Last month’s review of notable patent assignments considered the movement of assets from Avaya to Dominion Harbor Enterprises, LLC; from Level 3 Communications to Sandpiper CDN, LLC; from Seiko Epson to IPValue’s 138 East LCD Advancements Ltd. and Lumitek Display Technology Ltd.; from Transaction Security to a “BioCrypt Access”; from Fortress Investment Group LLC’s KIP Prod P1 LP to Prodea Automation LLC; from EMM Patents Ltd. to Empire IP LLC; from Siemens and Abdelsalam Helal to Rokiot USA LLC; and from Proxicom Wireless, LLC to Secure Communication Technologies, LLC. While a couple of these entities again feature prominently, this month’s review extends well beyond them to cover the movement of patents away from other operating companies, as well as within several repeat monetization players.

Wyoming Technology Licensing LLC has filed an Eastern District of Texas complaint against Verizon (2:24-cv-00467), alleging infringement of a single patent through the provision of smartphones, including those made by Alphabet (Google), Apple, or Samsung, that operate via an “intelligent voice assistant”. The claim chart attached to this complaint highlights the alleged infringement through the provision of the iPhone 15 Pro and its Siri voice assistant, characterizing that product as “representative for illustrating infringement of the other devices”, doing so despite the fact that a notice of settlement has been filed in the only prior case in this campaign, filed against Apple earlier this year.

Mobile Health Innovative Solutions, LLC (MHIS) has added an Eastern District of Texas case against Alphabet (Google) (2:24-cv-00437) to its sole litigation campaign, begun in December 2023 against Withings and since hitting Apple, Zepp Health, and Samsung (in that order). A single patent generally related to a wearable device with sensors that can be used to determine a user’s stress level is asserted against each defendant, with Google accused of infringement through the provision of its Pixel Watches.

This past January, Pay As You Go, LLC (PAYG), a plaintiff associated with monetization figure Leigh M. Rothschild, voluntarily dismissed its October 2023 case against Verizon, doing so without prejudice. Now, PAYG has sued Verizon (2:24-cv-00400) again, this time asserting a later family member of the patent previously in suit, both described as generally related to “telecommunications services and methods that enable a user and/or other responsible party to make payments as the user uses the telecommunication services”. The plaintiff again targets the provision of wireless telecommunication services that support features for allowing users to purchase such services in “blocks of data that can be used in a single month on the customer-user’s device”.

The bulk of the Eastern District of Texas complaint that Quantum Technology Innovations, LLC just filed against Liberty Media (SiriusXM) (2:24-cv-00246) is devoted to recounting the prosecution history of the sole patent-in-suit and to pleading defensively against an Alice attack. The intensity of that focus is perhaps motivated by the SiriusXM motion challenging the patents asserted against it this past December—by Display Technologies, LLC, which, like Quantum, is a plaintiff associated with Leigh M. Rothschild—as patent-ineligibly drawn to the abstract idea of “transferring a digital media file”. There, SiriusXM cites a prior court order characterizing Display’s “goal”: to pursue a “’nuisance-value’ settlement” through a “ransom” that SiriusXM does not wish to pay.

So far this month, Mobile Health Innovative Solutions, LLC (MHIS) has added cases against Samsung (2:24-cv-00106) and Zepp Health (Zepp North America) (2:24-cv-01030) to the litigation campaign that it began in December against Withings and expanded in January against Apple. As the plaintiff’s name suggests, this campaign is another health tracking affair, with a single patent generally related to a wearable device with sensors that can be used to determine a user’s stress level asserted. The case against Zepp was filed in the Central District of California, local rules of which require MHIS to disclose who is behind this litigation.

Valve has filed a second amended complaint in the Western District of Washington case (2:23-cv-01016) begun last July against Leigh M. Rothschild and three associated entities Display Technologies, LLC; Patent Asset Management, LLC; and Rothschild Broadcast Distribution Systems, LLC (RBDS), together with Rothschild counsel Meyler Legal, PLLC and its principal Samuel Meyler. The defendants have refiled a motion to dismiss the complaint in which they argue that Valve is “attempting to make ‘a mountain out of a mole hill’ by characterizing a simple clerical error as some sort of legal malfeasance” under the state’s “Patent Troll Protection Act”. Meanwhile, venue challenges in Eastern District of Texas cases filed this past September by three other Rothschild plaintiffs—Quantum Technology Innovations, LLC; Social Positioning Input Systems, LLC (SPIS); and Symbology Innovations, LLC—are ripening.

Display Technologies, LLC, one of many NPEs controlled by inventor Leigh M. Rothschild, has sued AP Global (2:20-cv-05041), Faurecia (Clarion) (8:20-cv-01028), and Mazda (8:20-cv-01029), each in the Central District of California. A single patent generally related to wirelessly transferring media files between devices is asserted, with the defendants accused of infringement through the provision of media streaming products that feature Bluetooth connectivity: for AP Global and Mazda, the BlueSYNC BX speaker; and for Clarion, the Clarion Car Infotainment System.

Having filed roughly 30 new cases since June 1, and more than 100 new suits since the start of 2019, prolific inventor and patent plaintiff Leigh M. Rothschild is poised to land—for the fourth year in a row—among this year’s most frequent NPE plaintiffs. (To view the 2018 list of the most frequent NPE plaintiffs, see the “Patent Litigation and Marketplace Report” that RPX published on Insight this past March.) Historically, Rothschild (through various associates) has asserted in litigation patents on which he is a named inventor, or, as was particularly the case in 2017-2018, patents acquired from Intellectual Ventures LLC (IV). Now, public records indicate that Rothschild looked to a new source for patents to assert in his latest campaign, which was recently kicked off with suits against Adobe and Blackbaud.