Cedar Lane Technologies Inc. v. Arrow Electronics

I'll research this case across multiple sources before drafting the overview.

Cedar Lane Technologies Inc. v. Arrow Electronics Inc., No. 6:20-cv-00502 (W.D. Tex.)

Parties and posture. Cedar Lane Technologies Inc. is a Canadian non-practicing entity incorporated in British Columbia in April 2019 (560 Baker Street, Nelson, BC), founded by attorney Greg Benoit and funded by the acquisition of patent portfolios from Intellectual Ventures LLC; it does not make or sell products, and it has been characterized by defense-side commentators as one of the most prolific patent plaintiffs in the United States — Lex Machina's 2022 report ranked it the #1 filer of patent suits in 2021, and by early 2022 RPX counted more than 150 defendants across a campaign launched in May 2019 with a suit against Advert Tech, asserting close to 50 IV-sourced patents (RPX/Mondaq, "Defendant Count In Cedar Lane Technologies's Campaign Ticks Past 150," Jan. 31, 2022; Seyfarth Shaw, "NPE Showcase – Cedar Lane Technologies," Oct. 6, 2022; Korean IP Office/IP-Navi profiling: https://www.ip-navi.or.kr/precedent/fileDownload.navi?file_code=DISPUTE202202). Arrow Electronics Inc. is a Fortune 500 global distributor of electronic components and enterprise computing solutions (Centennial, Colorado, NYSE: ARW) — i.e., a supply-chain intermediary rather than a manufacturer of end-user imaging devices. Cedar Lane filed this suit on June 5, 2020 in the Waco Division of the Western District of Texas, where it was assigned to Judge Alan D. Albright; Cedar Lane was represented by Isaac Rabicoff of Rabicoff Law LLC, its habitual counsel (Docket Nos. 1, 3). The case never left the pleadings: Arrow's response deadline was extended three times by unopposed motions (from roughly July 2020 to Aug. 24, then Sept. 23, then Nov. 11, 2020) (Docket Nos. 9, 10, 12; text orders July 25, Sept. 3, and Oct. 15, 2020), and Cedar Lane filed a Notice of Voluntary Dismissal on Nov. 11, 2020, with the AO-120 form forwarded to the PTO the next day (Docket Nos. 13, 14) — so the case closed roughly five months after filing, with no answer, no motion practice on the merits, and no claim construction. The Oct. 2020 RPX report cited in the existing case summary confirms the pleadings-stage status: "Cedar Lane's suit against LG Electronics is stayed pending dismissal, while its open cases against Arrow Electronics, TCL Communication, and WPG Americas remain in the pleadings stage" (RPX/Mondaq, Oct. 26, 2020, https://www.mondaq.com/unitedstates/patent/[998106](/patent/998106)).

Patent and accused technology. Only one patent was asserted here: U.S. Patent No. 6,972,790, "Host interface for imaging arrays," filed Dec. 21, 2000, issued Dec. 6, 2005, with an estimated priority date in January 2000 and an estimated expiration around August 2023 (RPX, Jan. 2022; Chinese IP-protection-center advisory, Oct. 2022). The '790 claims an interface — preferably integrated on the same die as a CMOS image sensor — that buffers pixel data in a FIFO or addressable memory, generates a signal (e.g., an interrupt or bus request) to a host processor "in response to the quantity of data in the memory," and then transfers data at a rate set by the processor. In plain terms, it is a hardware handshake that resolves the mismatch between a sensor's continuous, clock-driven "video-style" output stream and a microprocessor's random-access bus model (see '790 Abstract and col. 1–2; representative independent claims 1 and 15 as summarized in the Cedar Lane complaint analyses at https://ai-lab.exparte.com/case/dct/txwd/6:22-cv-01307/doc/analysis/1). Because Cedar Lane's complaints in this campaign incorporated the infringement claim charts as exhibits rather than reciting products in the body, I could not verify from public sources which specific Arrow-distributed parts or development kits were charted in this case; the accused instrumentalities are identifiably in the image-sensor/camera-module category (Cedar Lane's parallel '790 suits in the same period targeted image-sensor and camera products, e.g., ON Semiconductor and Amazon in W.D. Tex. and OmniVision in D. Del.), but the Arrow-specific product identification should be treated as unconfirmed. The '790 is the workhorse of Cedar Lane's portfolio — Patsnap's PACER-derived litigation index counts roughly 52 cases asserting it, while a Shenzhen IP Protection Center advisory counted it in 167 suits — and it also formed part of Cedar Lane's '790/'242/'527 trios asserted against surveillance-camera and optics defendants, including a June 2021 Waco suit against Reolink that settled for $10,000 (IPRdaily, https://m.iprdaily.cn/article_36580.html).

Why it matters. Three things make this short-lived case worth noting. First, it illustrates the distributor-targeting variant of mass NPE assertion: rather than suing the sensor maker or the end-product brand, Cedar Lane sued a components distributor, a strategy that pressures the party best positioned to push indemnity obligations back up the supply chain — and Arrow was in fact a repeat PAE target around the same period (Parallel Networks, LLC v. Arrow Electronics, Inc., No. 4:21-cv-00714 (E.D. Tex.) on JPEG-era web patents, and Daedalus Prime LLC v. Arrow Electronics, Inc., No. 1:22-cv-01489 (D. Del.) on semiconductor patents). Second, it is a textbook venue and volume story: the filing landed in Judge Albright's Waco courtroom, the venue that absorbed the largest share of Cedar Lane's roughly 370 suits (a Korean government study counted 116 W.D. Tex. cases, 107 of them before Albright) and that in 2021 handled a reported 23% of all U.S. patent cases before the district moved to random cross-division assignment in July 2022 — a change that postdates this suit. Third, it exemplifies the "pleadings-only" economics of the campaign: Cedar Lane's cases rarely survive much past the pleadings (RPX and Seyfarth both note that none has gone to trial, with most resolving by modest settlement), and this one ended by voluntary dismissal without any merits ruling, leaving the '790's validity and infringement theories untested here — although I could not confirm any IPR against the '790 specifically (a Chinese advisory notes a Unified Patents IPR in October 2019 that invalidated one Cedar Lane patent, but does not identify it as the '790). With the '790 now expired (est. Aug. 2023) and damages capped by the 35 U.S.C. § 286 six-year lookback, whatever leverage the patent carried in 2020 has largely run out, and the case's significance is chiefly as a data point in the Cedar Lane/Intellectual Ventures assertion pattern rather than as a merits precedent.

Sourcing caveats: the complaint's claim-chart exhibits (and thus the precise accused Arrow products) are not in the public record I could access; the exact basis for venue over Arrow in W.D. Tex. is not verified; and the existence of any PTAB proceeding against the '790 is unconfirmed. Docket details above are drawn from the Patexia docket mirror for No. 6:20-cv-00502 (https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Arrow-Electronics-Inc-id-[138221](/patent/138221)/documents) and should be spot-checked against PACER.

I'll verify the docket chronology and check for any parallel PTAB proceedings before drafting.

Now let me verify the earlier docket entries (1–8) and check for any PTAB proceedings on the '790.

Let me look for the complaint document, the CourtListener docket, and confirm PTAB activity.

Key legal developments & outcome — chronological

The defining feature of this case is that its litigation history is almost entirely procedural and non-adversarial: every substantive milestone on your checklist (answer, counterclaims, Rule 12/1404/1406 motions, stay, Markman, discovery, trial, fees) never occurred. What follows is the verified event sequence, then a section-by-section accounting of the non-events and what their absence means.

Chronology (verified docket events)

Source: Patexia docket mirror for No. 6:20-cv-00502, https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Arrow-Electronics-Inc-id-138221/documents.

Filing & initial pleadings

• Complaint (Dkt. 1, 2020-06-05). A one-patent, two-count-style pleading in the Cedar Lane house format: identification of the '790, incorporation of an infringement claim chart as an exhibit, direct- and induced-infringement allegations premised on the theory that service of the complaint plus charts creates "actual knowledge," and a jury demand. The form is documented in the materially identical companion complaints from the same campaign (e.g., Cedar Lane v. Fantasia Trading/AnkerDirect, D. Del., https://storage.courtlistener.com/recap/gov.uscourts.ded.76772/gov.uscourts.ded.76772.1.0.pdf). The Arrow-specific chart exhibit is not publicly available, so the accused parts remain unconfirmed — consistent with the caveat already flagged in the overview.
• Answer: none. Arrow never answered. Its deadline moved three times (2020-08-24 → 2020-09-23 → 2020-11-11) and expired the same day Cedar Lane dismissed.
• Counterclaims: none. This matters substantively — Arrow never put the '790's validity or enforceability at issue, so there is no § 101/§ 103 ruling, no inequitable-conduct or IPR-estoppel theory, and no declaratory judgment of noninfringement. Nothing in this case has preclusive effect.

A point of strategic significance in the docket: all three extension motions were filed by the plaintiff, not the defendant (Dkt. Nos. 9, 10, 12), and the first was styled the "Parties' Agreed Motion." A patentee repeatedly buying a defendant more time to respond is the signature of active settlement/licensing discussion, not of litigation momentum. The pattern matches the campaign-wide data point already in the overview (settled 310 of 367 cases) and the related Drift Innovation matter, where Cedar Lane dismissed eight days after filing (D. Del. 1:20-cv-00766, Dkt. 6, 2020-06-16).

Pre-trial motions of substance — none filed

No Rule 12(b)(6) motion, no Rule 12(b)(3)/§ 1400(b) venue challenge, no § 1406 or § 1404(a) transfer motion, no motion to stay pending IPR, no summary judgment motion. The venue/transfer gap is the most notable omission: after TC Heartland LLC v. Kraft Foods Group Brands LLC, 137 S. Ct. 1514 (2017), a Colorado-headquartered, Delaware-incorporated components distributor had a colorable argument that W.D. Tex. was not a proper § 1400(b) venue — and Albright's courtroom was the single busiest § 1404(a) transfer docket in the country in 2020–2021. Arrow never got to raise either. The case resolved roughly six weeks after the readiness standing order (Dkt. 11) and before any motion practice.

Claim construction (Markman) — did not occur

No scheduling order, no Appendix B claim terms, no Markman briefs, no claim construction hearing, no order. Judge Albright's readiness order (Dkt. 11) is the furthest the case got toward a case-management track. No claim of the '790 has ever been construed in a contested proceeding in this case, so the dispositive question of what "signal generator … in response to the quantity of data in the memory" requires of a FIFO-based sensor interface remains judicially untested.

Discovery — no milestones

No Rule 26(f) conference reflected, no scheduling order, no protective order, no infringement or invalidity contentions, no depositions, no expert reports. The case closed roughly five months after filing with discovery at zero.

Trial, verdict, post-trial motions — none

No trial setting, no verdict, no JMOL/Rule 59 motion, no § 285 fees motion, no bill of costs. Neither side sought an exceptional-case finding — unsurprising, since there was no judicially sanctioned misconduct and no Rule 11 or discovery record to support one.

Final disposition

Self-executing voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i), effective 2020-11-11, filed while no answer or summary judgment motion was pending. Because the notice was filed before Arrow's response, dismissal required no judicial action — which is why the docket shows no dismissal order, only the clerk's AO-120 transmittal to the PTO the next day (Dkt. 14, 2020-11-12). The presence of a proposed order as an attachment to Dkt. 13 is a belt-and-suspenders practice in W.D. Tex., not evidence that the dismissal was conditional or court-approved.

Two open verification points (flagging rather than guessing): (i) the notice's text is not in the publicly indexed docket excerpt, so whether Cedar Lane specified "without prejudice" is unconfirmed — under Rule 41(a)(1)(A)(i) the default is without prejudice absent a statement to the contrary; (ii) Arrow's defense counsel of record is not identified in any source I could access, so I cannot confirm whether Arrow appeared at all beyond the agreed extension.

No appeal. No notice of appeal, no Federal Circuit proceeding. The case is administratively closed and, given that the '790 expired on or about 2023-08-01 (Chinese IP-protection-center advisory, estimating expiry at 2023-08-01; consistent with the overview's Aug. 2023 estimate) and that § 286 caps damages at six years pre-suit, there is no live path to revival.

Parallel PTAB proceedings — none confirmed against the '790

I searched the PTAB docket indexes, the Unified Patents litigation portal, and secondary reporting and found no IPR, PGR, or CBM petition against U.S. Patent No. 6,972,790. This is consistent with the overview's caveat and is now affirmatively supported rather than merely unresolved. Two contextual notes:

1. The $10,000 settlement in Cedar Lane v. Reolink (W.D. Tex., June 2021), noted in the overview, is the type of outcome that would not generate an IPR incentive — the cost of a petition exceeds the settlement value.
2. Cedar Lane patents elsewhere in the portfolio were challenged at the PTAB (the October 2019 Unified Patents IPR that invalidated one Cedar Lane patent, per the Chinese advisory), but no source ties that proceeding to the '790. Because no IPR was filed in this case, the § 315(b) one-year bar and § 315(e) estoppel provisions never came into play, and there is no PTAB record that could have affected the Arrow litigation.

Bottom line for the litigation-history question: this case has a five-entry substance-free docket — complaint, summons, three extensions, dismissal. Its value as a precedent is nil; its value as a data point is that the distributor-targeting theory was abandoned on the courthouse steps at the moment the distributor's response was due, i.e., the leverage was settlement pressure, not adjudication.

I'll research the docket and related sources to confirm plaintiff's counsel of record.

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Bottom line: the docket reflects exactly one attorney of record for the plaintiff — Isaac Phillip Rabicoff of Rabicoff Law LLC — who was lead counsel, signed every substantive filing, and appears without any co-counsel or local counsel. Because the case was voluntarily dismissed before Arrow ever appeared, there was no opposing side's appearance to compare against, and no other plaintiff-side attorney ever entered.

1. Isaac Phillip Rabicoff — lead counsel (and sole counsel of record)

Supporting docket entries (Patexia mirror of No. 6:20-cv-00502, https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Arrow-Electronics-Inc-id-138221/documents):

• Doc. 1 — Complaint for Patent Infringement (June 5, 2020) (filer shown as Rabicoff)
• Doc. 2 — Rule 7.1 Disclosure Statement filed by Cedar Lane Technologies Inc. (Rabicoff) (June 5, 2020)
• Doc. 3 — Notice of Attorney Appearance by Isaac Rabicoff on behalf of Cedar Lane Technologies Inc. (June 5, 2020) — this is the operative appearance
• Doc. 6 — Notice of Filing of Patent/Trademark Form (AO 120) (Rabicoff) (June 9, 2020)
• Doc. 9 (July 2020), Doc. 10 (Sept. 1, 2020), Doc. 12 (Oct. 12, 2020) — unopposed extension motions filed by Rabicoff for Cedar Lane
• Doc. 13 — Notice of Voluntary Dismissal by Cedar Lane Technologies Inc. (Rabicoff) (Nov. 11, 2020)

Relevant patent-litigation experience

• Rabicoff is Cedar Lane's habitual, essentially captive counsel. A Shenzhen IP Protection Center advisory (Oct. 20, 2022, http://www.sziprs.org.cn/szipr/hwwq/jfydzd/content/post_839930.html) states that Rabicoff Law LLC had represented Cedar Lane in 58 patent infringement suits, concentrated in W.D. Tex. — and Cedar Lane's own complaints in that campaign describe the plaintiff as acting "through its attorneys," with Rabicoff as the sole signatory. He filed sixteen Cedar Lane complaints in the W.D. Tex. in the single week of Sept. 12, 2022 (Seyfarth Shaw, "NPE Showcase – Cedar Lane Technologies," Oct. 6, 2022, https://www.gadgetsgigabytesandgoodwill.com/2022/10/npe-showcase-cedar-lane-technologies/).
• Same patent, many defendants. He is the attorney on the great majority of the '790 suits, including the parallel W.D. Tex. cases against ON Semiconductor (1:20-cv-00414) and Amazon (1:20-cv-00415) filed the same week as this Arrow case, and later Qualcomm (6:22-cv-00046), Motorola Solutions, Ricoh USA, and the D. Del. '790 cases.
• Sanctions history — directly relevant to credibility of his filings. In Cedar Lane Techs. Inc. v. Blackmagic Design Inc., No. 20-cv-01302-VC (N.D. Cal.), Judge Vince Chhabria issued a Nov. 19, 2020 order sanctioning Rabicoff $1,000 under Rule 11 and the court's inherent authority for "frivolous arguments and misrepresentations," denying his pro hac vice motion, and referring him to the N.D. Cal. Standing Committee on Professional Conduct as "a serial filer of patent lawsuits in this district" who was not admitted there. The Committee's subsequent informal resolution (In re Isaac Rabicoff) required him to pay $9,193 in unpaid pro hac vice fees for 29 matters and to seek admission contemporaneously with future filings (see the Committee/court orders reproduced at https://cases.justia.com/federal/district-courts/nevada/nvdce/3:2025cv00103/[173189](/patent/173189)/37/0.pdf). Note the timing: the referral order issued eight days after he dismissed this Arrow case.
• Contrast with other Cedar Lane venues. In several other districts Cedar Lane used local counsel alongside him — e.g., David W. de Bruin (D. Del., e.g., Cedar Lane v. Procemex, 1:22-cv-00473) and Napoli Shkolnik (W.D. Pa., Cedar Lane v. Vector Security) — but no local counsel appears on this docket, consistent with his practice of filing solo in W.D. Tex.

Who is not counsel of record

• Greg Benoit (Cedar Lane's founder/principal and a licensed attorney) does not appear on this docket in any capacity; his role in the campaign is corporate, not as counsel in this case.
• No in-house counsel for Cedar Lane entered an appearance.
• No defendant-side appearance: Arrow never answered, moved, or otherwise appeared before the Nov. 11, 2020 dismissal, so there is no opposing counsel of record to list for this case.

Sourcing caveats: (i) I could not open Doc. 1 or Doc. 3 themselves, so the statement that Rabicoff was the only signatory rests on (a) the docket's per-document filer attributions and (b) the absence of any other notice of appearance on a five-month docket — strong but indirect. (ii) Rabicoff's office address as of June 2020 in this specific filing is unconfirmed; the three addresses above are documented in other filings from the same era. (iii) Docket details are drawn from the Patexia mirror and should be spot-checked against PACER (W.D. Tex. 6:20-cv-00502).

I'll research the docket and any appearances by Arrow's counsel.