Sonos, Inc. v. Google LLC

District Court, N.D. California·Decided June 7, 2022·No. 3:21-cv-07559·Unknown

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8

10 SONOS, INC., 11 Plaintiff, No. C 21-7559 WHA

12 v.

13 GOOGLE LLC, ORDER RE MOTION FOR LEAVE TO AMEND AND MOTION TO STAY 14 Defendant.

15 16 17 INTRODUCTION 18 Plaintiff in this patent infringement action seeks leave to file its third amended complaint. 19 To the extent stated, that motion is GRANTED. Defendant’s corresponding motion to stay is 20 DENIED AS MOOT. 21 STATEMENT 22 A previous order herein dismissed with leave to amend Sonos, Inc.’s claims for enhanced 23 damages and indirect infringement for three of the patents-in-suit, U.S. Patent Nos.: 10,469,966; 24 10,779,033; and 10,848,885. That March 16 order grappled with the dearth of authority 25 regarding the appropriate pleading standard for enhanced damages and the key factual 26 particularities at issue here (Dkt. No. 156). 27 Specifically, the order established the ground rule that the complaint must adequately 1 Further, the order clarified that knowledge (required for both willful and indirect infringement) 2 cannot be established by the filing of the complaint itself. The order emphasized the efficacy of 3 a cease-and-desist letter in these circumstances. Such a letter explains why the accused product 4 infringes and gives the infringer a fair chance to cease or to obtain a license. The order, 5 nevertheless, found the filing of a declaratory relief action could conceivably concede the alleged 6 infringer’s knowledge of the patents and of infringement sufficient for a willful infringement 7 claim. After establishing these ground rules, the order dismissed Sonos’ willful and indirect 8 infringement claims but allowed Sonos to amend and try again. 9 Due, in part, to the vast amount of judicial resources being consumed on these issues in the 10 district courts, that order certified the rulings for interlocutory appeal under 28 U.S.C. Section 11 1292(b). Sonos filed a petition with the Court of Appeals for the Federal Circuit for review. 12 Alleged infringer Google LLC cross-petitioned for permission to appeal as well on a related 13 issue (Dkt. Nos. 161, 165). The day after Sonos docketed its petition, it also moved for leave to 14 amend its pleading on these issues in this action. Google opposes the motion for leave to amend 15 and moved to stay issues related to Sonos’s motion for leave to amend. During the pendency of 16 these motions, however, the Court of Appeals for the Federal Circuit summarily denied both 17 petitions regarding the March 16 order. Google’s motion is accordingly moot. 18 This order thus proceeds to consider Sonos’ motion for leave to amend, and follows full 19 briefing and oral argument. 20 ANALYSIS 21 Rule 15 states that leave to amend should be freely given when justice so requires. A 22 district court will consider: (1) bad faith; (2) undue delay; (3) prejudice to the opposing party; 23 (4) futility of amendment; and (5) repeated failure to cure deficiencies despite previous 24 amendments. Foman v. Davis, 371 U.S. 178, 182 (1962). The touchstone of the evaluation is 25 prejudice to the opposing party. Absent prejudice or a strong showing for another factor, a 26 presumption typically exists under Rule 15 in favor of granting leave to amend. Delay alone 27 cannot justify denying leave to amend, but futility can. Johnson v. Buckley, 356 F.3d 1067, 1077 1. FUTILITY. 1 This order starts with futility. “A motion to make an amendment is to be liberally granted 2 where from the underlying facts or circumstances, the plaintiff may be able to state a claim.” 3 DCD Programs, Ltd. v. Leighton, 833 F.2d 183, 186 (9th Cir. 1987) (quotation omitted). As in a 4 motion to dismiss, an amended complaint properly states a claim when the factual allegations 5 permit a reasonable inference, not just speculation, that defendants are liable for the misconduct 6 alleged. All factual allegations rate as true, but legal conclusions merely couched as fact may be 7 disregarded. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 8 544, 555 (2007). 9 The March 16 order on Google’s motion to dismiss the second amended complaint set the 10 ground rules. That order did not find it necessary to reach several of the technicalities that this 11 order now addresses — each in light of the tenets the March 16 order set forth. 12 First, Sonos’ proposed third amended complaint seeks to rectify the willfulness allegations 13 pertaining to the ’966 and ’033 patents. As the March 16 order reasoned, when the alleged 14 infringer files a declaratory judgment action of noninfringement, “the patent owner . . . should be 15 allowed to plead the infringer’s conceded knowledge of the patents and that the infringer has had 16 sufficient time to analyze the accused product vis-à-vis those patents (along with other specifics 17 needed to show willfulness)” (Dkt. No. 156 at 8). Consequently, Sonos’ proposed third amended 18 complaint includes revised allegations regarding Google’s filing of its declaratory judgment 19 filing. 20 The proposed pleading alleges Google “represented to the Court and to Sonos that it had a 21 Rule 11 basis to file its DJ action” (Proposed Third Amd. Compl. ¶ 56). Sonos then avers, “In 22 order to have conducted this investigation and to have formed a reasonable belief as to Google’s 23 alleged non-infringement of the asserted patents in time for its filing on September 28, 2020, 24 Google was conducting its investigation days, weeks, or months prior to September 28, 2020” 25 (id. ¶ 60). In the alternative, Sonos alleges that even if Google did, in fact, learn of the relevant 26 patents-in-suit when it received a draft of Sonos’ complaint: 27 specifications, claims, and file histories of the asserted patents, and 1 (iii) compare the operation of the accused products to the claims of the asserted patents and allegedly conclude that, for one or more 2 reasons, the accused products, according to Google, did not practice one or more elements of the asserted claims. 3 4 (id. ¶ 61). In either case, Sonos alleges “Google learned of the asserted patents and learned of its 5 alleged infringement thereof” (id. ¶ 63). 6 True, the March 16 order found that the eleven-hour period between Google receiving 7 Sonos’ draft complaint and the filing of its declaratory judgment action “was not enough time to 8 provide an alleged infringer a meaningful opportunity to cease infringing and negotiate a 9 license” (Dkt. No. 156 at 9). Now, however, Sonos has revised its allegations on this point and 10 plausibly alleged Google had adequate notice to assess the allegations of infringement in the 11 draft complaint. On the one hand, according to Sonos, Google had been preparing a declaratory 12 judgment action for some time on the relevant patents, which demonstrates knowledge of the 13 patents and knowledge of infringement. Or, on the other hand, Google expedited its review of its 14 technology and Sonos’ patents in order to beat the clock and file a declaratory judgment action 15 first. In light of the requirements of Rule 11, as Sonos avers, this order finds it plausible that 16 Google performed all this analysis. That is enough for our present purposes to allow the issue of 17 willfulness to go forward with respect to the ’966 and ’033 patents. 18 Google did not dispute this conclusion in its briefing, resting instead on now-mooted 19 arguments about Federal Circuit intervention (Opp. at 8). At oral argument, however, Google 20 pivoted.

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Sonos, Inc. v. Google LLC, (N.D. Cal. 2022).

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
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550 U.S. 1 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)