Untitled case

I'll research this case thoroughly before drafting.

Confirmed the defendant. Let me dig into details.

Case Overview & Background

The parties. The defendant is Motorola Mobility LLC — the consumer-devices operating company (best known for smartphones and, historically, mobile handsets; now a Lenovo subsidiary, headquartered in the Chicago area, which explains the N.D. Ill. forum). This confirms the previously flagged uncertainty in the earlier summary that the defendant was "likely a Motorola entity." The plaintiff, Cine Graphic Solutions LLC, is a non-practicing entity (NPE/PAE): Unified Patents describes it as "an NPE and a subsidiary of Strategic Intellectual Solutions, LLC" (Unified Patents, PATROLL contest pages and "Cine Graphics Solutions '587 prior art found," Jan. 26, 2022). The patents originated with inventor Douglas G. Richardson of Dripping Springs, Texas, who in 2005 developed a technique he marketed as the "Cinegif" — an otherwise still image containing an isolated region of motion designed to draw a viewer's eye, used in online advertising for clients such as Jaguar Land Rover, Maserati, Chick-fil-A, and others (allegations in Richardson v. Pond5, Inc., S.D.N.Y. 1:22-cv-04963, Compl. ¶¶ 10–14). So this is a classic inventor-sourced portfolio placed into an assertion vehicle rather than a university or operating-company plaintiff.

The accused technology and patents. The suit was filed April 6, 2021 as Cine Graphic Solutions LLC v. Motorola Mobility LLC, No. 1:21-cv-01840 (N.D. Ill.), nature of suit 830 (Patent), and the docket aggregator records is now closed. Public sources confirm the three asserted patents but I could not verify the precise accused Motorola products/services or the specific claims charted; the complaints themselves are the authoritative source and are not reflected in the search results I could retrieve. The patents — all from the same family and generally directed to "providing animation in electronic communications, such as emails and websites" (Unified Patents) — are: US 7,388,587, titled "Method for embedding animation in electronic mail and websites" (the foundational Cinegif-style overlay of a low-resolution animated region onto a high-resolution still image); US 7,629,977, a sibling in the same animation-embedding family; and US 8,035,644, likewise described by Unified as a "Method for Embedding Animation." The family also includes US 8,487,939, which Richardson later asserted directly. In other words, the technical thrust is decades-old web/email image-composition and animated-GIF delivery, not wireless or handset hardware.

Procedural posture and why it matters. Venue in the Northern District of Illinois is unremarkable but meaningful: it is Motorola Mobility's home district, and it sits in the Seventh Circuit rather than the plaintiff-friendly patent venues of Texas or Delaware. I could not confirm the assigned judge, the disposition date, or the terms of the closing order (settlement, voluntary dismissal, or inter partes review stay/dismissal are all plausible), so any statement about why it closed would be speculation. The case is notable chiefly as one node in a multi-defendant 2021 assertion wave: Unified Patents reports the same three patents were asserted against Motorola, Samsung, and Fujifilm (the Fujifilm action was filed in S.D.N.Y. as Cine Graphic Solutions LLC v. FUJIFILM Holdings America Corp. et al., No. 1:21-cv-07917). Critically for IPR linkage, Unified Patents opened three PATROLL crowdsourcing prior-art contests on December 8, 2021 covering claim 1 of all three patents and subsequently announced prior art found on the '587 (July 2022) and '644 (July 2023) patents — the '644 award going to a submission naming Richardson as owner, suggesting ownership may have reverted to the inventor. That prior-art effort makes an IPR challenge plausible, but I found no confirmed PTAB petition against these patents and cannot state that one was filed. The commercial context is the long-running fight over animated images/GIFs in digital advertising and e-commerce, which is why the later Richardson v. Pond5 case over stock-media imagery matters.

Sourcing caveats: Party identity, case number, filing date, patents, NPE status, and the inventor/portfolio background are well sourced (docket aggregators; Unified Patents PATROLL pages and insights; the Pond5 complaint). The accused products, assigned judge, and the reason/terms of closure are not verified and should be checked against PACER and the actual complaint before any filing or memo relies on them.

I'll research the docket, rulings, and disposition of this case.

Let me look for the docket detail, PTAB proceedings, and parallel cases.

Important sourcing note up front: the N.D. Ill. docket for this case is not fully reflected in the sources I was able to reach. Unlike the Fujifilm S.D.N.Y. case (whose docket text surfaced in search), the Motorola docket's individual entries did not come back. So the chronology below distinguishes verified events from unverified/inferred ones. I flag every gap rather than fill it.

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Key Legal Developments & Outcome

1. Filing and initial pleadings

The complaint asserted the three family patents US 7,388,587, US 7,629,977, and US 8,035,644. Filing date and NOS code are consistent across the case metadata and the CourtListener-derived aggregator (ai-lab-cl-prod.azurewebsites.net/case/dct/ilnd/1:21-cv-01840). The aggregator lists the case as Status: Closed, but gives no disposition date or closing entry — I could not retrieve that.

I found no evidence of a Rule 12(b)(6) motion, a § 1406/1404 transfer motion, or any other threshold motion in this case. Note that the aggregator page carries an anomalous "Ex Parte" label in its title field; that appears to be an aggregator template artifact, not evidence of an ex parte reexamination — I would not rely on it.

2. Pre-trial motions of substance — stay pending IPR, transfer, SJ

None verified. There is a strong structural reason a stay motion would have been expected, however: Unified Patents opened three PATROLL crowdsourcing prior-art contests on 2021-12-08 targeting claim 1 of all three asserted patents, with an announced deadline of 2022-03-31 (Unified Patents, "$6,000 for Cine Graphic Solutions prior art," 2021-12-08). Crowdsourced PATROLL art typically precedes a filed IPR, and a defendant in Motorola's position would have had every incentive to seek a stay. But I found no confirmed PTAB petition against these three patents, and therefore cannot state that any IPR was filed, much less that a stay was sought or granted. This is the single most important unresolved item in the chronology.

3. Claim construction (Markman)

No Markman order, transcript, or joint claim construction statement located. The case appears to have closed without a public claim construction ruling; the three asserted claims are short method/apparatus claims in the animation-embedding family (Unified describes them as directed to "providing animation in electronic communications, such as emails and websites"). I cannot confirm whether claim construction was ever reached.

4. Discovery milestones

None verified. No scheduling order, ESI order, infringement/contentions service, or expert deadline surfaced. The absence of a Markman ruling plus the "Closed" status suggests an early-to-mid-stage exit (voluntary dismissal or settlement), but that is inference, not evidence.

5. Trial, verdict, post-trial motions

No trial, verdict, JMOL, new-trial, or fee motion located. The docket aggregator shows the case closed. Given the filing date (April 2021), a closed status, and no reported opinion, trial is highly unlikely — the realistic dispositions are voluntary dismissal, settlement, or dismissal tied to a challenge to the patents. I could not verify which.

6. Final disposition / present posture

Closed, terms unknown. This is the honest bottom line. The aggregator reports the case as closed but does not show the closing entry, so I cannot tell you whether the file closed by:

• stipulated/voluntary dismissal (with or without prejudice),
• settlement,
• dismissal after an IPR or reexamination invalidated or narrowed the claims, or
• some other order.

Flagging a potential contradiction with the earlier-generated summary: that summary said the docket "records is now closed" while also cautioning that the disposition is unverified — those are consistent, but please note the aggregator's "Closed" flag is the only source for closure I could reach, and it is a secondary aggregator rather than PACER itself.

7. Parallel PTAB / USPTO developments — the most substantive verified thread

This is where the real documentary record is, and it materially bears on the litigation's trajectory:

• 2021-12-08 — Unified Patents launches PATROLL contests on claim 1 of the '587, '977, and '644 patents, noting they "have been asserted against Motorola, Samsung, and Fujifilm." Contests close 2022-03-31. (unifiedpatents.com/insights/2021/12/8/6000-for-cine-graphic-solutions-prior-art)
• 2022-07-26 — Unified announces prior art found on the '587 patent (unifiedpatents.com/insights/2022/7/26/cine-graphics-solutions-587-prior-art-found). The winning submission is identified on the PATROLL contest page (patroll.unifiedpatents.com/contests/d8EnnurxF42M79APT).
• 2023-07-24 — Unified announces a $2,000 award for prior art on the '644 patent, and — critically for ownership — describes the '644 patent as "owned by Douglas G. Richardson," "formerly owned by Cine Graphic Solutions." (unifiedpatents.com/insights/2023/7/24/2000-awarded-for-douglas-g-richardson-animation-patent-prior-art)

Strategic significance: the '644 award notice is direct evidence that ownership of at least the '644 patent moved back from Cine Graphic Solutions to the inventor by mid-2023. That is consistent with (a) Cine Graphic's assertion campaign winding down, and (b) the inventor continuing separately (Richardson v. Pond5, Inc., S.D.N.Y. 1:22-cv-04963). It is not proof that the Motorola case settled, but a reassignment of the asserted patent during the pendency of the suit would be a strong indicator of an exit event.

No IPR/PGR number for any of the three patents appears in my search results. If Unified's prior-art finds matured into petitions, they are not reflected in the retrievable record. Treat "no IPR was filed" as unconfirmed, not established.

8. Parallel district-court litigation in the same wave

• Samsung — asserted patents per Unified's statements; case details not retrieved.

• Fujifilm — Cine Graphic Solutions LLC v. FUJIFILM Holdings America Corp. et al., No. 1:21-cv-07917 (S.D.N.Y.), assigned to Judge Vernon S. Broderick. Verified docket activity: complaint filed ~2021-09 with exhibits including the '587, '977, and '644 patents plus separate claim charts for each patent (Dkt. 1–6); service on both defendants 2021-09-29/30 (Dkt. 14–15); defendant's counsel Richard F. Martinelli appeared (Dkt. 16, 2021-10-15); answers extended first to 2021-11-19 (Dkt. 18, 2021-10-18) and then to 2021-12-20 (Dkt. 20, 2021-11-19). Plaintiff's counsel in that action: Charles Austin Ginnings and Timothy E. Grochocinski.

  Two takeaways: (1) the wave had filed claim charts for each asserted patent, which is where the accused-product identification actually lives for the Motorola case too; and (2) the Motorola case was filed in April 2021 — roughly five months before the Fujifilm case — making Motorola the earliest or among the earliest filings in the campaign.

  Note: the Fujifilm docket shows plaintiff's counsel in the S.D.N.Y. action; whether the same counsel appeared for Cine Graphic in N.D. Ill. is not verified.

• Tangential but relevant context: Motorola Mobility is a repeat N.D. Ill. patent defendant (e.g., Ironworks Patents, LLC v. Motorola Mobility LLC, No. 1:20-cv-01357 (N.D. Ill.), before Judge Joan H. Lefkow, where a jury trial was set for 2022-07-11). That is a different case and does not bear on this one except as venue context.

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Bottom line on outcome

The litigation is closed, almost certainly without trial, and there is no public judicial ruling — no Markman order, no summary judgment opinion, no verdict, no appellate decision — attached to Cine Graphic Solutions v. Motorola Mobility. The verified record of substance sits in the PATROLL/prior-art track (Dec. 2021 contests → '587 art found July 2022 → '644 art found July 2023, by which time the '644 had reverted to the inventor), not in the courtroom. The precise reason and terms of closure are unverified.

What I could not verify (recommended PACER pulls)

1. Closing entry and its date — docket entries after mid-2022, looking for a stipulation of dismissal (likely under Rule 41(a)) and any settlement-order language.
2. Assigned judge and referral to a magistrate (N.D. Ill. patent cases are often referred to a designated magistrate).
3. Motorola's answer and any invalidity counterclaims, and whether § 101 was pleaded.
4. Whether a motion to stay pending IPR was filed and any PTAB petition numbers.
5. The 2021-04-06 complaint's accused products and asserted claims.
6. Any reexamination or IPR certificate affecting the '587, '977, or '644 claims.
7. The Samsung case number, court, and disposition (not found here).
8. USPTO assignment records for all three patents to confirm the Cine Graphic → Richardson reassignment and its date.

Caveat: all party names, the case number, the April 6, 2021 filing date, and the three patents are taken as authoritative from the case metadata and corroborated by secondary sources. Everything about motion practice, Markman, discovery, trial, and the mechanical nature of closure is unverified and should not be relied on in a filing or memo without a PACER/PTAB confirmation.

I'll research the plaintiff's counsel of record for this case.

Let me dig deeper with more targeted searches.

The S.D.N.Y. Fujifilm docket shows plaintiff's attorneys. Let me verify whether the same counsel appeared in the Motorola N.D. Ill. case, and research each attorney.

I hit the tool-call limit before I could fully confirm the N.D. Ill. docket directly, so let me report what I was able to verify and be explicit about the gaps.

Plaintiff's Counsel of Record — Cine Graphic Solutions LLC v. Motorola Mobility LLC, No. 1:21-cv-01840 (N.D. Ill.)

What I could confirm

Direct confirmation for the Motorola case is incomplete. I was not able to pull the actual N.D. Ill. docket sheet or complaint PDF for 1:21-cv-01840 through the searches available, so I cannot yet quote a specific attorney-appearance docket entry (e.g., ECF No. 2/5 "Notice of Appearance") in this case. The aggregator pages that surfaced for 1:21-cv-01840 (CourtListener/ai-lab mirror) show the case metadata — filed 04/06/21, NOS 830, "Status: Closed," defendant Motorola Mobility LLC — but did not render the counsel field. Treat the names below as highly probable but not docket-confirmed for the Motorola action specifically.

Strong cross-case indication (same NPE wave, same patents)

The most reliable counsel evidence comes from the parallel sister action filed by the same plaintiff on the same three patents: Cine Graphic Solutions LLC v. FUJIFILM Holdings America Corporation et al., No. 1:21-cv-07917 (S.D.N.Y.) (Judge Vernon S. Broderick). The UniCourt docket for that case lists the plaintiff's attorneys as:

The S.D.N.Y. docket also reflects a defense attorney, Richard F. Martinelli, but that is Fujifilm's side and does not bear on plaintiff's Motorola counsel.

Assessment and caveats

• Likelihood the same two attorneys appear in the Motorola case: high — NPE assertion waves on identical patents are almost always handled by one plaintiff-side team across all defendants, and Cine Graphic Solutions (a subsidiary of Strategic Intellectual Solutions, LLC) is a single-patent-holder vehicle. But I have not verified it, and I will not state it as docket fact.
• Do not rely on these names for the Motorola action without checking PACER / CourtListener RECAP directly for 1:21-cv-01840, looking for the "Notice of Appearance" or the signature block on the complaint (likely filed 04/06/2021) and on any stipulation of dismissal (the case is closed).
• Local-counsel requirement: Because 1:21-cv-01840 is in N.D. Ill., at least one attorney appearing for plaintiff must be a member of the N.D. Ill. bar. Grochocinski's Chicago-area base fits a local-counsel role; Ginnings may be the lead filer. I could not confirm which is designated lead.
• In-house counsel: none expected — the plaintiff is an NPE shell with no in-house litigation staff.

What remains unverified (flagged, not fabricated)

1. The exact ECF appearance entries in 1:21-cv-01840.
2. The specific firm names and office locations for Ginnings and Grochocinski as stated on their appearances in this case (my firm attribution for Grochocinski is from background knowledge of his practice, not confirmed from a filing here).
3. Whether any additional plaintiff-side attorneys (e.g., local N.D. Ill. counsel of record, or other firm members) also appeared.

Bottom line: The plaintiff's counsel most likely of record are Charles Austin Ginnings and Timothy E. Grochocinski, per the confirmed counsel list in the plaintiff's parallel S.D.N.Y. Fujifilm action on the same patents — but this should be verified against the N.D. Ill. docket in 1:21-cv-01840 before being cited as the counsel of record in the Motorola case.

I'll research the counsel of record for Motorola Mobility in this case.

Let me dig into the docket and CourtListener records.

Let me try the docket aggregator directly and other sources.

Counsel of Record — Defendant Motorola Mobility LLC

Bottom line: counsel of record is not verified in the sources I could retrieve

I was unable to confirm, from any reliable source, the identity of the attorneys who appeared for Motorola Mobility LLC in Cine Graphic Solutions LLC v. Motorola Mobility LLC, No. 1:21-cv-01840 (N.D. Ill.). Rather than fill this gap with guesses, I want to be explicit: I will not name attorneys I cannot source. The specific appearance forms and the clerk's counsel list for this docket did not surface in the searches I could run.

What the available records do and don't show

• Docket aggregator (CourtListener-derived). The case page at ai-lab-cl-prod.azurewebsites.net/case/dct/ilnd/1:21-cv-01840/... confirms the caption, filing date (April 6, 2021), nature of suit (830 – Patent), sector (Communications), and status (Closed). The page includes an "Attorney" field, but the underlying content did not render in the search snippet — so the aggregator has a counsel field, I simply could not read its contents. This is the single best place to confirm counsel of record, either via the aggregator's full page or, authoritatively, via PACER.
• No appearance documents surfaced. Searches for N.D. Ill. attorney-appearance forms or pro hac vice motions tied to this case returned nothing. By contrast, for an unrelated older Motorola matter (Intellect Wireless v. Motorola, No. 1:08-cv-01350), an N.D. Ill. appearance form did surface — confirming such documents are indexed when they exist, and that the absence here is a retrieval gap, not proof that no appearance was filed.
• No order, dismissal motion, or settlement notice surfaced that would have named counsel in a signature block.

Because the case is closed, appearances were almost certainly filed at some point; a closed 2021 patent case defended by an operating company does not go to closure without counsel ever entering. So the correct inference is that counsel exists but is unverified here, not that none appeared.

Why I'm not naming anyone (rather than guessing)

This is exactly the kind of field where the risk of fabrication is high. Motorola Mobility (a Lenovo subsidiary, HQ in the Chicago area) is a frequent patent-litigation defendant, and numerous well-known firms have represented it over the years across many cases — which makes it easy to pattern-match a plausible-sounding name and hard to confirm it belongs to this docket. None of the firms or attorneys that appeared in my broader search results (e.g., Mayer Brown, Wolf Greenfield, Orrick, Greenberg Traurig) were tied by any returned source to this case. I therefore decline to list them as counsel here.

How to confirm counsel of record (recommended next steps)

1. PACER / CourtListener RECAP docket for No. 1:21-cv-01840 — the docket entries plus the "Attorneys" tab are authoritative. Look for:
   • Initial Appearance forms (N.D. Ill. uses a standard "Attorney Appearance Form," L.R. 83.12–83.14);
   • Motions for leave to appear pro hac vice (these name the out-of-state lead counsel and the local Rule 83.15 sponsor);
   • The signature blocks of the FRCP 7.1 corporate disclosure statement, answer/motion to dismiss, and any joint status report — these invariably list lead and local counsel.
2. The ai-lab-cl-prod aggregator page's "Attorney" field — re-open it directly (not via search snippet) to read the counsel list it already indexes.
3. The complaint's certificate of service and any notice of voluntary dismissal / stipulation of dismissal — the closing documents typically carry counsel signature blocks.
4. Unified Patents PATROLL pages for the three patents ('587, '977, '644) — though these track prior art/PTAB activity, not district-court defense counsel, so they likely won't help on this point.

What I can state confidently about the defense side

• Defendant: Motorola Mobility LLC (confirmed as the previously-flagged "likely Motorola entity").
• Likely defense structure (general practice, not case-specific here): Motorola Mobility typically retains national patent-litigation counsel (often a large IP-heavy firm) working alongside local N.D. Ill. counsel admitted to the court's general bar, with in-house IP counsel supervising. The pro hac vice / local counsel pairing is the standard pattern in this district — but I have no verified source identifying the specific firms or individuals in this case, so treat this as a structural expectation only.

Sourcing caveats

Everything above about the case posture (caption, filing date, NSD 830, closed status) comes from the CourtListener-derived aggregator page. The identity of counsel is unsourced in my results and should be treated as unknown pending PACER review. I have deliberately left this section's core deliverable — names, firms, offices, roles — blank rather than populate it with unverified entries. If you can pull the docket sheet (or let me re-run targeted searches against PACER/CourtListener with the docket-entry numbers), I can complete the attorney table precisely.