Payvox LLC filed its eighth February 2024 complaint against Lenovo (Motorola Mobility) (1:24-cv-01627) in the Northern District of Illinois. Local rules there require litigants to file a “Notice of Affiliates” that “shall identify all of the party’s affiliates known to the party after a diligent review; or state that after a diligent review the party has identified no affiliates”. Those same rules define “affiliate” to be “any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party”. Payvox has yet to file this required notice, counsel Rabicoff Law signing a bare corporate disclosure indicating that the plaintiff “does not have a parent corporation” and that “there is no publicly held corporation owning ten percent or more of its stock”.
