Litigation
Cedar Lane Technologies Inc. v. Enterprise Holdings
Patents at issue (1)
Plaintiffs (1)
Defendants (1)
Summary
Named in Stanford NPE Litigation Database entry for US 6,972,790.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
I'll research this case across docket sources, PTAB records, and patent databases.
Good initial hits. Now let me verify the docket details, judge, accused products, and any PTAB proceedings.
Case Overview — Cedar Lane Technologies, Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.)
The parties. Cedar Lane Technologies Inc. is a Canadian entity with a stated principal place of business in Nelson, British Columbia (560 Baker Street, Suite 1), and is consistently described in its own complaints as a corporation organized under Canadian law that holds acquired patents by assignment rather than as an original innovator — its Rule 7.1 disclosure statements list no parents or affiliates. Stanford's NPE Litigation Database classifies Cedar Lane as a non-practicing entity under the "acquired patents" asserter category, and the company does not appear to make or sell any product; its business is patent assertion. Its lead counsel throughout this campaign is Isaac Rabicoff of Rabicoff Law LLC, with Napoli Shkolnik listed as co-counsel on some of the November 2022 filings. Enterprise Holdings, Inc. is the privately held St. Louis–based parent of the Enterprise Rent-A-Car, National Car Rental, and Alamo Rent A Car brands — a large operating company in vehicle rental and fleet management. That makes this a classic NPE-versus-end-user configuration: the defendant is the operator of a business that uses camera-equipped devices and imaging systems, not the manufacturer of an image sensor or interface chip. (Stanford NPE DB – Cedar Lane; Stanford NPE DB – case 269217; complaint excerpt, Cedar Lane v. Alps Alpine, W.D. Wash. 2:23-cv-00001)
Patents and accused technology. U.S. Patent No. 6,972,790, "Host interface for imaging arrays" (issued Dec. 6, 2005; application filed Dec. 21, 2000; earliest priority Jan. 21, 2000), names Mark Suska as inventor and issued to Psion Teklogix Systems Inc. of Canada before traveling to Cedar Lane. In one line: it claims an interface — preferably integrated on the same die as the CMOS sensor — that buffers imaging-array data and clocking signals in a FIFO (or addressable) memory at the sensor's clock rate, then uses a signal generator to interrupt the host processor when the buffered data quantity crosses a threshold, with a circuit clocking the data out at the host's own rate, thereby eliminating external "glue logic." Representative claim 1 recites the memory, the quantity-responsive signal generator, and the host-rate transfer circuit; the specification's interrupt generator compares a FIFO counter output to a FIFO limit (col. 6). Litigation databases record the docket as asserting both the '790 and its divisional, U.S. Patent No. 8,537,242 ("Host interface for imaging arrays," issued Sept. 17, 2013, method claims reciting FIFO counting/comparison and interrupt generation); your case metadata tracks only the '790, so treat the '242 as docket-reported but worth confirming against the paper complaint. On the accused instrumentality, the public record is thin and I will not invent specifics: Cedar Lane's complaints in this campaign identify only "Exemplary Defendant Products" and incorporate by reference claim-chart exhibits that were not publicly filed, so no public document I located names the specific Enterprise systems at issue. Given that Enterprise is a rental/fleet operator rather than a chip or camera vendor, the infringement theory necessarily runs through Enterprise's use (and its employees' internal testing/use) of camera-bearing devices and imaging workflows in rental operations — damage-inspection/check-in imaging, in-vehicle cameras, handheld scanners — but which of those the claim charts actually target is not publicly sourced. (Patsnap case record 6:22-cv-01197; Patsnap patent litigation index, US6972790B2; Illinois Lawyer Now, Nov. 2022 Retail Patent Litigation Report)
Posture, venue, and why it matters. The case was filed November 17, 2022 in the Western District of Texas (Waco Division) and closed June 13, 2023 — 208 days — via a Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice, filed before Enterprise answered or moved for summary judgment, with each side bearing its own costs and fees. Litigation databases list Chief Judge Alan D. Albright as presiding; note a discrepancy: a November 2022 trade roundup covering Cedar Lane's batch of retail/rental-car suits attributes the group to Judge Reed O'Connor, so the assigned judge should be confirmed from the PACER docket rather than taken as settled. Venue mattered for the usual reasons: W.D. Tex. was the dominant NPE filing district in 2022, with a fast docket and a plaintiff-friendly posture, and Enterprise's rental locations and continuous business activity in the district made a § 1400(b) venue challenge impractical. The case is notable on four counts. First, volume: the '790 was one of Cedar Lane's workhorse assets — Patsnap's current snapshot counts 52 cases asserting it, and a Shenzhen IP Protection Center risk alert states the patent has 226 district-court case entries, against a campaign that had already named more than 150 defendants by late 2021. Second, timing and economics: the '790's estimated term ended August 1, 2023, roughly seven weeks after the dismissal, so the patent was in its final months and its value was purely backward-looking damages — consistent with the rapid, costs-each-party dismissal pattern seen across this campaign (compare the near-simultaneous dismissals of Cedar Lane's '790 suits against Snap and Raytheon). Third, no IPR linkage: patent-record databases show no recorded validity challenge to the '790, so unlike many NPE campaigns this one was not shaped by PTAB estoppel or instituted reviews. Fourth, market context: Enterprise is a repeat target for camera/imaging NPEs — it is currently a defendant in Near Field Electronics, LLC v. Enterprise Holdings, LLC, No. 4:25-cv-665 (E.D. Tex.), a 2025–26 case in which the court recently addressed the customer-suit exception — illustrating how end-user defendants in rental/fleet businesses keep absorbing imaging-patent assertions that the manufacturer-facing suits never resolved on the merits. (Patsnap case record; Cedar Lane v. Snap, D. Del. 1:22-cv-00058 docket; Cedar Lane v. Raytheon, D. Del. 1:22-cv-01628 docket; [JD Supra summary of Near Field Electronics v. Enterprise Holdings, E.D. Tex. July 31, 2026](https://www.j
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
I'll research this case systematically, starting with the core docket and patent records.
Cedar Lane Technologies, Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.)
Bottom line: This was a short-lived, single-defendant campaign case that never produced an answer, a motion, a claim construction order, or a trial. It was filed 2022-11-17 and terminated 2023-06-13 — 208 days later — by Cedar Lane's own notice of voluntary dismissal with prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i), with each side bearing its own costs and fees. The only substantive "development" is the docket bookends plus the surrounding campaign context.
Source note: The analysis below rests on litigation-database docket extracts (Patsnap, Stanford NPE database, RPX/Unified, CourtListener/RECAP) and contemporaneous trade reporting. I could not pull the W.D. Tex. PACER docket directly, so intermediate docket entries (service, extensions, any show-cause/readiness order) are unverified — see caveats at the end.
1. Filing and initial pleadings
- 2022-11-17 — Complaint filed. Cedar Lane Technologies, Inc. (Nelson, BC, Canada — an acquired-patent NPE per Stanford's database) sued Enterprise Holdings, Inc. in the Waco Division of W.D. Tex., assigned to Chief Judge Alan D. Albright. Case No. 6:22-cv-01197. Stanford NPE Litigation Database entry; Patsnap case record: https://www.patsnap.com/resources/blog/litigation/cedar-lane-technologies-v-enterprise-holdings-patent-dismissal-patsnap/
- Patents asserted: the record reflects two patents — U.S. 6,972,790 and U.S. 8,537,242, both titled "Host interface for imaging arrays" ('790 issued 2005-12-06; '242, a divisional, issued 2013-09-17). Note this is a discrepancy with the case metadata supplied to me, which lists only the '790. The two-patent pairing is the standard Cedar Lane pleading package in this campaign (compare the parallel complaints, e.g. Cedar Lane v. Alps Alpine, No. 2:23-cv-00001, https://storage.courtlistener.com/recap/gov.uscourts.wawd.[317813](/patent/317813)/gov.uscourts.wawd.317813.1.0.pdf).
- Pleading structure: counts of direct infringement (literal and DOE) with infringement charts incorporated as exhibits; the complaints in this family recite that "Exemplary Defendant Products" are identified only in the claim-chart exhibits. In the publicly available member-case filings, those exhibits were not filed publicly, so the specific accused Enterprise products are not identifiable from the public record I reviewed — I am not going to guess at them.
- Plaintiff's counsel: Isaac Rabicoff, Rabicoff Law LLC (recorded as counsel of record). The November 2022 retail-litigation report also lists Napoli Shkolnik as campaign co-counsel across the Cedar Lane wave. https://www.illinoislawyernow.com/2024/02/november-2022-retail-patent-litigation-report/
- Answer / counterclaims: none. The dismissal notice itself recites that "Defendant has not yet answered the Complaint or moved for summary judgment." So there is no answer, no invalidity/non-infringement counterclaim, and no declaratory-judgment counterclaim on this docket. That is material: no issue was joined, so nothing in this case has preclusive or estoppel effect against Cedar Lane on the '790 or '242.
2. Pre-trial motions of substance
- None. No Rule 12(b)(3) transfer motion (notable given the post-TC Heartland / In re Google venue pressure on Waco filings in 2022–23, and given that Enterprise is a Missouri-based holding company), no Rule 12(b)(6) motion, no motion to stay pending IPR, no § 101 motion, and no summary-judgment motion. The case ended before the pleadings closed.
3. Claim construction (Markman)
- None. The case was dismissed roughly seven months in, well before any Markman briefing, hearing, or order. Consequently, no court has ever construed the '790 or '242 claims in this case.
4. Discovery milestones
- None of substance on the public record. No scheduling order discovery events, no infringement/contentions exchange, no IPR estoppel-generating disclosures are recorded in the sources reviewed. Cedar Lane's dismissal came early enough that no discovery burden was imposed on Enterprise.
5. Trial, verdict, post-trial motions
- None. No trial setting, no verdict, no JMOL / new-trial / § 285 fee motion. Because dismissal was by notice (before answer), the dismissal was self-executing rather than the product of an adjudicated judgment, and there was no appealable final judgment — and no appeal was taken.
6. Final disposition
- 2023-06-13 — Voluntary dismissal with prejudice. Verbatim basis-of-termination text in the record: "Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), Plaintiff hereby dismisses this action with prejudice. Defendant has not yet answered the Complaint or moved for summary judgment. Each party shall bear its own costs, expenses, and attorneys' fees." Case closed the same day. Patsnap case record, supra.
- Present posture: closed and final; no reopened or related appellate proceeding identified. The patent itself is also inactive — the '790's estimated expiry is 2023-08-01 (earliest priority 2000-01-21, filed 2000-12-21, plus PTA), i.e., roughly seven weeks after dismissal. https://www.patsnap.com/resources/blog/litigation/patent/us6972790b2/ Practical consequence: even absent dismissal, the recoverable damages window was closing (six-year lookback plus a fast-approaching expiration), which is a strong economic explanation for a quick, quiet exit.
7. Parallel PTAB proceedings
- No IPR/PGR on the '790 or '242 is identified in the sources I reviewed, and the '790's litigation record lists "Validity challenges: None recorded." I want to be explicit about a trap here: the best-known PTAB case involving Cedar Lane as patent owner — Unified Patents, LLC v. Cedar Lane Technologies Inc., IPR2020-00006, petition filed 2019-10-03, instituted 2020-03-18, final written decision 2021-02-12 holding claims of U.S. 7,173,177 unpatentable — is not about the '790 or '242 and had no effect on this litigation. https://www.unifiedpatents.com/insights/2021/2/12/cedar-lane-patent-held-unpatentable
- Effect on the litigation: none, because no PTAB proceeding on the asserted patents was pending. Conversely, there is no § 315(e) estoppel and no PTAB claim-amendment history constraining either side going forward.
Strategic reading
- This is a "license-and-dismiss" case, not a litigated case. The dismissal with prejudice, no answer, and mutual cost-bearing is the signature of a pre-answer resolution — typically a paid license or covenant — consistent with Cedar Lane's documented pattern of filing and then dismissing within days or weeks once a defendant engages (e.g., Cedar Lane v. Snap, D. Del. 1:22-cv-00058, filed 2022-01-14 and dismissed 2022-01-25; Cedar Lane v. Drift Innovation, 1:20-cv-00766, filed 2020-06-08 and dismissed 2020-06-16).
- It was part of a coordinated November 2022 wave. The same month, Cedar Lane sued Xerox, Openeye US, Hertz, Orlando Rentco, SIXT Rent A Car, and Avis Budget Group on the same '527 / '790 / '242 trio — a car-rental/imaging-cluster targeting strategy that Enterprise, as the largest rental holding company, anchored. https://www.illinoislawyernow.com/2024/02/november-2022-retail-patent-litigation-report/
- Zero precedential value. No claim construction, no validity ruling, no damages finding. For any current or future dispute over the '790 or '242, this docket contributes nothing but timing and campaign-intelligence value — and the patent is now expired anyway.
Caveats / what to verify on PACER
- Intermediate docket entries (summons/waiver of service, any extension of the answer deadline, Judge Albright's standing-order compliance and "Notice of Readiness" entries, the exact document number of the dismissal notice, and whether a separate closing order issued beyond the 2023-06-13 notice) are not verified — I did not obtain the 6:22-cv-01197 PACER docket directly.
- The patents-asserted discrepancy ('790 alone per your metadata vs. '790 + '242 per Patsnap and the standard complaint package) should be resolved against the complaint and Dkt. 1 exhibits.
- Whether the dismissal followed a settlement payment or a bare covenant not to sue is not public; the dismissal text contains no settlement terms and the parties bore their own fees and costs.
- Judge attribution: the November 2022 retail report lists "Judge: District Judge Reed O'Connor" at the head of the Cedar Lane group, while the docket record for 6:22-cv-01197 shows Albright. Division and judge assignment in Waco in that period warrants a direct docket check.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Rabicoff Law
- Isaac P. Rabicoff · lead counsel
I'll research the counsel of record for Cedar Lane Technologies in this case.
Let me pull the specific docket for the Enterprise Holdings case (W.D. Tex. 6:22-cv-01197).
Counsel of Record — Cedar Lane Techs. Inc. v. Enterprise Holdings, Inc.
Case posture first (this matters for how thin the counsel record is): The case is Cedar Lane Technologies Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.), filed 17 Nov 2022 before Chief Judge Alan D. Albright, asserting U.S. Patent No. 6,972,790 ("Host interface for imaging arrays"). It was closed 13 June 2023 — 208 days later — on a Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice, filed before Enterprise answered or moved for summary judgment. Because the case terminated at the pleading stage, the docket contains essentially only the complaint, an appearance, and the dismissal notice; there is no substantive motion practice that generated a counsel-rich record. (Patsnap case record; Stanford NPE DB case 269217 / patent 6,972,790)
Plaintiff's counsel
| Name | Role | Firm / Office | Note |
|---|---|---|---|
| Isaac P. Rabicoff | Lead counsel (sole appearing attorney of record) | Rabicoff Law LLC, Alexandria, VA (mailing address 5680 King Centre Dr., Suite 645, Alexandria, VA 22315; firm is Chicago-rooted) | Founder/principal of a one-attorney patent-plaintiff shop; near-exclusive outside counsel to Cedar Lane, recorded as counsel in the vast majority of its 300+ suits. Handled Cedar Lane's W.D. Tex. campaign before Judge Albright. Notably sanctioned in 2020 by N.D. Cal. Judge Vince Chhabria (Cedar Lane and Rabicoff sanctioned for "objectively frivolous" positions taken in bad faith; referred to the court's Standing Committee on Professional Conduct) — see Seyfarth NPE Showcase. |
| Napoli Shkolnik PLLC | Co-counsel (reported; not verified on this docket) | Napoli Shkolnik PLLC (New York-based; national mass-tort/consumer class-action firm) | The November 2022 Retail Patent Litigation Report lists plaintiff's counsel for the Enterprise Holdings/Avis Budget/Openeye batch as "Rabicoff Law; Napoli Shkolnik." I could not confirm a Napoli Shkolnik appearance on the 6:22-cv-01197 docket itself — treat as reported, not confirmed. (Lexology, Nov. 2022 report) |
Points I could not verify — flagged rather than filled in
- Local counsel in W.D. Tex.: I found no confirmed local-counsel appearance for this specific case. In this campaign Rabicoff typically files pro hac vice and relies on local counsel; for contemporaneous Cedar Lane matters that local counsel varied by district — e.g., David W. deBruin (Delaware counsel in the D. Del. Cedar Lane cases, including Cedar Lane v. Raytheon, 1:22-cv-01628) and Philip P. Mann of Mann Law Group PLLC, Bainbridge Island, WA (W.D. Wash. local counsel in Cedar Lane v. Alps Alpine, 2:23-cv-00001, with Rabicoff "pro hac forthcoming"). I am not asserting either appeared here. (Alps Alpine complaint)
- In-house counsel: Cedar Lane's founder, Greg Benoit (a lawyer and career NPE operator), is the company's principal and effectively its in-house decision-maker, but he is not counsel of record in this case. Cedar Lane has no public website or in-house legal department that I could locate.
- Defense side: not requested, and I did not confirm Enterprise Holdings' appearances — given the pre-answer dismissal, it is unclear whether defense counsel ever entered an appearance beyond an extension.
Reliability caveat on the sourcing
Two data aggregators (Patsnap and the Stanford NPE database) are consistent that Rabicoff Law LLC / Isaac Rabicoff is plaintiff's recorded counsel for 6:22-cv-01197. However, I was not able to open the underlying PACER/CourtListener docket sheet for this case number in this session, so I cannot cite a specific docket entry (e.g., "D.I. 2 — Notice of Attorney Appearance") for Rabicoff's appearance. If a docket-entry-level citation is required for a filing or brief, the appearance entry and the 13 June 2023 dismissal notice should be pulled directly from PACER for 6:22-cv-01197 (W.D. Tex.).
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
I'll research the counsel of record for Enterprise Holdings in this case.
The docket appears to be 6:22-cv-01197 (W.D. Tex.). Let me pull the actual docket sheet.
Now let me find the actual docket sheet to see whether any defense counsel appeared.
Bottom line
Based on the records I could retrieve, no attorney appears of record for Enterprise Holdings, Inc. in this case. The case — Cedar Lane Technologies, Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.) — was filed 17 Nov 2022 and terminated 208 days later on 13 June 2023 by Cedar Lane's unilateral notice of dismissal, filed before Enterprise answered or appeared. I could not identify any defense-side attorney, firm, or office location, and I am not going to name one by inference.
| Name | Role | Firm / Office | Note |
|---|---|---|---|
| — none identified — | — | — | No defense counsel found in docket-derived records |
| Isaac Rabicoff | Plaintiff's counsel (lead) | Rabicoff Law LLC (Chicago, IL) | Sole counsel of record for Cedar Lane; files the entire Cedar Lane campaign himself |
| (Napoli Shkolnik PLLC) | Plaintiff-side co-counsel per secondary reporting | New York, NY | Listed as "Pls. Cnsl" in the Nov. 2022 Retail Patent Litigation Report; not verified on this docket |
The evidence, and why the negative finding is well grounded
1. The dismissal notice itself is the strongest indicator. The recorded termination text reads:
"Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), Plaintiff hereby dismisses this action with prejudice. Defendant has not yet answered the Complaint or moved for summary judgment. Each party shall bear its own costs, expenses, and attorneys' fees."
— Cedar Lane Techs., Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex. June 13, 2023) (notice of voluntary dismissal), as reproduced at Patsnap litigation record.
A Rule 41(a)(1)(A)(i) dismissal requires no leave of court precisely because the defendant has not yet served an answer or MSJ. The recital that Enterprise had not answered is plaintiff's own representation and is inconsistent with any substantive defense participation.
2. The counsel-of-record field for Enterprise is empty in the litigation database. Patsnap's case record lists "Counsel: Isaac Rabicoff / Firm: Rabicoff Law LLC" under Cedar Lane, and for Enterprise Holdings states "Not recorded" in the counsel field. (case record). That field is populated from docket appearances.
3. Stanford NPE Database entry for the case (No. 6:22-cv-01197, W.D. Tex., filed 17 Nov 2022) contains no defense counsel data: npe.law.stanford.edu/case/269217; patent 6972790 page.
Important caveat on verification: I was not able to pull the raw PACER/CourtListener docket sheet for 6:22-cv-01197 directly — Justia, CourtListener, and PACER-monitor mirrors did not surface a docket page for this specific case number in my searches, and the searchable secondary sources are the ones cited above. It remains possible that a defense attorney filed a notice of appearance (or an unopposed extension of time to answer) between November 2022 and June 2023 that is not reflected in the aggregated records. An extension-stipulation practice is common in Cedar Lane's cases, and in at least one later Enterprise case (below) extensions were sought by plaintiff's counsel rather than by an appearing defense firm. To confirm definitively, the docket (Dkt. entries 1 through ~10) should be pulled on PACER for W.D. Tex. case 6:22-cv-01197 — a 208-day case that ended in a pre-answer dismissal will typically have a docket of under a dozen entries.
Additional corrections / context for the case file
- Patent count discrepancy. The case metadata lists only US 6,972,790. The docket-derived records show two patents asserted: US 6,972,790 and US 8,537,242 (both "Host interface for imaging arrays"), both recorded as inactive/expired. See Patsnap '790 litigation record and Stanford NPE '242 page. The Nov. 2022 Retail Patent Litigation Report also lists 6,473,527 among the Cedar Lane patents asserted that month against the rental-car cohort (Enterprise, Hertz, Orlando Rentco, SIXT, Avis), though '527 appears with the Xerox-family defendants rather than necessarily in 6:22-cv-01197.
- Parallel defendants / likely coordinated dismissal. Enterprise was sued in the same November 2022 wave as The Hertz Corporation, Orlando Rentco LLC, SIXT Rent A Car LLC, and Avis Budget Group. The named presiding judge per the retail-litigation report was District Judge Reed O'Connor (Waco Division), while Patsnap lists Chief Judge Alan D. Albright; the W.D. Tex. case-number prefix "6:" is the Waco division, consistent with Judge O'Connor. The Cedar Lane-vs-Enterprise dismissal came roughly seven months after filing.
- Later, separate Enterprise case (not this one). Fall Line Patents, LLC v. Enterprise Holdings, Inc., No. 5:24-cv-00180 (E.D. Tex., filed Nov. 25, 2024, Judge Robert W. Schroeder III), involves Enterprise Holdings, Enterprise Rent-A-Car Company, EAN Services, and EAN Holdings, with answer extensions to Feb. 7, 2025 (Justia docket). Defense counsel names in that case would be a reasonable proxy for Enterprise's usual patent-defense roster, but they are not counsel of record in the Cedar Lane case and I did not verify their names from a reliable source; I'd recommend pulling that docket if you need Enterprise's institutional patent counsel.
Recommendation
If the question is being asked for a counsel-of-record table or damages/fee analysis, the accurate entry for this case is "no appearance; case dismissed pre-answer under Rule 41(a)(1)(A)(i)." If you need confirmation, request the PACER docket for 6:22-cv-01197 — no sealed filings are implicated (Cedar Lane's dismissals in this campaign are public), so the absence of a defense appearance should be verifiable in a handful of entries.