 2023 185 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 IBMS MOTION TO COMPEL DISCOVERY REGARDING LZLABS CLEAN ROOM PROCESS AND DISCOVERY REQUEST PROCEDURES, # 3 DECLARATION OF ADAM STEINMETZ IN SUPPORT OF IBMS MOTION TO COMPEL DISCOVERY REGARDING LZLABS CLEAN ROOM PROCESS AND DISCOVERY REQUEST PROCEDURES, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G) (Zhu, Peter) (Entered: 06/22/2023) (0)
Jun 21, 2023 184 Sealed Motion filed: PLAINTIFF IBMS OPPOSITION TO LZLABS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRADE SECRETS. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H) (zv) (Entered: 06/21/2023) (0)
Jun 20, 2023 183 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 IBM's Opposition to LzLabs' Motion to Compel Re-Designation, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H) (Zhu, Peter) (Entered: 06/20/2023) (0)
Jun 15, 2023 182 Joint MOTION for Entry of Scheduling Order Deadlines JOINT MOTION FOR ENTRANCE OF MODIFIED SCHEDULING ORDER by International Business Machines Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Wilcox, Justin) (Entered: 06/15/2023) (0)
Jun 14, 2023 180 Sealed Order Granting 179 Unopposed Motion for leave to File Sealed Document. Signed by Judge David A. Ezra. (zv) (Entered: 06/14/2023) (0)
Jun 14, 2023 181 Sealed Motion filed: LZLABSS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANIS DECLARATION, (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY, AND (3) IBMS PRELIMINARY IDENTIFICATION OF TRADE SECRETS. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Order) (zv) (Entered: 06/14/2023) (0)
Jun 13, 2023 178 Unopposed MOTION for Leave to File UNDER SEAL ITS MOTION TO COMPEL PROTECTIVE ORDER RE-DESIGNATION OF (1) MARK ANZANI'S DECLARATION (2) IBM CORPORATE REPRESENTATIVE DEPOSITION TESTIMONY AND (3) IBM'S "PRELIMINARY IDENTIFICATION OF TRADE SECRETS" by LzLabs GmbH. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 06/13/2023) (0)
Jun 13, 2023 179 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Brief SEALED DOCUMENT, # 2 Exhibit SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Exhibit SEALED DOCUMENT, # 8 Exhibit SEALED DOCUMENT, # 9 Exhibit SEALED DOCUMENT, # 10 Exhibit SEALED DOCUMENT, # 11 Exhibit SEALED DOCUMENT, # 12 Proposed Order SEALED DOCUMENT, # 13 Proposed Order SEALED DOCUMENT) (Reynolds, Chris) (Entered: 06/13/2023) (0)
Jun 2, 2023 177 REPLY to Response to Motion, filed by International Business Machines Corporation, re 174 Unopposed Motion for leave to File Sealed Document filed by Defendant LzLabs GmbH Plaintiff IBMs Reply in support of its Cross-Motion for Summary Judgment on LzLabs Statute of Limitation Defense (Attachments: # 1 Appendix Declaration of Sumeet Dang in Support of IBM's Reply, # 2 Exhibit P)(Wilcox, Justin) (Entered: 06/02/2023) (0)
May 30, 2023 175 Sealed Order Granting 174 Unopposed Motion for leave to File Sealed Document. Signed by Judge David A. Ezra. (zv) (Entered: 05/30/2023) (0)
May 30, 2023 176 Sealed Document filed: DEFENDANTS REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT ON TRADE SECRETS CLAIMS DUE TO STATUTE OF LIMITATIONS 165 AND RESPONSE TO IBMS CROSS-MOTION FOR SUMMARY JUDGMENT 171 . (Attachments: # 1 Exhibit 12, # 2 Exhibit 13, # 3 Exhibit 14-1, # 4 Exhibit 15, # 5 Exhibit 16) (zv) (Entered: 05/30/2023) (0)
May 26, 2023 174 Unopposed Motion for leave to File Sealed Document (Attachments: # 1 Brief SEALED DOCUMENT, # 2 Exhibit SEALED DOCUMENT, # 3 Exhibit SEALED DOCUMENT, # 4 Exhibit SEALED DOCUMENT, # 5 Exhibit SEALED DOCUMENT, # 6 Exhibit SEALED DOCUMENT, # 7 Proposed Order) (Reynolds, Chris) (Entered: 05/26/2023) (0)
May 25, 2023 173 ORDER GRANTING 172 Joint Motion REGARDING RESPONSE FOR CROSS-MOTION FOR SUMMARY JUDGMENT AND REPLY IN SUPPORT OF DEFENDANTS' MOTION FOR SUMMARY JUDGMENT. Defendants must file their Combined Response and Reply by May 26, 2023, and IBM must file its reply in support of its Cross Motion by June 2, 2023. Signed by Judge David A. Ezra. (zv) (Entered: 05/25/2023) (1)
May 24, 2023 172 Joint MOTION REGARDING RESPONSE FOR CROSS-MOTION FOR SUMMARY JUDGMENT AND REPLY IN SUPPORT OF DEFENDANTS' MOTION FOR SUMMARY JUDGMENT re 165 Sealed Motion filed, 171 Sealed Motion filed by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 05/24/2023) (0)
May 22, 2023 170 Sealed Order GRANTING 169 PLAINTIFF IBMS UNOPPOSED MOTION TO FILE UNDER SEAL PLAINTIFF IBMS CROSS-MOTION FOR SUMMARY JUDGMENT ON LZLABS STATUTE OF LIMITATIONS DEFENSE AND OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT. Signed by Judge David A. Ezra. (zv) (Entered: 05/22/2023) (0)
May 22, 2023 171 Sealed Motion filed: PLAINTIFF IBMS CROSS-MOTION FOR SUMMARY JUDGMENT ON LZLABS STATUTE OF LIMITATIONS DEFENSE AND OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT re 165 . (Attachments: # 1 Appendix Declaration of S. Dang in Support of IBMs Opposition to Defendants Motion, # 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, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O) (zv) (Entered: 05/22/2023) (0)
May 19, 2023 169 Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 Brief IBMs Opposition to Defendants Motion for Summary Judgement and Cross Motion for Summary Judgment, # 3 Appendix Declaration of S. Dang in Support of IBMs Opposition to Defendants Motion for Summary Judgement and Cross Motion for Summary Judgment, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Exhibit O) (Dang, Sumeet) (Entered: 05/19/2023) (0)
May 12, 2023 168 Transcript filed of Proceedings held on 5/4/2023, Proceedings Transcribed: Discovery Hearing. Court Reporter/Transcriber: Dipti Patel, Telephone number: (847) 848-4907. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 6/2/2023, Redacted Transcript Deadline set for 6/12/2023, Release of Transcript Restriction set for 8/10/2023, (bc) (Entered: 05/15/2023) (35)
May 9, 2023 164 Sealed Order Granting 160 Motion for leave to File Sealed Document. Signed by Judge David A. Ezra. (zv) (Entered: 05/09/2023) (0)
May 9, 2023 165 Sealed Motion filed: DEFENDANTS MOTION FOR SUMMARY JUDGMENT. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11) (zv) (Entered: 05/09/2023) (0)
May 9, 2023 166 ATTACHMENT Proposed Order to 163 Joint MOTION For Entrance of Order Governing Electronic Discovery by International Business Machines Corporation. (Wilcox, Justin) (Entered: 05/09/2023) (1)
May 9, 2023 167 First Amended ANSWER re 16 to 1 Complaint, with Jury Demand by Texas Wormhole, LLC.(Reynolds, Chris) (Entered: 05/09/2023) (30)
May 8, 2023 161 ATTACHMENT Defendants' Amended Certificate of Service to 160 Motion for leave to File Sealed Document by LzLabs GmbH, Texas Wormhole, LLC. (Reynolds, Chris) (Entered: 05/08/2023) (2)
May 8, 2023 162 Transcript filed of Proceedings held on April 6, 2023, Proceedings Transcribed: Motions Hearing. Court Reporter/Transcriber: Lily I. Reznik, Telephone number: 512-391-8792 or Lily_Reznik@txwd.uscourts.gov. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 5/30/2023, Redacted Transcript Deadline set for 6/8/2023, Release of Transcript Restriction set for 8/7/2023, (lr) (Entered: 05/08/2023) (48)
May 8, 2023 163 Joint MOTION For Entrance of Order Governing Electronic Discovery by International Business Machines Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Wilcox, Justin) (Entered: 05/08/2023) (0)
May 5, 2023 158 TRANSCRIPT REQUEST by LzLabs GmbH for Motion to Compel proceedings held on 05/04/2023. Court Reporter: FTR. (Reynolds, Chris) (Entered: 05/05/2023) (2)
May 5, 2023 159 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on 05/04/2023. Proceedings Transcribed: Motion to Compel. Court Reporter: FTR. (Wilcox, Justin) (Entered: 05/05/2023) (1)
May 5, 2023 160 Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order Proposed Order Granting Motion to File Under Seal, # 2 Brief Defendants' Motion for Summary Judgment, # 3 Exhibit Exhibit 1 to MSJ, # 4 Exhibit Exhibit 2 to MSJ, # 5 Exhibit Exhibit 3 to MSJ, # 6 Exhibit Exhibit 4 to MSJ, # 7 Exhibit Exhibit 5 to MSJ, # 8 Exhibit Exhibit 6 to MSJ, # 9 Exhibit Exhibit 7 to MSJ, # 10 Exhibit Exhibit 8 to MSJ, # 11 Exhibit Exhibit 9 to MSJ, # 12 Exhibit Exhibit 10 to MSJ, # 13 Exhibit Exhibit 11 to MSJ) (Reynolds, Chris) (Entered: 05/05/2023) (0)
May 4, 2023 156 Minute Entry for proceedings held before Judge Derek T. Gilliland: Discovery Hearing held on 5/4/2023. Case called for a Discovery Hearing via Zoom. Parties announced ready. Statements and arguments of counsel heard. The requested discovery relief was ruled on based on the representations made by the the parties during the hearing. Parties are to email a jointly proposed order in word format to the Court's Law Clerk at Mariah_Karigan@txwd.uscourts.gov within seven (7) days of the date of this hearing. Written Discovery Order to follow. Hearing concluded. (Minute entry documents are not available electronically.) (Court Reporter FTR.)(zv) (Entered: 05/04/2023) (0)
May 4, 2023 157 ORDER GRANTING IN PART AND DENYING IN PART 150 Motion to Compel. Signed by Judge Derek T. Gilliland. (zv) (Entered: 05/04/2023) (2)
Apr 28, 2023 155 ORDER Setting Zoom Discovery for 5/4/2023 02:00 PM before Judge Derek T. Gilliland. Signed by Judge Derek T. Gilliland. (bot1) (Entered: 04/28/2023) (1)
Apr 27, 2023 154 REPLY to Response to Motion, filed by International Business Machines Corporation, re 150 MOTION to Compel filed by International Business Machines Corporation (Attachments: # 1 Appendix, # 2 Exhibit 6, # 3 Exhibit 7, # 4 Exhibit 8)(Wilcox, Justin) (Entered: 04/27/2023) (0)
Apr 20, 2023 153 RESPONSE to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 150 MOTION to Compel filed by International Business Machines Corporation (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B)(Reynolds, Chris) (Entered: 04/20/2023) (0)
Apr 17, 2023 152 Transcript filed of Proceedings held on March 6, 2023, Proceedings Transcribed: Motions Hearing. Court Reporter/Transcriber: Lily I. Reznik, Telephone number: 512-391-8792 or Lily_Reznik@txwd.uscourts.gov. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 5/8/2023, Redacted Transcript Deadline set for 5/18/2023, Release of Transcript Restriction set for 7/17/2023, (lr) (Entered: 04/17/2023) (19)
Apr 14, 2023 151 ORDER GRANTING IN PART AND DENYING IN PART 131 Motion to Compel. Signed by Judge Derek T. Gilliland. (zv) (Entered: 04/14/2023) (19)
Apr 13, 2023 149 Proposed Order to 131 MOTION to Compel Production of Documents by Texas Wormhole, LLC. (Sirkes, Adi) (Entered: 04/13/2023) (19)
Apr 13, 2023 150 MOTION to Compel by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Proposed Order)(Wilcox, Justin) (Entered: 04/13/2023) (0)
Apr 11, 2023 148 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on April 6, 2023. Proceedings Transcribed: LZLabs's Motion to Overrule IBM's Objections to Requests For Production and Compel Production of Documents. Court Reporter: Lily Reznik. (Wilcox, Justin) (Entered: 04/11/2023) (1)
Apr 6, 2023 146 Proposed Order (Amended Order) to 131 MOTION to Compel Production of Documents by Texas Wormhole, LLC. (Sirkes, Adi) (Entered: 04/06/2023) (15)
Apr 6, 2023 147 Minute Entry for proceedings held before Judge Derek T. Gilliland: Motion Hearing held on 4/6/2023 re 131 MOTION to Compel Production of Documents filed by LzLabs GmbH.Case called for a Motions Hearing via Zoom. Parties announced ready. Statements and arguments of counsel heard. Defendant's Motion to Overrule IBM's Objections to Requests for Production and Compel Production of Documents (Doc. 131) is GRANTED in Part and DENIED in Part. Parties are to jointly submit a proposed order to the Court's Law Clerk at Mariah_Karigan@txwd.uscourts.gov within seven (7) days from the date of this hearing. Written Order to follow. Hearing concluded. (Minute entry documents are not available electronically.) (Court Reporter Lily Reznik.)(zv) (Entered: 04/10/2023) (0)
Mar 29, 2023 145 NOTICE of Attorney Appearance by Charles Tait Graves on behalf of LzLabs GmbH, Texas Wormhole, LLC. Attorney Charles Tait Graves added to party LzLabs GmbH(pty:dft), Attorney Charles Tait Graves added to party Texas Wormhole, LLC(pty:dft) (Graves, Charles) (Entered: 03/29/2023) (2)
Mar 28, 2023 144 MOTION to Appear Pro Hac Vice by Adi Sirkes ( Filing fee $ 100 receipt number ATXWDC-17249261) by on behalf of Texas Wormhole, LLC. (Sirkes, Adi) (Entered: 03/28/2023) (5)
Mar 24, 2023 142 ORDER GRANTING 106 Motion to Dismiss. Terminated party International Business Machines Corporation and LzLabs GmbH. For the reasons stated in this Order, the Court GRANTS IBMs Motion to Dismiss Counterclaim. (Dkt. # 106.) Because LzLabs already had an opportunity to amend (see Dkt. # 80), the counterclaim for monopolization under the Sherman Act § 2 is DISMISSED WITHOUT PREJUDICE. Signed by Judge David A. Ezra. (zv) (Entered: 03/24/2023) (22)
Mar 24, 2023 143 ORDER SETTING MOTIONS HEARING VIA ZOOM on 131 MOTION to Compel Production of Documents : Motion Hearing set for 4/6/2023 03:00 PM before Judge Derek T. Gilliland. Signed by Judge Derek T. Gilliland. (ad3) (Entered: 03/24/2023) (1)
Mar 20, 2023 141 REPLY to Response to Motion, filed by LzLabs GmbH, re 131 MOTION to Compel Production of Documents filed by Defendant LzLabs GmbH (Attachments: # 1 Exhibit A)(Reynolds, Chris) (Entered: 03/20/2023) (0)
Mar 16, 2023 139 RESPONSE to Motion, filed by International Business Machines Corporation, re 137 MOTION for Hearing Status Conference filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC PLAINTIFF IBMS RESPONSE NOT OPPOSING DEFENDANTS MOTION FOR STATUS CONFERENCE (Wilcox, Justin) (Entered: 03/16/2023) (3)
Mar 16, 2023 140 MOTION to Appear Pro Hac Vice by Jeanne M. Heffernan on Behalf of Noah S. Frank ( Filing fee $ 100 receipt number ATXWDC-17208572) by on behalf of International Business Machines Corporation. (Heffernan, Jeanne) (Entered: 03/16/2023) (4)
Mar 14, 2023 137 MOTION for Hearing Status Conference by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 03/14/2023) (0)
Mar 14, 2023 138 NOTICE of Attorney Appearance by Jeanne M. Heffernan on behalf of International Business Machines Corporation. Attorney Jeanne M. Heffernan added to party International Business Machines Corporation(pty:cd), Attorney Jeanne M. Heffernan added to party International Business Machines Corporation(pty:pla) (Heffernan, Jeanne) (Entered: 03/14/2023) (3)
Mar 13, 2023 136 Response in Opposition to Motion, filed by International Business Machines Corporation, re 131 MOTION to Compel Production of Documents filed by Defendant LzLabs GmbH (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order)(Wilcox, Justin) (Entered: 03/13/2023) (0)
Mar 7, 2023 134 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on 03/06/2023. Proceedings Transcribed: LzLabs' MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep. Court Reporter: Lily Reznik. (Wilcox, Justin) (Entered: 03/07/2023) (1)
Mar 7, 2023 135 Proposed Order to 131 MOTION to Compel Production of Documents by LzLabs GmbH. (Reynolds, Chris) (Entered: 03/07/2023) (30)
Mar 6, 2023 131 MOTION to Compel Production of Documents by LzLabs GmbH. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6)(Reynolds, Chris) (Entered: 03/06/2023) (0)
Mar 6, 2023 132 Minute Entry for proceedings held before Judge Derek T. Gilliland: Motion Hearing held on 3/6/2023 re 124 MOTION filed by International Business Machines Corporation, 122 MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep filed by LzLabs GmbH. Case called for a Motions Hearing via Zoom. Parties announced ready. Statements and arguments of counsel heard. Defendant LZLabs GmBH's Motion to Compel the Rule 30(b)(6) Deposition of Plaintiff IBM's Corporate Representative on Trade Secret Issues (Doc. 122) is GRANTED. Plaintiff IBM's Cross-Motion Pursuant to Rule 26(c) for Protection Against Designating a Corporate Representative Pursuant to Defendants' Rule 30(b)(6) Notice of Deposition (Doc. 124) is DENIED. Written Order to follow. Hearing concluded. (Minute entry documents are not available electronically.) (Court Reporter Lily Reznik.)(zv) (Entered: 03/06/2023) (0)
Mar 6, 2023 133 ORDER GRANTING 122 Motion to Compel; DENYING 124 Motion Cross-Motion for Protection. Signed by Judge Derek T. Gilliland. (ad3) (Entered: 03/07/2023) (5)
Mar 3, 2023 130 REPLY to Response to Motion, filed by International Business Machines Corporation, re 122 MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep filed by Defendant LzLabs GmbH PLAINTIFF IBMS REPLY IN SUPPORT OF ITS CROSS-MOTION PURSUANT TO RULE 26(c) FOR PROTECTION AGAINST DESIGNATING A CORPORATE REPRESENTATIVE PURSUANT TO DEFENDANTS RULE 30(b)(6) NOTICE OF DEPOSITION (Wilcox, Justin) (Entered: 03/03/2023) (9)
Feb 27, 2023 128 ORDER GRANTING 126 Motion for Protective Order. Signed by Judge David A. Ezra. (zv) (Entered: 02/27/2023) (20)
Feb 27, 2023 129 ORDER Setting Zoom Motion Hearing for 3/6/2023 02:00 PM before Judge Derek T. Gilliland. Signed by Judge Derek T. Gilliland. (bot2) (Entered: 02/27/2023) (1)
Feb 24, 2023 126 Joint MOTION for Protective Order JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER by International Business Machines Corporation. (Attachments: # 1 Proposed Order - Stipulated Protective Order)(Dang, Sumeet) (Entered: 02/24/2023) (0)
Feb 24, 2023 127 REPLY to Response to Motion, filed by LzLabs GmbH, re 124 MOTION filed by International Business Machines Corporation, 122 MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep filed by Defendant LzLabs GmbH (Attachments: # 1 Exhibit A)(Reynolds, Chris) (Entered: 02/24/2023) (0)
Feb 21, 2023 125 REPLY to Response to Motion, filed by International Business Machines Corporation, re 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization filed by International Business Machines Corporation (Dang, Sumeet) (Entered: 02/21/2023) (17)
Feb 17, 2023 124 Motion: RESPONSE to Motion, filed by International Business Machines Corporation, re 122 MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep filed by Defendant LzLabs GmbH PLAINTIFF IBM RESPONSE IN OPPOSITION TO LZLABS MOTION TO COMPEL THE RULE 30(b)(6) DEPOSITION OF IBM CORPORATE REPRESENTATIVE ON TRADE SECRET ISSUES AND PLAINTIFF IBM CROSS-MOTION PURSUANT TO RULE 26(c) FOR PROTECTION AGAINST DESIGNATING A CORPORATE REPRESENTATIVE PURSUANT TO DEFENDANTS RULE 30(b)(6) NOTICE OF DEPOSITION (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Proposed Order)(Wilcox, Justin) Modified on 2/21/2023 due to incorrect event entry used. Per PSCRD, changed event entry to a Misc. Motion(zv). (Entered: 02/17/2023) (0)
Feb 10, 2023 122 MOTION to Compel The Rule 30(b)(6) Deposition of IBM's Corporate Rep by LzLabs GmbH. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Proposed Order)(Reynolds, Chris) (Entered: 02/10/2023) (0)
Feb 10, 2023 123 RESPONSE to Motion, filed by LzLabs GmbH, re 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization filed by International Business Machines Corporation (Reynolds, Chris) (Entered: 02/10/2023) (27)
Feb 7, 2023 121 ORDER GRANTING 120 Motion for Extension of Time to File Response/Reply re 120 Joint MOTION for Extension of Time to File Response/Reply as to 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization . Signed by Judge David A. Ezra. (zv) (Entered: 02/07/2023) (1)
Feb 6, 2023 120 Joint MOTION for Extension of Time to File Response/Reply as to 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 02/06/2023) (0)
Feb 3, 2023 119 Case reassigned to Judge David A. Ezra. Judge Alan D Albright no longer assigned to the case. CM WILL NOW REFLECT THE JUDGE INITIALS AS PART OF THE CASE NUMBER. PLEASE APPEND THESE JUDGE INITIALS TO THE CASE NUMBER ON EACH DOCUMENT THAT YOU FILE IN THIS CASE. (sm3) (sm3). (Entered: 02/03/2023) (1)
Feb 1, 2023 118 ORDER GRANTING 99 Motion to Disqualify Judge. It is therefore ORDERED AND ADJUDGED that: The Clerk of Court shall transfer this case to Honorable Robert Pitman of the U.S. District Court for the Western District of Texas for all further proceedings. Signed by Judge Alan D Albright. (zv) (Entered: 02/02/2023) (1)
Jan 31, 2023 116 NOTICE OF PROPOSED SCHEDULING MODIFICATIONS TO THE COURT'S SCHEDULING ORDER by International Business Machines Corporation (Wilcox, Justin) (Entered: 01/31/2023) (6)
Jan 31, 2023 117 NOTICE OF AGREED EXTENSION OF MOTIONS TO DISMISS RESPONSE AND REPLY DEADLINES by LzLabs GmbH, Texas Wormhole, LLC re 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization (Reynolds, Chris) (Entered: 01/31/2023) (2)
Jan 27, 2023 115 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on 01/26/2023. Proceedings Transcribed: Hearing on Defendants' Motion for Disqualification Under 28 U.S.C. § 455. Court Reporter: Kristie Davis. (Wilcox, Justin) (Entered: 01/27/2023) (1)
Jan 26, 2023 112 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 99 MOTION to Disqualify Judge filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Reynolds, Chris) (Entered: 01/26/2023) (15)
Jan 26, 2023 113 Transcript filed of Proceedings held on 1-26-23, Proceedings Transcribed: Motion Hearing. Court Reporter/Transcriber: Kristie Davis (kmdaviscsr@yahoo.com), Telephone number: 12546660904. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 2/16/2023, Redacted Transcript Deadline set for 2/27/2023, Release of Transcript Restriction set for 4/26/2023, (kd) (Entered: 01/26/2023) (66)
Jan 26, 2023 114 Minute Entry for proceedings held before Judge Alan D Albright: Motions Hearing held on 1/26/2023. Parties announce ready. Statements and arguments of counsel heard. Motion taken under advisement. Written Order will be forthcoming. (Minute entry documents are not available electronically.) (Court Reporter Kristie Davis.)(sm3) (Entered: 01/27/2023) (0)
Jan 25, 2023 107 ORDER GRANTING 102 Motion to Appear Pro Hac Vice for Attorney Danielle Rosenthal. Attorney added for LzLabs GmbH, Texas Wormhole, LLC. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 01/25/2023) (1)
Jan 25, 2023 108 ORDER GRANTING 103 Motion to Appear Pro Hac Vice for Attorney Scott E. Miller. Attorney added for LzLabs GmbH, Texas Wormhole, LLC. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 01/25/2023) (1)
Jan 25, 2023 109 ORDER GRANTING 104 Motion to Appear Pro Hac Vice for Attorney Nicholas Groombridge. Attorney added for LzLabs GmbH, Texas Wormhole, LLC. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 01/25/2023) (1)
Jan 25, 2023 110 ORDER GRANTING 105 Motion to Appear Pro Hac Vice for Attorney Jennifer H. Wu. Attorney added for LzLabs GmbH, Texas Wormhole, LLC. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 01/25/2023) (1)
Jan 25, 2023 111 Response in Opposition to Motion, filed by International Business Machines Corporation, re 99 MOTION to Disqualify Judge filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Declaration of Adam Steinmetz, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Proposed Order)(Wilcox, Justin) (Entered: 01/25/2023) (0)
Jan 24, 2023 106 MOTION to Dismiss Defendant LzLabs GMBH's Amended Counterclaim for Monopolization by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Wilcox, Justin) (Entered: 01/24/2023) (0)
Jan 23, 2023 102 MOTION to Appear Pro Hac Vice by Chris Reynolds on behalf of Danielle Rosenthal ( Filing fee $ 100 receipt number ATXWDC-16992301) by on behalf of LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 01/23/2023) (0)
Jan 23, 2023 103 MOTION to Appear Pro Hac Vice by Chris Reynolds on behalf of Scott E. Miller ( Filing fee $ 100 receipt number ATXWDC-16992358) by on behalf of LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 01/23/2023) (0)
Jan 23, 2023 104 MOTION to Appear Pro Hac Vice by Chris Reynolds on behalf of Nicholas Groombridge ( Filing fee $ 100 receipt number ATXWDC-16992388) by on behalf of LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 01/23/2023) (0)
Jan 23, 2023 105 MOTION to Appear Pro Hac Vice by Chris Reynolds on behalf of Jennifer H. Wu ( Filing fee $ 100 receipt number ATXWDC-16992416) by on behalf of LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 01/23/2023) (0)
Jan 20, 2023 101 ORDER RESETTING Zoom Motion Hearing for 1/26/2023 01:30 PM before Judge Alan D Albright. Signed by Judge Alan D Albright. (bot1) (Entered: 01/20/2023) (1)
Jan 18, 2023 100 ORDER Setting Zoom Motion Hearing for 2/2/2023 01:30 PM before Judge Alan D Albright. Signed by Judge Alan D Albright. (bot1) (Entered: 01/18/2023) (1)
Jan 17, 2023 98 ORDER GRANTING 97 Motion to Appear Pro Hac Vice for Attorney Peter Zhu. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 01/17/2023) (1)
Jan 17, 2023 99 MOTION to Disqualify Judge by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Reynolds, Chris) (Entered: 01/17/2023) (0)
Jan 13, 2023 97 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Peter Y. Zhu) ( Filing fee $ 100 receipt number ATXWDC-16962667) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 01/13/2023) (0)
Jan 10, 2023 96 REPLY to Response to Motion, filed by International Business Machines Corporation, re 68 MOTION to Dismiss Defendant LzLabs GMBH's Counterclaim for Monopolization filed by International Business Machines Corporation (Wilcox, Justin) (Entered: 01/10/2023) (11)
Jan 9, 2023 95 ORDER DENYING 23 Motion for Protective Order/Motion to Compel. Signed by Judge Alan D Albright. (zv) (Entered: 01/09/2023) (7)
Jan 8, 2023 94 Transcript filed of Proceedings held on 1-5-23, Proceedings Transcribed: Markman Hearing. Court Reporter/Transcriber: Kristie Davis (kmdaviscsr@yahoo.com), Telephone number: 2546660904. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 1/30/2023, Redacted Transcript Deadline set for 2/8/2023, Release of Transcript Restriction set for 4/10/2023, (kd) (Entered: 01/08/2023) (43)
Jan 6, 2023 92 TRANSCRIPT REQUEST by LzLabs GmbH, Texas Wormhole, LLC for proceedings held on 01/05/2023. Proceedings Transcribed: Markman Hearing. Court Reporter Kristie Davis. (Reynolds, Chris) (Entered: 01/06/2023) (1)
Jan 6, 2023 93 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on 01/05/2023. Proceedings Transcribed: Markman Hearing. Court Reporter: Kristie Davis. (Wilcox, Justin) (Entered: 01/06/2023) (1)
Jan 5, 2023 86 ORDER DENYING 15 Motion to Dismiss. Signed by Judge Alan D Albright. (ad3) (Entered: 01/05/2023) (7)
Jan 5, 2023 87 ORDER DENYING 41 Motion to Dismiss. Signed by Judge Alan D Albright. (ad3) (Entered: 01/05/2023) (5)
Jan 5, 2023 88 ORDER DENYING 14 Motion to Strike 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g), 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims ; DENYING 15 Motion to Strike 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g), 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims Signed by Judge Alan D Albright. (ad3) (Entered: 01/05/2023) (6)
Jan 5, 2023 89 Minute Entry for proceedings held before Judge Alan D Albright: Markman Hearing held on 1/5/2023. PARTIES ANNOUNCE READY. STATEMENTS AND ARGUMENTS OF COUNSEL HEARD - The Court declares all discovery is open beginning today. WRITTEN ORDER FORTHCOMING. (Minute entry documents are not available electronically.) (Court Reporter Kristie Davis.)(zv) (Entered: 01/05/2023) (0)
Jan 5, 2023 90 CLAIM CONSTRUCTION ORDER AND MEMORANDUM IN SUPPORT THEREOF. Signed by Judge Alan D Albright. (zv) (Entered: 01/06/2023) (30)
Jan 5, 2023 91 ORDER TO PAY TECHNICAL ADVISOR. Signed by Judge Alan D Albright. (zv) (Entered: 01/06/2023) (1)
Jan 4, 2023 85 NOTICE of Attorney Appearance by Joseph Daniel Gray on behalf of LzLabs GmbH, Texas Wormhole, LLC. Attorney Joseph Daniel Gray added to party LzLabs GmbH(pty:cc), Attorney Joseph Daniel Gray added to party LzLabs GmbH(pty:dft), Attorney Joseph Daniel Gray added to party Texas Wormhole, LLC(pty:dft) (Gray, Joseph) (Entered: 01/04/2023) (1)
Dec 29, 2022 84 NOTICE of Petition for Inter Partes Review by International Business Machines Corporation (Wilcox, Justin) (Entered: 12/29/2022) (3)
Dec 27, 2022 83 NOTICE of Agreed Extension of time To Respond to Lzlabs GMBH's First Amended Answer, Affirmative Defenses, and Counterclaim by International Business Machines Corporation re 80 Answer to Complaint, Counterclaim (Wilcox, Justin) (Entered: 12/27/2022) (4)
Dec 23, 2022 82 Joint MOTION for Extension of Time to File Response/Reply as to 80 Answer to Complaint, Counterclaim by International Business Machines Corporation. (Wilcox, Justin) (Entered: 12/23/2022) (4)
Dec 20, 2022 80 FIRST AMENDED ANSWER to 1 Complaint, FIRST AMENDED, COUNTERCLAIM against International Business Machines Corporation by LzLabs GmbH. (Attachments: # 1 Exhibit 1)(Reynolds, Chris) (Entered: 12/20/2022) (0)
Dec 20, 2022 81 RESPONSE to Motion, filed by LzLabs GmbH, re 68 MOTION to Dismiss Defendant LzLabs GMBH's Counterclaim for Monopolization filed by International Business Machines Corporation (Attachments: # 1 Proposed Order, # 2 Proposed Order)(Reynolds, Chris) (Entered: 12/20/2022) (0)
Dec 16, 2022 76 NOTICE of Attorney Appearance by Chris Reynolds on behalf of LzLabs GmbH, Texas Wormhole, LLC (Reynolds, Chris) (Entered: 12/16/2022) (2)
Dec 16, 2022 77 NOTICE of Attorney Appearance by Chris Reynolds on behalf of LzLabs GmbH, Texas Wormhole, LLC (Reynolds, Chris) (Entered: 12/16/2022) (2)
Dec 16, 2022 78 Unopposed MOTION to Withdraw as Attorney by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 12/16/2022) (0)
Dec 16, 2022 79 ORDER GRANTING 75 Motion to Appear Pro Hac Vice for Attorney Keshav Dimri. Attorney added for LzLabs GmbH, Texas Wormhole, LLC. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot2) (Entered: 12/16/2022) (1)
Dec 15, 2022 75 MOTION to Appear Pro Hac Vice by Chris Reynolds ( Filing fee $ 100 receipt number ATXWDC-16869400) by on behalf of LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Proposed Order)(Reynolds, Chris) (Entered: 12/15/2022) (0)
Nov 30, 2022 72 NOTICE OF AGREED EXTENSION OF OPTIONAL TUTORIAL DEADLINE by LzLabs GmbH, Texas Wormhole, LLC (Reynolds, Chris) (Entered: 11/30/2022) (3)
Nov 30, 2022 73 Joint Claim Construction Brief or Statement by International Business Machines Corporation. (Dacus, Deron) (Entered: 11/30/2022) (5)
Nov 29, 2022 71 ORDER RESETTING MARKMAN HEARING. Markman Hearing reset for 1/5/2023 01:30 PM before Judge Alan D Albright. Signed by Judge Alan D Albright. (zv) (Entered: 11/29/2022) (1)
Nov 29, 2022 74 ORDER APPOINTING TECHNICAL ADVISOR. Signed by Judge Alan D Albright. (zv) (Entered: 12/02/2022) (3)
Nov 23, 2022 70 BRIEF Surreply Claim Construction Brief regarding 67 Brief, by International Business Machines Corporation. (Wilcox, Justin) (Entered: 11/23/2022) (20)
Nov 21, 2022 69 ORDER Setting Zoom Markman Hearing for 12/15/2022 03:00 PM before Judge Alan D Albright. Signed by Judge Alan D Albright. (bot1) (Entered: 11/21/2022) (1)
Nov 18, 2022 68 MOTION to Dismiss Defendant LzLabs GMBH's Counterclaim for Monopolization by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Wilcox, Justin) (Entered: 11/18/2022) (Main Document) (29)
Nov 18, 2022 68 MOTION to Dismiss Defendant LzLabs GMBH's Counterclaim for Monopolization by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Wilcox, Justin) (Entered: 11/18/2022) (Proposed Order) (1)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Main Document) (20)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Appendix) (1)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Exhibit A) (5)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Exhibit B) (4)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Exhibit C) (26)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Exhibit D) (3)
Nov 9, 2022 67 BRIEF Reply Claim Construction Brief regarding 52 Opening Claim Construction Brief and 65 Response by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reynolds, Chris) Modified on 11/10/2022 (lad). (Entered: 11/09/2022) (Exhibit E) (30)
Oct 27, 2022 66 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit A)(Reynolds, Chris) (Entered: 10/27/2022) (Main Document) (14)
Oct 27, 2022 66 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit A)(Reynolds, Chris) (Entered: 10/27/2022) (Exhibit A) (4)
Oct 26, 2022 64 Reply Claim Construction Brief regarding 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) Modified on 10/27/2022. Plaintiff's counsel informed Clerk's Office that this Reply was filed in error. Refiled as a Response 65 (zv). (Entered: 10/26/2022) (Main Document) (29)
Oct 26, 2022 65 RESPONSE Responsive Claim Construction Brief to 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) (Entered: 10/26/2022) (Main Document) (29)
Oct 26, 2022 64 Reply Claim Construction Brief regarding 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) Modified on 10/27/2022. Plaintiff's counsel informed Clerk's Office that this Reply was filed in error. Refiled as a Response 65 (zv). (Entered: 10/26/2022) (Appendix) (1)
Oct 26, 2022 64 Reply Claim Construction Brief regarding 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) Modified on 10/27/2022. Plaintiff's counsel informed Clerk's Office that this Reply was filed in error. Refiled as a Response 65 (zv). (Entered: 10/26/2022) (Exhibit 1) (4)
Oct 26, 2022 64 Reply Claim Construction Brief regarding 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) Modified on 10/27/2022. Plaintiff's counsel informed Clerk's Office that this Reply was filed in error. Refiled as a Response 65 (zv). (Entered: 10/26/2022) (Exhibit 2) (4)
Oct 26, 2022 65 RESPONSE Responsive Claim Construction Brief to 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) (Entered: 10/26/2022) (Appendix) (1)
Oct 26, 2022 65 RESPONSE Responsive Claim Construction Brief to 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) (Entered: 10/26/2022) (Exhibit 1) (4)
Oct 26, 2022 65 RESPONSE Responsive Claim Construction Brief to 52 Claim Construction Brief by International Business Machines Corporation. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Dacus, Deron) (Entered: 10/26/2022) (Exhibit 2) (4)
Oct 24, 2022 63 NOTICE of Petition for Inter Partes Review by International Business Machines Corporation (Dacus, Deron) (Entered: 10/24/2022) (3)
Oct 21, 2022 N/A Text Order MOOTING 57 Motion for Extension of Time to Answer re 57 MOTION for Extension of Time to File Answer re 42 Answer to Complaint, Counterclaim entered by Judge Alan D Albright. In view of the parties' Joint Notice 60 and Notice of Withdrawal 62 , the Court hereby finds that this Motion is MOOT. (This is a text-only entry generated by the court. There is no document associated with this entry.) (NMlc) (Entered: 10/21/2022) (0)
Oct 20, 2022 62 NOTICE of Withdrawal of IBM's Opposed Motion to Extend Time to Respond to LZLabs' Answer, Affirmative Defenses, and Counterclaim by International Business Machines Corporation re 57 MOTION for Extension of Time to File Answer re 42 Answer to Complaint, Counterclaim (Dacus, Deron) (Entered: 10/20/2022) (3)
Oct 18, 2022 60 NOTICE Joint Notice of Agreed Extension of Counterclaim Response Deadlines and Agreed Modification of Fact Discovery Period by International Business Machines Corporation re 26 Order on Motion for Entry of Scheduling Order, 42 Answer to Complaint, Counterclaim (Dacus, Deron) (Entered: 10/18/2022) (5)
Oct 18, 2022 N/A Reset Deadlines: International Business Machines Corporation answer due 11/18/2022. (zv) (Entered: 10/18/2022) (0)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Main Document) (28)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Appendix) (1)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Exhibit 1) (30)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Exhibit 2) (6)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Exhibit 3) (5)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Exhibit 4) (3)
Oct 18, 2022 61 Response in Opposition to Motion, filed by International Business Machines Corporation, re 41 MOTION to Dismiss Based on Forum Non Conveniens filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Proposed Order)(Dacus, Deron) (Entered: 10/18/2022) (Proposed Order) (1)
Oct 14, 2022 N/A Text Order GRANTING 59 Motion to Withdraw as Attorney. It is ORDERED that Alexander Rudis, John T. McKee, David A. Nelson and Nina Susan Tallon are WITHDRAWN as counsel for Plaintiff. It is further ORDERED that the docket be amended to reflect that Alexander Rudis, John T. McKee, David A. Nelson and Nina Susan Tallon are withdrawn as counsel for Plaintiff and no longer need to be noticed of any pleadings, motions, or other documents filed or served in this case. Entered by Judge Alan D Albright. (This is a text-only entry generated by the court. There is no document associated with this entry.) (RJlc) (Entered: 10/14/2022) (0)
Oct 13, 2022 59 Unopposed MOTION to Withdraw as Attorney by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/13/2022) (Main Document) (3)
Oct 13, 2022 59 Unopposed MOTION to Withdraw as Attorney by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/13/2022) (Proposed Order) (1)
Oct 12, 2022 56 ORDER GRANTING 55 Motion to Appear Pro Hac Vice for Attorney Sumeet Dang. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot2) (Entered: 10/12/2022) (1)
Oct 12, 2022 57 Opposed MOTION for Extension of Time to File Answer re 42 Answer to Complaint, Counterclaim by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) Modified on 10/13/2022 (lad). (Entered: 10/12/2022) (Main Document) (4)
Oct 12, 2022 57 Opposed MOTION for Extension of Time to File Answer re 42 Answer to Complaint, Counterclaim by International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) Modified on 10/13/2022 (lad). (Entered: 10/12/2022) (Proposed Order) (1)
Oct 11, 2022 55 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Sumeet Dang) ( Filing fee $ 100 receipt number ATXWDC-16620602) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/11/2022) (Main Document) (4)
Oct 11, 2022 55 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Sumeet Dang) ( Filing fee $ 100 receipt number ATXWDC-16620602) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/11/2022) (Proposed Order) (1)
Oct 10, 2022 54 NOTICE of Agreed Extensions of time To Respond and Reply to Defendants' Motion to Dismiss Based on Forum Non Conveniens by International Business Machines Corporation re 41 MOTION to Dismiss Based on Forum Non Conveniens (Dacus, Deron) (Entered: 10/10/2022) (4)
Oct 7, 2022 53 ORDER GRANTING 47 Motion to Appear Pro Hac Vice for Attorney Steven M. Balcof for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center Signed by Judge Alan D Albright. (bw) (Entered: 10/07/2022) (1)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Main Document) (30)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Appendix) (1)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit A) (30)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit B) (8)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit C) (19)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit D) (8)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit E) (30)
Oct 5, 2022 52 Opening Claim Construction Brief by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Appendix, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Reynolds, Chris) (Entered: 10/05/2022) (Exhibit F) (30)
Oct 4, 2022 47 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Steven M. Balcof) ( Filing fee $ 100 receipt number ATXWDC-16596256) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/04/2022) (Main Document) (4)
Oct 4, 2022 48 ORDER GRANTING 43 Motion to Appear Pro Hac Vice for Attorney John M. Desmarais. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 10/04/2022) (1)
Oct 4, 2022 49 ORDER GRANTING 44 Motion to Appear Pro Hac Vice for Attorney Adam Steinmetz. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 10/04/2022) (1)
Oct 4, 2022 50 ORDER GRANTING 46 Motion to Appear Pro Hac Vice for Attorney Jordan Owens. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 10/04/2022) (1)
Oct 4, 2022 51 ORDER GRANTING 45 Motion to Appear Pro Hac Vice for Attorney Justin P.D. Wilcox for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (zv) (Entered: 10/04/2022) (1)
Oct 4, 2022 47 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Steven M. Balcof) ( Filing fee $ 100 receipt number ATXWDC-16596256) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/04/2022) (Proposed Order) (1)
Oct 3, 2022 43 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of John M. Desmarais) ( Filing fee $ 100 receipt number ATXWDC-16591992) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Main Document) (5)
Oct 3, 2022 44 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Adam Steinmetz) ( Filing fee $ 100 receipt number ATXWDC-16592010) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Main Document) (4)
Oct 3, 2022 45 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Justin P.D. Wilcox) ( Filing fee $ 100 receipt number ATXWDC-16592019) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Main Document) (4)
Oct 3, 2022 46 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Jordan Owens) ( Filing fee $ 100 receipt number ATXWDC-16592935) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Main Document) (4)
Oct 3, 2022 43 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of John M. Desmarais) ( Filing fee $ 100 receipt number ATXWDC-16591992) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Proposed Order) (1)
Oct 3, 2022 45 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Justin P.D. Wilcox) ( Filing fee $ 100 receipt number ATXWDC-16592019) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Proposed Order) (1)
Oct 3, 2022 44 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Adam Steinmetz) ( Filing fee $ 100 receipt number ATXWDC-16592010) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Proposed Order) (1)
Oct 3, 2022 46 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Jordan Owens) ( Filing fee $ 100 receipt number ATXWDC-16592935) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 10/03/2022) (Proposed Order) (1)
Sep 30, 2022 42 ANSWER to 1 Complaint, , COUNTERCLAIM against International Business Machines Corporation by LzLabs GmbH. (Attachments: # 1 Exhibit 1)(Reynolds, Chris) (Entered: 09/30/2022) (Main Document) (30)
Sep 30, 2022 42 ANSWER to 1 Complaint, , COUNTERCLAIM against International Business Machines Corporation by LzLabs GmbH. (Attachments: # 1 Exhibit 1)(Reynolds, Chris) (Entered: 09/30/2022) (Exhibit 1) (26)
Sep 29, 2022 41 MOTION to Dismiss Based on Forum Non Conveniens by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Proposed Order)(Reynolds, Chris) (Entered: 09/29/2022) (Main Document) (12)
Sep 29, 2022 41 MOTION to Dismiss Based on Forum Non Conveniens by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Proposed Order)(Reynolds, Chris) (Entered: 09/29/2022) (Exhibit A) (25)
Sep 29, 2022 41 MOTION to Dismiss Based on Forum Non Conveniens by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Proposed Order)(Reynolds, Chris) (Entered: 09/29/2022) (Exhibit B) (30)
Sep 29, 2022 41 MOTION to Dismiss Based on Forum Non Conveniens by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Proposed Order)(Reynolds, Chris) (Entered: 09/29/2022) (Proposed Order) (1)
Sep 16, 2022 N/A Parties shall comply with Judge Albright's updated standing orders available by clicking the included hyperlinks. The updated orders are as follows:1. Standing Order Governing Proceedings Patent Cases,2. Amended Standing Order On Pretrial Procedures and Requirements in Civil Cases. (bot4) (Entered: 09/17/2022) (0)
Aug 29, 2022 40 Transcript filed of Proceedings held on August 25, 2022, Proceedings Transcribed: Discovery Hearing Via Zoom Teleconference. Court Reporter/Transcriber: Dipti Patel - Liberty Transcripts, Telephone number: (847) 848-4907. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 9/19/2022, Redacted Transcript Deadline set for 9/29/2022, Release of Transcript Restriction set for 11/28/2022, (tr) (Entered: 08/29/2022) (11)
Aug 26, 2022 37 ORDER. Plaintiffs request for production oftechnical documents is DENIED. Signed by Judge Derek T. Gilliland. (sv) (Entered: 08/26/2022) (1)
Aug 26, 2022 38 TRANSCRIPT REQUEST by International Business Machines Corporation for proceedings held on August 25, 2022. Proceedings Transcribed: Discovery Hearing.. (Nelson, David) (Entered: 08/26/2022) (2)
Aug 26, 2022 39 ORDER GRANTING 35 Motion to Appear Pro Hac Vice for Attorney Nina S. Tallon. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot1) (Entered: 08/26/2022) (1)
Aug 25, 2022 36 Minute Entry for proceedings held before Judge Derek T. Gilliland: Discovery Hearing held on 8/25/2022. Case called for Discovery Hearing via Zoom. Parties announced ready. Statements and arguments ofcounsel heard. Written Order to follow. Hearing concluded. (Minute entry documents are not available electronically). (Court Reporter FTR.)(sv) (Entered: 08/25/2022) (0)
Aug 24, 2022 33 ORDER Setting Zoom Discovery for 8/25/2022 04:00 PM before Judge Derek T. Gilliland. Signed by Judge Derek T. Gilliland. (bot2) (Entered: 08/24/2022) (1)
Aug 24, 2022 34 ORDER of Limited Referral: discovery hearing in this case. Signed by Judge Alan D Albright. (sv) (Entered: 08/24/2022) (1)
Aug 24, 2022 35 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Nina S. Tallon) ( Filing fee $ 100 receipt number ATXWDC-16444330) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 08/24/2022) (Main Document) (3)
Aug 24, 2022 35 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Nina S. Tallon) ( Filing fee $ 100 receipt number ATXWDC-16444330) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 08/24/2022) (Proposed Order) (1)
Aug 23, 2022 31 ORDER GRANTING 30 Motion to Appear Pro Hac Vice for Attorney John T. McKee. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Registration is managed by the PACER Service Center. Signed by Judge Alan D Albright. (bot2) (Entered: 08/23/2022) (1)
Aug 23, 2022 32 NOTICE OF WITHDRAWAL OF RULE 12(b)(2) MOTION, AND NOTICE OF AGREED ANSWER DEADLINE by LzLabs GmbH re 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) (Reynolds, Chris) (Entered: 08/23/2022) (3)
Aug 19, 2022 30 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of John Thomas McKee) ( Filing fee $ 100 receipt number ATXWDC-16424642) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 08/19/2022) (Main Document) (3)
Aug 19, 2022 30 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of John Thomas McKee) ( Filing fee $ 100 receipt number ATXWDC-16424642) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 08/19/2022) (Proposed Order) (1)
Aug 8, 2022 29 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 23 MOTION for Protective Order MOTION to Compel Pre-Discovery Identification of Trade Secrets filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Reynolds, Chris) (Entered: 08/08/2022) (8)
Aug 3, 2022 28 NOTICE OF AGREED EXTENSION OF JURISDICTIONAL DISCOVERY DEADLINE by LzLabs GmbH, Texas Wormhole, LLC (Reynolds, Chris) (Entered: 08/03/2022) (3)
Aug 1, 2022 27 Response in Opposition to Motion, filed by International Business Machines Corporation, re 23 MOTION for Protective Order MOTION to Compel Pre-Discovery Identification of Trade Secrets filed by Defendant LzLabs GmbH, Defendant Texas Wormhole, LLC (Nelson, David) (Entered: 08/01/2022) (15)
Jul 25, 2022 26 ORDER GRANTING 25 Motion for Entry of Scheduling Order Markman Hearing set for 12/13/2022 before Judge Alan D Albright, Joinder of Parties due by 1/24/2023, Amended Pleadings due by 4/4/2023, Dispositive Motions due by 9/20/2023 Signed by Judge Alan D Albright. (sv) (Entered: 07/25/2022) (4)
Jul 21, 2022 24 NOTICE of Agreed Extension of Time to Respond to Defendants' Motion for Protective Order and to Compel Pre-Discovery Identification of Trade Secrets by International Business Machines Corporation (Rudis, Alexander) (Entered: 07/21/2022) (4)
Jul 21, 2022 25 Joint MOTION for Entry of Scheduling Order Deadlines by International Business Machines Corporation. (Attachments: # 1 Appendix A - Proposed Scheduling Order)(Rudis, Alexander) (Entered: 07/21/2022) (Main Document) (3)
Jul 21, 2022 25 Joint MOTION for Entry of Scheduling Order Deadlines by International Business Machines Corporation. (Attachments: # 1 Appendix A - Proposed Scheduling Order)(Rudis, Alexander) (Entered: 07/21/2022) (Appendix A - Proposed Scheduling Order) (5)
Jul 15, 2022 23 MOTION for Protective Order , MOTION to Compel Pre-Discovery Identification of Trade Secrets by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit 1, # 2 Proposed Order)(Reynolds, Chris) (Entered: 07/15/2022) (Main Document) (13)
Jul 15, 2022 23 MOTION for Protective Order , MOTION to Compel Pre-Discovery Identification of Trade Secrets by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit 1, # 2 Proposed Order)(Reynolds, Chris) (Entered: 07/15/2022) (Exhibit 1) (26)
Jul 15, 2022 23 MOTION for Protective Order , MOTION to Compel Pre-Discovery Identification of Trade Secrets by LzLabs GmbH, Texas Wormhole, LLC. (Attachments: # 1 Exhibit 1, # 2 Proposed Order)(Reynolds, Chris) (Entered: 07/15/2022) (Proposed Order) (2)
Jul 14, 2022 22 Joint MOTION for Entry of Scheduling Order Deadlines by International Business Machines Corporation. (Attachments: # 1 Appendix A - Proposed Scheduling Order)(Nelson, David) (Entered: 07/14/2022) (Main Document) (3)
Jul 14, 2022 22 Joint MOTION for Entry of Scheduling Order Deadlines by International Business Machines Corporation. (Attachments: # 1 Appendix A - Proposed Scheduling Order)(Nelson, David) (Entered: 07/14/2022) (Appendix A - Proposed Scheduling Order) (5)
Jul 12, 2022 21 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Reynolds, Chris) (Entered: 07/12/2022) (Main Document) (13)
Jul 12, 2022 21 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Reynolds, Chris) (Entered: 07/12/2022) (Exhibit 1) (10)
Jul 12, 2022 21 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Reynolds, Chris) (Entered: 07/12/2022) (Exhibit 2) (4)
Jul 12, 2022 21 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Reynolds, Chris) (Entered: 07/12/2022) (Exhibit 3) (30)
Jul 12, 2022 21 REPLY to Response to Motion, filed by LzLabs GmbH, Texas Wormhole, LLC, re 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Reynolds, Chris) (Entered: 07/12/2022) (Exhibit 4) (30)
Jun 30, 2022 20 Response in Opposition to Motion, filed by International Business Machines Corporation, re 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) filed by Defendant LzLabs GmbH, 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Dacus, Deron) (Entered: 06/30/2022) (Main Document) (24)
Jun 30, 2022 20 Response in Opposition to Motion, filed by International Business Machines Corporation, re 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) filed by Defendant LzLabs GmbH, 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Dacus, Deron) (Entered: 06/30/2022) (Exhibit 1) (2)
Jun 30, 2022 20 Response in Opposition to Motion, filed by International Business Machines Corporation, re 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2) MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) filed by Defendant LzLabs GmbH, 15 MOTION to Strike Pursuant to Rule 12(f) MOTION to Dismiss Indirect and Willful Infringement Claims filed by Defendant Texas Wormhole, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Dacus, Deron) (Entered: 06/30/2022) (Exhibit 2) (15)
Jun 23, 2022 18 NOTICE of Intent to Proceed with Jurisdictional Discovery by International Business Machines Corporation (Nelson, David) (Entered: 06/23/2022) (3)
Jun 23, 2022 19 NOTICE for Unopposed Extensions of Time to Respond and Reply to Defendants' Motions to Strike and Motion to Dismiss by International Business Machines Corporation (Nelson, David) (Entered: 06/23/2022) (4)
Jun 16, 2022 17 NOTICE of Case Readiness Status Report by International Business Machines Corporation (Dacus, Deron) (Entered: 06/16/2022) (4)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Main Document) (24)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Main Document) (12)
Jun 9, 2022 16 ANSWER to 1 Complaint, by Texas Wormhole, LLC.(Reynolds, Chris) (Entered: 06/09/2022) (30)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit A) (30)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit B) (30)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit C) (16)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit D) (3)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Proposed Order on Motion to Strike) (1)
Jun 9, 2022 15 MOTION to Strike Pursuant to Rule 12(f), MOTION to Dismiss Indirect and Willful Infringement Claims by Texas Wormhole, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Proposed Order on Motion to Strike, # 6 Proposed Order on Motion to Dismiss)(Reynolds, Chris) (Entered: 06/09/2022) (Proposed Order on Motion to Dismiss) (1)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Affidavit Rockmann Declaration) (6)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit 1 to Declaration) (20)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit 2 to Declaration) (25)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit 3 to Declaration) (30)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit 4 to Declaration) (3)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit A) (30)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit B) (30)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Exhibit C) (16)
Jun 9, 2022 14 MOTION to Dismiss for Lack of Jurisdiction Pursuant to Federal Rule of Civil Procedure 12(b)(2), MOTION to Strike Pursuant to Federal Rule of Civil Procedure 12(g) by LzLabs GmbH. (Attachments: # 1 Affidavit Rockmann Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Proposed Order)(Reynolds, Chris) (Entered: 06/09/2022) (Proposed Order) (1)
Apr 28, 2022 13 NOTICE Agreed Notice of Extension of Time to Respond to Complaint by LzLabs GmbH re 1 Complaint, (Smith, Nathan) (Entered: 04/28/2022) (2)
Apr 28, 2022 N/A Reset Deadlines: LzLabs GmbH answer due 6/9/2022. (sv) (Entered: 04/28/2022) (0)
Apr 15, 2022 12 NOTICE of 45-Day Extension of Time to Respond to Complaint (Agreed) by LzLabs GmbH, Texas Wormhole, LLC re 1 Complaint, (Reynolds, Chris) (Entered: 04/15/2022) (2)
Apr 15, 2022 N/A Reset Deadlines: Texas Wormhole, LLC answer due 6/9/2022. (sv) (Entered: 04/18/2022) (0)
Apr 14, 2022 10 SUMMONS Returned Executed by International Business Machines Corporation. Texas Wormhole, LLC served on 4/2/2022, answer due 4/25/2022. (Dacus, Deron) (Entered: 04/14/2022) (4)
Apr 14, 2022 11 Standing Order Regarding Order Governing Proceedings Patent Cases. Signed by Judge Alan D Albright. (Entered: 04/14/2022) (18)
Mar 23, 2022 9 ORDER GRANTING 8 Motion to Appear Pro Hac Vice for Attorney Alexander Rudis. Attorney added for International Business Machines Corporation. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order, if he/she has not previously done so for a prior case in this District. Signed by Judge Alan D Albright. (bot3) (Entered: 03/23/2022) (1)
Mar 22, 2022 8 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Alexander Rudis) ( Filing fee $ 100 receipt number 0542-15839235) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 03/22/2022) (Main Document) (3)
Mar 22, 2022 8 MOTION to Appear Pro Hac Vice by Deron R Dacus (on behalf of Alexander Rudis) ( Filing fee $ 100 receipt number 0542-15839235) by on behalf of International Business Machines Corporation. (Attachments: # 1 Proposed Order)(Dacus, Deron) (Entered: 03/22/2022) (Proposed Order) (1)
Mar 21, 2022 2 Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Dacus, Deron) (Entered: 03/21/2022) (1)
Mar 21, 2022 3 REQUEST FOR ISSUANCE OF SUMMONS by International Business Machines Corporation. (LxLabs GmgH) (Dacus, Deron) (Entered: 03/21/2022) (2)
Mar 21, 2022 4 REQUEST FOR ISSUANCE OF SUMMONS by International Business Machines Corporation. (Texas Wormhole, LLC) (Dacus, Deron) (Entered: 03/21/2022) (2)
Mar 21, 2022 N/A All parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 03/21/2022) (0)
Mar 21, 2022 5 Pro Hac Vice Letter. (Main document is Letter to Hamstra, Attachments: # 1 Letter to Rudis, # 2 Letter to Tallon)(lad) (Entered: 03/21/2022) (Main Document) (1)
Mar 21, 2022 6 Summons Issued as to LzLabs GmbH. (lad) (Entered: 03/21/2022) (2)
Mar 21, 2022 7 Summons Issued as to Texas Wormhole, LLC. (lad) (Entered: 03/21/2022) (2)
Mar 21, 2022 N/A Case assigned to Judge Alan D Albright. CM WILL NOW REFLECT THE JUDGE INITIALS AS PART OF THE CASE NUMBER. PLEASE APPEND THESE JUDGE INITIALS TO THE CASE NUMBER ON EACH DOCUMENT THAT YOU FILE IN THIS CASE. (lad) (Entered: 03/21/2022) (0)
Mar 21, 2022 1 Complaint* (1)
Mar 21, 2022 5 Pro Hac Vice Letter. (Main document is Letter to Hamstra, Attachments: # 1 Letter to Rudis, # 2 Letter to Tallon)(lad) (Entered: 03/21/2022) (Letter to Rudis) (1)
Mar 21, 2022 5 Pro Hac Vice Letter. (Main document is Letter to Hamstra, Attachments: # 1 Letter to Rudis, # 2 Letter to Tallon)(lad) (Entered: 03/21/2022) (Letter to Tallon) (1)
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