Bose Corp v. IngenioSpec LLC

Bose Corp v. IngenioSpec LLC (IPR2025-01549) was an Inter Partes Review initiated by Bose Corp against IngenioSpec LLC before the Patent Trial and Appeal Board (PTAB), challenging the validity of U.S. Patent No. 11,852,901. The petitioner, Bose Corporation, is an American manufacturing company renowned for its audio equipment, including home audio systems, speakers, and noise-canceling headphones. The patent owner, IngenioSpec LLC, is identified as a patent assertion entity (PAE) or non-practicing entity (NPE) that acquires and licenses patents, particularly in the electronic eyewear and head wearable markets.

This IPR stemmed from an underlying patent infringement lawsuit filed by IngenioSpec LLC against Bose in the U.S. District Court for the Eastern District of Texas (Case No. 2:24-cv-00822), on October 7, 2024. In that litigation, IngenioSpec alleged that Bose's "wireless wearable devices," specifically identifying the "Bose QuietComfort Ultra Earbuds," infringed the '901 patent. U.S. Patent 11,852,901 is generally described as relating to a "wearable audio system supporting enhanced hearing support." The Eastern District of Texas is a well-known venue for patent infringement cases, often chosen by plaintiffs for its efficiency and historical track record.

The IPR, filed on September 19, 2025, was part of Bose's defense against IngenioSpec's infringement claims. The underlying district court case was ultimately dismissed on October 15, 2025, following a joint motion to dismiss by IngenioSpec, indicating a settlement between the parties. This IPR is notable as it represents an operating company's challenge to patents asserted by an NPE with an active litigation campaign against multiple major consumer electronics manufacturers, including Apple, LG, Samsung, and Sony, concerning wireless audio and wearable technologies. Furthermore, Unified Patents has highlighted IngenioSpec's portfolio, running crowdsourcing contests to find prior art against some of its patents, suggesting a broader industry interest in challenging their validity.

The case "Bose Corp v. IngenioSpec LLC, IPR2025-01549" concerns an Inter Partes Review (IPR) before the Patent Trial and Appeal Board (PTAB) regarding U.S. Patent 11852901. While the prompt initially asks about "patent infringement litigation," the provided case number and court clearly indicate an IPR proceeding. However, related district court litigation involving the same patent and parties has also been identified.

Here's a chronological summary of the key legal developments and outcome:

Parallel District Court Litigation (Eastern District of Texas):

• 2024-10-07: IngenioSpec LLC filed a patent infringement lawsuit against Bose Corporation in the U.S. District Court for the Eastern District of Texas (Case No. 2:24-cv-00822). The lawsuit alleged infringement of several patents, including US Patent 11852901, by Bose's "QuietComfort Ultra Earbuds" and other wireless communication devices.
• 2024-11-27: Bose filed a Motion to Dismiss for Improper Venue in the Texas suit.
• 2024-12-11: IngenioSpec stipulated to a dismissal of the Texas lawsuit against Bose without prejudice.
• 2025-07-30: An order was signed by District Judge Rodney Gilstrap granting a motion to stay all deadlines and notice of settlement in a related district court case (though the specific parties for this event aren't clearly Bose and IngenioSpec, it indicates broader settlement activity by IngenioSpec).
• 2025-08-28: An order was signed by District Judge Rodney Gilstrap granting a motion to further extend the stay of all deadlines.
• 2025-09-30: An order was signed by District Judge Rodney Gilstrap granting a motion to further extend the stay of all deadlines.
• 2025-10-15: An order was signed by District Judge Rodney Gilstrap dismissing the district court case (2:24-cv-00822) at the termination of the case.

IPR Proceeding (PTAB):

• 2025-09-19: Bose Corp filed IPR2025-01549 against IngenioSpec LLC challenging US Patent 11852901.
• The status of IPR2025-01549 is "resolved." While specific details of the resolution for this IPR are not immediately available, generally, IPRs can be resolved through a final written decision, a settlement, or a decision to deny institution. Given the parallel district court litigation's dismissal due to settlement, it is highly probable that the IPR was terminated due to a settlement between Bose and IngenioSpec.
• The PTAB's practice includes "Terminated-Settled" as a common outcome for IPRs.
• The USPTO has a Director Review process for IPRs, and decisions on institution can consider discretionary factors, including "settled expectations." However, without specific docket entries for IPR2025-01549 beyond its filing and "resolved" status, the exact nature of its resolution cannot be definitively stated as anything other than resolved between the parties.

In summary, while Bose initiated an IPR against IngenioSpec regarding patent 11852901, there was also an associated patent infringement lawsuit in district court. The district court case was dismissed following a settlement. The IPR proceeding is also noted as "resolved," strongly suggesting a parallel settlement of the IPR in conjunction with the district court case.

The following counsel of record represented Bose Corp. (plaintiff) in IPR2025-01549:

In-House Counsel:

• Daniel Sternberg (IP Counsel)
  • Firm: Bose Corporation (Framingham, MA)
  • Note: Mr. Sternberg is IP Counsel at Bose Corporation and represents clients in all aspects of intellectual property litigation in district court and the International Trade Commission (ITC). He has extensive experience in defending against patent infringement and enforcing such claims, along with advising on patent portfolio strategy and providing IP due diligence support.

External Counsel (likely involved, based on related district court litigation):

Attorneys from Blank Rome LLP were listed as representing Bose Corporation in a related district court case, IngenioSpec, LLC v. Bose Corporation (2:24-cv-00822), which involved the same parties and patents. It is common for the same external counsel to handle both district court litigation and related IPRs. Blank Rome LLP has a strong intellectual property practice with experience in patent litigation and inter partes reviews.

• Sean Dominic Damon (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome has handled over 400 patent infringement suits and declaratory judgment actions in the past five years and has extensive experience in inter partes review proceedings.
• Andrew R. Kopsidas (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome's intellectual property team has been lead counsel on over 100 patent lawsuits and has conducted over 35 inter partes review proceedings.
• Ameya V. Paradkar (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome's attorneys are dedicated to helping clients develop, protect, strategically manage, and maximize the value of their intellectual assets, and have successfully represented clients before the USPTO and PTAB.
• Jonathan W.S. England (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome's IP practice includes over 50 attorneys registered to practice before the USPTO, a key requirement for lead counsel in USPTO contested proceedings, and has handled more than 100 contested proceedings and 90 IPRs.
• Josh Seth Reisberg (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome offers a broad-based offering with substantial expertise in a wide range of IP matters, both contentious and non-contentious, regularly acting in patent litigation, prosecution, and transactional matters.
• Sydney Salters (Counsel)
  • Firm: Blank Rome LLP
  • Note: Blank Rome’s IP litigators seek opportunities for early resolution through understanding each client’s business objectives and are adept at handling complex patent litigation in U.S. district courts and the Federal Circuit.

Attorneys from Davidson Berquist Jackson & Gowdey LLP (now part of Rimon Law) were also listed for Bose Corporation in the related district court case, IngenioSpec, LLC v. Bose Corporation (2:24-cv-00822).

• Walter Drake Davis, Jr. (Counsel)
  • Firm: Davidson Berquist Jackson & Gowdey LLP (now Rimon Law - McLean, VA office)
  • Note: James D. Berquist, a partner from Davidson Berquist Jackson & Gowdey LLP (now Rimon Law), has been lead counsel in over 75 patent infringement litigations and has experience before the U.S. Patent and Trademark Office's Patent Trial and Appeal Board.

In the underlying patent infringement case, IngenioSpec LLC v. Bose Corporation (2:24-cv-00822), IngenioSpec LLC was represented by several attorneys. The following counsel of record appeared for IngenioSpec LLC:

• Shani M. Tutt (Lead Counsel)
  • Firm: Russ August & Kabat, Los Angeles, California.
  • Note: Ms. Tutt has appeared on behalf of IngenioSpec LLC in other related cases, such as IngenioSpec, LLC v. SAMSUNG ELECTRONICS CO., LTD. et al (2:24-cv-00819).
• Matthew D. Aichele (Counsel)
  • Firm: Russ August & Kabat, Los Angeles, California.
  • Note: Mr. Aichele has also appeared for IngenioSpec LLC in IngenioSpec, LLC v. LG Electronics Inc et al (2:24-cv-00823) and IngenioSpec, LLC v. SAMSUNG ELECTRONICS CO., LTD. et al (2:24-cv-00819).
• Daniel Benjamin Kolko (Counsel)
  • Firm: Russ August & Kabat, Los Angeles, California.
  • Note: Mr. Kolko has appeared for IngenioSpec LLC in other cases, including IngenioSpec, LLC v. LG Electronics Inc et al (2:24-cv-00823) and IngenioSpec, LLC v. SAMSUNG ELECTRONICS CO., LTD. et al (2:24-cv-00819).
• Benjamin T. Wang (Counsel)
  • Firm: Russ August & Kabat, Los Angeles, California.
  • Note: Mr. Wang has also appeared for IngenioSpec LLC in IngenioSpec, LLC v. LG Electronics Inc et al (2:24-cv-00823) and IngenioSpec, LLC v. SAMSUNG ELECTRONICS CO., LTD. et al (2:24-cv-00819).
• Michael P. Cicero (Of Counsel/Local Counsel)
  • Firm: Taylor English Duma, LLP, Atlanta, Georgia. (It is noted that Mr. Cicero is currently with Mavacy.)
  • Note: Mr. Cicero is an experienced intellectual property attorney with over 30 years in private practice, including patent litigation. He has also authored portions of the IP Litigation chapter in "Georgia Business Litigation."
• James E. Scarbrough (Of Counsel/Local Counsel)
  • Firm: Lippes Mathias LLP, Cleveland, Ohio.
  • Note: Mr. Scarbrough is the Partner-in-Charge of Lippes Mathias' Cleveland office, which resulted from a combination with Fay Sharpe LLP. He has extensive experience in patent matters, including patent prosecution, legal opinions, and litigation support, with a background in Mechanical Engineering.

While the IP Verse source lists "Ingeniospec, Llc V. Bose Corporation" and indicates legal representatives for various parties, it does not explicitly list counsel for IngenioSpec LLC in the Bose case, only for Samsung Electronics America, Inc. However, other sources confirm the appearance of the Russ August & Kabat attorneys for IngenioSpec in parallel and related Eastern District of Texas cases, which were consolidated with the Bose case. Michael P. Cicero and James E. Scarbrough also represent IngenioSpec in some of their litigation campaigns.