Anderson Power Products, Inc. v. Bizlink Technology, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 12, 2025
Docket3:23-cv-05436
StatusUnknown

This text of Anderson Power Products, Inc. v. Bizlink Technology, Inc. (Anderson Power Products, Inc. v. Bizlink Technology, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson Power Products, Inc. v. Bizlink Technology, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ANDERSON POWER PRODUCTS, INC., Case No. 23-cv-05436-AMO

8 Plaintiff, ORDER GRANTING STAY v. 9 Re: Dkt. No. 62 10 BIZLINK TECHNOLOGY, INC., et al., Defendants. 11

12 13 This is an action for patent infringement relating to Defendants’ alleged infringement of 14 United States Patent No. 8,808,017 (“the ’017 patent”). Before the Court is Defendants’ Motion 15 to Stay the case pending inter partes review (“IPR”). The matter is fully briefed and suitable for 16 decision without oral argument. Accordingly, the hearing set for February 27, 2025, is 17 VACATED. See Civ. L.R. 7-6. Having read the parties’ papers and carefully considered their 18 arguments and the relevant legal authority, and good cause appearing, the Court hereby GRANTS 19 the Motion. 20 I. BACKGROUND 21 Plaintiff filed this action on October 23, 2023, alleging infringement of the ’017 patent by 22 Defendants’ BSC-301 series receptacle and BC-330 series plug (collectively, the “Accused 23 Product”). See Compl. (ECF 1). Plaintiff alleges that Defendants infringed 14 claims of the ’017 24 patent, including claims 1-6, 7, 9, and 13-18. See id. Defendants answered Plaintiff’s complaint 25 on March 19, 2024. ECF 27. On June 7, 2024, the Court entered a Case Management Order 26 setting the claim construction hearing date for January 23, 2025. ECF 38, ECF 39. The parties 27 have served and responded to written discovery, exchanged infringement and invalidity 1 On October 29, 2024, Plaintiff filed a Motion for Leave to Amend its Infringement 2 Contentions to add claims 5-6 and 13-18 of the ’017 patent (“Newly Asserted Claims”). ECF 49. 3 The Court then vacated the claim construction hearing, noting that Anderson’s infringement 4 contentions remain “unsettled.” ECF 59. 5 On November 24, 2024, the Patent Trial and Appeal Board (“PTAB”) issued its Decision 6 Granting Inter Partes Review of claims 1-4 and 7-12 of the ’017 patent. Smyth Decl., Ex. 1 (ECF 7 62-6). Defendants filed this Motion to Stay on November 27, 2024. See ECF 62. 8 II. DISCUSSION 9 Courts have inherent power to manage their dockets, “including the discretion to grant a 10 stay pending concurrent proceedings before the PTO.” Capella Photonics, Inc. v. Cisco Sys., Inc., 11 2015 WL 1006582, at *1 (N.D. Cal. Mar. 6, 2015) (citing Ethicon, Inc. v. Quigg, 849 F.2d 1422, 12 1426–27 (Fed. Cir. 1988)). In determining whether to stay a patent infringement case pending 13 review or reexamination of the patents, courts traditionally consider three factors: “(1) whether 14 discovery is complete and whether a trial date has been set; (2) whether a stay will simplify the 15 issues in question and trial of the case; and (3) whether a stay would unduly prejudice or present a 16 clear tactical disadvantage to the nonmoving party.” PersonalWeb, LLC v. Apple, Inc., 69 F. 17 Supp. 3d 1022, 1025 (N.D. Cal. 2014) (citations and quotations omitted). Courts in this district 18 have often recognized a “liberal policy in favor of granting motions to stay” pending IPR. See, 19 e.g., Zomm, LLC v. Apple, Inc., 391 F. Supp. 3d 946, 956 (N.D. Cal. 2019). 20 Here, all factors weigh in favor of staying this case pending PTAB review. 21 A. Stage of Litigation 22 “The first factor the Court considers is whether the litigation is at an early stage.” Zomm, 23 LLC v. Apple Inc., 391 F. Supp. 3d 946, 956 (N.D. Cal. 2019) (citing AT&T Intellectual Property I 24 v. Tivo, Inc., 774 F. Supp. 2d 1049, 1052 (N.D. Cal. 2011)). “An early stay may save the parties 25 and the Court from unnecessarily expending significant resources. A stay later in the proceedings 26 will likely produce less benefit and increase the possibility of prejudice.” Largan Precision Co. v. 27 Motorola Mobility LLC, No. 21-cv-09138-JSW, 2022 WL 294935, at *4 (N.D. Cal. July 26, 1 dispositive motion practice; (2) whether the court has issued its claim construction order; and 2 (3) whether the court has set a trial date.” Id.; see also PersonalWeb Techs., LLC v. Apple Ins., 69 3 F. Supp. 3d 1022, 1025-26 (N.D. Cal. 2014) (collecting cases). 4 Here, the stage of this litigation favors a stay. Though the parties have filed their claim 5 construction briefs, the Court has not made any substantive determinations on the merits. The 6 schedule also favors a stay. No trial date has been set. ECF 39. In addition, although discovery 7 has begun, it is far from complete. Id. No fact depositions have been taken and no close to 8 discovery has been set. While it is true that the parties have begun or completed several of their 9 obligations under the patent local rules (e.g., infringement contentions, claim construction 10 discovery), these are generally events that happen early in the life of a case and are not, by 11 themselves, enough to weigh against a stay. Far more work lies ahead for the litigants. The Court 12 thus finds this factor weighs in favor of granting a stay. 13 B. Simplification of Issues 14 “A stay pending reexamination is justified where ‘the outcome of the reexamination 15 would be likely to assist the court in determining patent validity and, if the claims were canceled 16 in the reexamination, would eliminate the need to try the infringement issue.’ ” Evolutionary 17 Intelligence, LLC v. Apple, Inc., No. 13-CV-04201-WHA, 2014 WL 93954, at *2 (N.D. Cal. Jan. 18 9, 2014) (quoting Slip Track Sys., Inc. v. Metal Lite, Inc., 159 F.3d 1337, 1341 (Fed. Cir. 1998)). 19 “The standard is simplification of the district court case, not complete elimination of it by the 20 PTAB.” Finjan v. Symantec Corp., 139 F. Supp. 3d 1032, 1036 (N.D. Cal. 2015) (citing LELO, 21 Inc. v. Standard Innovation (US) Corp., No. 13-cv-01393-JD, 2014 WL 2879851, at *3 (N.D. Cal. 22 June 24, 2014)). Courts regularly grant stays even before the PTAB has decided whether to 23 conduct IPR and the likelihood of simplification remains somewhat speculative. See, e.g., Topia 24 Tech., Inc. v. Dropbox Inc., No. 23-CV-00062-JSC, 2023 WL 3437823, at *4-6 (N.D. Cal. May 25 12, 2023) (granting stay request before PTAB made IPR institution decision). 26 Here, the PTAB granted Defendants’ review petition as to all of the six claims currently at 27 issue in the case, including claims 1-4, 7, and 9. Smyth Decl., Ex. 1 at 32 (“Accordingly, it is: 1 claims 1-4 and 7-12 of the ’017 patent based on the unpatentability challenges presented in the 2 Petition”). The PTAB’s final decision on these claims will substantially simplify the issues in this 3 case. Either the claims, already found reasonably likely to be invalid, will become moot, or the 4 Court will have the benefit of the PTAB’s findings. Under either outcome, a stay pending IPR 5 will likely simplify the issues in question, avoid inconsistent outcomes, and preserve limited 6 judicial resources from ruling on issues that may change following PTAB review. The Court 7 concludes that the second factor weighs in favor of a stay. 8 C. Undue Prejudice 9 “Third, the Court looks to whether a stay would unduly prejudice or present a clear tactical 10 disadvantage to the nonmoving party.” PersonalWeb Techs., 69 F. Supp. 3d at 1029.

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Anderson Power Products, Inc. v. Bizlink Technology, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-power-products-inc-v-bizlink-technology-inc-cand-2025.