Cedar Lane Technologies Inc. v. Enterprise Holdings, Inc.

I'll research this case thoroughly before drafting the overview.

Let me get the docket and accused-product details.

Let me try to pull the actual docket and complaint, plus IPR/validity history for the '242.

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 non-practicing entity formed around 2019 that asserts patents acquired from Intellectual Ventures–linked entities; the Stanford NPE Litigation Database classifies it as a "Non Practicing Entity" whose asserted patents fall in the "1 Acquired patents" (i.e., acquired-portfolio) category, and it is represented in this campaign by Isaac Rabicoff of Rabicoff Law LLC (the November 2022 retail-litigation roundup also lists Napoli Sholkik as co-counsel across the related filings). Seyfarth Shaw's "NPE Showcase" profiled Cedar Lane as "one of the more prolific NPEs in the patent enforcement market," noting it had filed sixteen cases in a single week in W.D. Tex. and that "none of [its] cases have reached the trial stage," with the campaign characterized as "traditional patent-based nuisance litigation designed to generate large amounts of minor settlements" (JD Supra/Seyfarth; Stanford NPE DB). 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 and the largest U.S. rental-car operator by fleet; the operating subsidiaries that typically answer these suits are EAN Holdings, LLC, EAN Services, LLC and Enterprise Rent-A-Car Company (see the related later suit, Fall Line Patents, LLC v. Enterprise Holdings, Inc., No. 5:24-cv-00180 (E.D. Tex.)). Enterprise is the operating company here — the pure defendant side of a classic PAE-versus-end-user posture.

The technology and patents. The asserted family is U.S. Patent No. 8,537,242, "Host interface for imaging arrays" (issued Sept. 17, 2013; application filed Oct. 27, 2005; inventor Mark Suska; earliest priority Jan. 21, 2000; estimated expiry Aug. 1, 2023). In one line: it claims an interface circuit — preferably integrated on the same die as the image sensor — that buffers imaging-array data in a FIFO or addressable memory to decouple the sensor's clock rate from the host processor's, and that signals the processor via an interrupt or a bus-request line when the buffer reaches a threshold. The '242 is a divisional of the application that produced U.S. Patent No. 6,972,790, same title and specification, which Cedar Lane pleaded alongside it in the parallel complaints. One important discrepancy to flag: the case metadata supplied to me lists only the '242, but PatSnap's case record for 6:22-cv-01197 reports two patents in suit — the '790 and the '242 — and every parallel Cedar Lane complaint from this campaign that I reviewed (e.g., against Alps Alpine, Zebra, Avis) pleads both (PatSnap; Avis complaint summary; Alps complaint, W.D. Wash.). Treat '242 as confirmed and '790 as probable-but-unconfirmed absent the actual PDF of the complaint.

The accused products — and where sourcing runs out. This is the weak point of the public record, and I won't paper over it. Cedar Lane's form complaint in this campaign never names products in the body; it accuses "Exemplary Defendant Products" identified only in claim-chart exhibits (typically Exhibit 4 or 6), which are behind the PACER paywall and which I could not retrieve. The '790/'242 family was asserted in this period against camera- and image-sensor-bearing hardware — Wyze cameras, Zebra handheld scanners, Qualcomm SoCs, security-camera makers (OpenEye, Silent Sentinel, Tattile, Zhuhai RaySharp) — so the logical targets at a rental-car company would be camera-equipped check-in/inspection devices or the brands' mobile apps and photo-based damage-capture workflows. That specific attribution is inference, not documented fact. What is documented is the industry sweep: Enterprise was sued on Nov. 17, 2022, in the same weeks as Sixt Rent A Car (6:22-cv-01231), Avis Budget Group (6:22-cv-01232), The Hertz Corporation and Orlando Rentco, alongside Xerox and OpenEye (November 2022 Retail Patent Litigation Report; Stanford NPE DB, '242).

Procedural posture. Filed Nov. 17, 2022 in the W.D. Tex., Waco Division (case-number prefix "6"), assigned to Chief Judge Alan D. Albright. It closed on June 13, 2023 — 208 days later — by a Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice, filed before Enterprise had answered or moved for summary judgment, with each side bearing its own costs and fees (docket text quoted verbatim in the PatSnap case record). No answer, no Markman order, no transfer ruling and no IPR appears in the record I could verify. Note a conflict in secondary sources: the retail-litigation report lists "Judge: District Judge Reed O'Connor," which is almost certainly an aggregation artifact — O'Connor sits in N.D. Tex., and PatSnap records Albright. I could not open the PACER docket directly to confirm the assignment order.

Why it matters. Three reasons. First, venue: a November 2022 W.D. Tex./Waco filing sits at the tail end of the district's dominance in patent filings under Judge Albright, and in the middle of the 2022 wave of Federal Circuit mandamus rulings reversing Albright's venue-transfer denials — a St. Louis–headquartered defendant like Enterprise had an obvious §1404(a) argument for E.D. Mo., which is

I'll research this case thoroughly across dockets, PTAB records, and legal news.

Key facts are emerging. Let me pull the actual docket and check PTAB proceedings.

Let me check the PTAB record for the '242 patent and try to access the actual docket.

Cedar Lane Technologies, Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.)

Posture at a glance

A short-lived, pleading-stage-only case. Cedar Lane filed a two-patent infringement complaint in Waco before Judge Alan D. Albright in November 2022 and voluntarily dismissed it — with prejudice — roughly seven months later, before Enterprise ever answered. There is no answer, no counterclaim, no motion practice, no Markman proceeding, no discovery of record, no trial, no appeal, and no PTAB proceeding on the asserted patent. The litigation's significance is almost entirely as a data point in Cedar Lane's mass-assertion campaign against rental-car and imaging-device defendants, not as a source of substantive patent law.

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Chronology of legal developments

2022-11-17 — Complaint filed. Cedar Lane Technologies, Inc. filed an infringement action against Enterprise Holdings, Inc. in the [U.S. District Court for the Western District of Texas, Waco Division](/courts/western-district-of-texas-waco), assigned Case No. 6:22-cv-01197 and to Chief Judge Alan D. Albright. The case was recorded as terminated 2023-06-13. (PatSnap case record; Stanford NPE Litigation Database)

Patents asserted — note a metadata discrepancy. The case metadata supplied for this analysis lists only U.S. Patent No. 8,537,242. The granular litigation databases (PatSnap, Stanford NPE Database) record two patents in this case: U.S. Patent No. 6,972,790 and U.S. Patent No. 8,537,242, both entitled "Host interface for imaging arrays." (PatSnap; Stanford) I could not retrieve the complaint itself to resolve this, so I flag it rather than pick a side. The two patents are a parent/divisional pair from inventor Mark Suska: the '790 (issued 2005-12-06) claims the apparatus — a FIFO buffer between an image sensor and a host processor that signals the processor when buffered data reaches a threshold; the '242 (issued 2013-09-17) claims the corresponding method (storing data in a FIFO, updating a FIFO counter, comparing to a FIFO limit, generating an interrupt). Both were originally prosecuted by McAndrews Held & Malloy and reached Cedar Lane via Intellectual Ventures, consistent with the rest of Cedar Lane's acquired portfolio.

2022-11 through 2023-06 — No answer, no counterclaims. Enterprise never filed an answer, counterclaim, or Rule 12 motion. This is confirmed by the dismissal notice itself, which recites that "Defendant has not yet answered the Complaint or moved for summary judgment." (PatSnap, quoting the notice verbatim) In W.D. Tex. practice, the reason is the standard Albright standing order sequence — Defendants typically obtain agreed extensions of the answer deadline while the parties negotiate, and Cedar Lane's campaign uniformly resolved cases in that window.

2023-06-13 — Voluntary dismissal with prejudice (final disposition). Cedar Lane filed a notice of voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i), dismissing the action with prejudice, with each party to bear its own costs, expenses, and attorneys' fees. Verbatim from 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." The case closed the same day, after 208 days. (PatSnap)

The with-prejudice form matters: a Rule 41(a)(1)(A)(i) dismissal is ordinarily without prejudice, but a plaintiff may specify otherwise, and Cedar Lane did. That permanently forecloses re-assertion of the '242 (and '790, if it was in fact pleaded) against Enterprise on these patents — a rational concession for a patentee whose consideration was, in all likelihood, a modest payment, and whose patent term was nearly run.

Post-dismissal — no appeal, no reopened proceedings. Nothing further was docketed; there is no Federal Circuit appeal, no Rule 54(b) or Rule 59/60 motion, and no motion for fees under § 285. Enterprise did not pursue an exceptional-case fee award, which is unsurprising given it never answered and there was no judicial finding of frivolousness.

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Stages the case never reached (negative findings)

For completeness, and because the absence of these events is itself the outcome:

• Motions to dismiss / transfer / stay pending IPR: none. Notably, no § 1404(a) transfer motion was filed, even though Enterprise is headquartered in St. Louis, Missouri, and W.D. Tex. transfer practice was active in this period.
• Claim construction (Markman): none. No scheduling order, no exchange of preliminary infringement contentions or invalidity contentions, no Markman briefs, no hearing, no claim construction order.
• Discovery: none of substance. No document production, no depositions, no expert reports, no damages discovery. The complaint's own exhibits are the only evidentiary record.
• Trial, verdict, JMOL / new trial: none.
• Settlement disclosures: any settlement amount is not public. The dismissal notice's "each party shall bear its own costs" formulation is the standard Cedar Lane template and does not disclose terms.

Sourcing caveat: free RECAP/ CourtListener coverage of this docket appears absent or incomplete, so I could not retrieve PACER docket entry numbers or the complaint PDF. The dates and the quoted dismissal language above are drawn from PatSnap's PACER-derived record, which tracks the docket but does not expose entry numbers; treat individual docket numbers as unverified.

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Parallel PTAB proceedings

None. No IPR or PGR petition was ever filed against U.S. Patent No. 8,537,242 (or the '790). PatSnap's patent-level record lists "Validity challenges: None recorded" for both patents, and no PTAB trial number exists for either. (PatSnap '242 record) The practical consequences:

1. No stay pressure and no estoppel. Enterprise had no PTAB lever to seek a § 315 stay, and Cedar Lane faced no § 315(e) estoppel risk. The patents emerged from the campaign with their claims formally intact and unadjudicated.
2. No validity precedent. Because the case died at the pleadings and no IPR followed, the '242's claims were never construed and never tested. Any party later accused on the '242 (Cedar Lane continued asserting it into 2025 in unrelated sectors) would be litigating on a blank slate.
3. Term expiry did the work an IPR might have. PatSnap estimates both patents' expiry at 2023-08-01, i.e., approximately six weeks after this dismissal. That timing is the most plausible explanation for the with-prejudice dismissal at essentially no cost: with no forward damages exposure, Enterprise had little reason to buy a license and Cedar Lane had little leverage to sell one.

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Companion and parallel litigation (campaign context)

This case was one of a synchronized November 2022 wave against car-rental companies, all filed in W.D. Tex. by Isaac Rabicoff of Rabicoff Law LLC (with Napoli Sholnik also listed on the campaign), all on the same '790/'242 pair:

Sources: PatSnap '242 litigation index; PatSnap Hertz record; Stanford NPE Database '242; Nov. 2022 Retail Patent Litigation Report. Note that the Retail Patent Litigation Report attributes the November 2022 cluster to District Judge Reed O'Connor; the case-level records place this case before Judge Albright. The report appears to aggregate several venues and may be describing a companion N.D. Tex. matter.

The broader campaign is documented in Seyfarth Shaw's NPE Showcase: Cedar Lane, a Canadian entity incorporated in 2019, filed hundreds of suits asserting IV-derived patents, has never taken a case to trial, and has drawn judicial criticism — Judge Vince Chhabria of the N.D. Cal. sanctioned Cedar Lane and Mr. Rabicoff in 2020 for positions that were "objectively frivolous" and taken in "bad faith," and referred Rabicoff to the court's standing committee on professional conduct. (JD Supra / Seyfarth) The '242 alone was asserted in 52 cases across nine districts, overwhelmingly resolved by voluntary dismissal or consent judgment. (PatSnap '242 index)

On settlement economics, a useful (if non-party) benchmark: in a parallel Cedar Lane suit on the same patent family, the Shenzhen-listed Reolink (Zhuhai RaySharp) disclosed in its 2024 IPO prospectus that it settled for US$10,000 in August 2021 in exchange for a perpetual worldwide license and withdrawal of the suit. (IPRdaily) Cedar Lane's rental-car demands were presumably calibrated in a similar range.

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Bottom line

The case produced no merits ruling of any kind. Its legal significance is procedural and structural: it illustrates the post-TC Heartland / Fintiv-era NPE playbook in which a plaintiff files in a plaintiff-friendly venue, extracts a small payment (or nothing) before an answer is due, and exits with a self-imposed with-prejudice dismissal that costs the defendant nothing and leaves the patent's validity untested. For Enterprise, the outcome was effectively a no-cost defense: no answer, no claim construction, no discovery burden, no fee award against it, and permanent repose on the '242 and '790 — reinforced by the patents' expiry on 2023-08-01, weeks after dismissal.

Open items I could not verify: the complaint's actual count structure (one patent or two); Enterprise's counsel of record; whether any payment was made; and PACER docket entry numbers. These require the PACER docket directly.

I'll research the counsel of record for Cedar Lane Technologies in this case.

Plaintiff's Counsel of Record — Cedar Lane Techs., Inc. v. Enterprise Holdings, Inc., No. 6:22-cv-01197 (W.D. Tex.)

Bottom line

The docket in this case is short — Cedar Lane filed on 17 Nov. 2022 and dismissed voluntarily (with prejudice, under Rule 41(a)(1)(A)(i)) on 13 June 2023, before Enterprise answered. Because the case died at the pleading stage, only one attorney is affirmatively recorded as counsel for Cedar Lane, and no local-counsel or second-chair appearance is confirmed in this specific docket.

Sourcing and confidence

• Rabicoff is the recorded plaintiff's counsel. Patent-data aggregators pulling from the docket state: "Isaac Rabicoff is recorded as counsel for plaintiff Cedar Lane Technologies," firm Rabicoff Law LLC (PatSnap litigation record for Case 6:22-cv-01197, https://www.patsnap.com/resources/blog/litigation/cedar-lane-technologies-v-enterprise-holdings-patent-dismissal-patsnap/).
• Firm/office at the relevant time. In the contemporaneous Cedar Lane W.D. Tex. (Waco Division) filings from the same campaign — e.g., the Cedar Lane Techs. v. Xerox dismissal papers — the signature block reads: "/s/ Isaac Rabicoff, Rabicoff Law LLC, 5680 King Centre Dr, Suite 645, Alexandria, VA 22315, 773-669-4590, isaac@rabilaw.com, Counsel for Plaintiff Cedar Lane Technologies Inc." (https://www.action-intell.com/wp-content/uploads/2023/02/Cedar-Lane-v-Xerox-dismissed.pdf). CourtListener party records for later Cedar Lane suits list the Chicago address (https://www.courtlistener.com/docket/71146609/parties/cedar-lane-technologies-inc-v-johnson-controls-international-plc/).
• Bio detail from the firm's own attorney page: http://www.rabilaw.com/rabicoff.html.

Points of caution / what I could not verify

1. Possible second firm — unconfirmed for this docket. The Lexology "November 2022 Retail Patent Litigation Report" lists plaintiff's counsel for the November 2022 Cedar Lane wave (Xerox, Openeye, Enterprise Holdings, Hertz, Orlando Rentco, SIXT, Avis Budget) as "Rabicoff Law; Napoli Shkolnik" (https://www.lexology.com/library/detail.aspx?g=d1072014-f617-4639-babd-a62707e23f61). That entry aggregates several separately filed suits, so it does not establish that a Napoli Shkolnik attorney entered an appearance in 6:22-cv-01197. I found no individual Napoli Shkolnik attorney name tied to this case number. Treat a Napoli Shkolnik appearance here as unverified.
2. No local counsel of record identified. Rabicoff's admissions (Illinois, U.S. Supreme Court, Fed. Cir., 7th Cir., E.D. Tex., N.D. Ill. Trial Bar, W.D. Wis.) do not list the Texas bar, and Cedar Lane's W.D. Tex. complaints in this period were filed with Rabicoff as the only signatory — consistent with his appearing pro hac vice/nunc pro tunc rather than through a Texas local-counsel firm. I could not retrieve the actual appearance document (Dkt. 2) for this case number to confirm whether a pro hac vice motion was ever ruled on before dismissal; note that Cedar Lane has used local counsel in other districts (e.g., Philip P. Mann, Mann Law Group PLLC, Bainbridge Island, WA, in W.D. Wash.).
3. Docket access limitation. This case number is not mirrored in the RECAP/CourtListener corpus I could reach, so I could not read the docket sheet line by line. Authoritative confirmation of appearances, pro hac vice orders, and the dismissal entry is available on PACER (W.D. Tex. CM/ECF, case 6:22-cv-01197), and no sealing order or sealed appearance is indicated in any source I found — the absence of other counsel simply reflects a 208-day case that closed before an answer.
4. Minor discrepancy (not counsel-related): the case metadata here lists only the '242 patent, while PatSnap's record for this case number lists both U.S. 6,972,790 and 8,537,242 as asserted. Per your instruction I'm treating the '242 as authoritative, but the complaint likely pleaded both.

Practical significance

Because Cedar Lane's entire W.D. Tex. docket in this era was handled out of Rabicoff's own shop with (at most) case-specific local counsel, any future correspondence, Rule 41 dismissal practice, or res judicata/claim-preclusion analysis (the dismissal here was with prejudice) runs through Rabicoff Law LLC — not through a Texas general-counsel firm. If you need a certified docket for a filing, pull it from PACER rather than relying on the aggregators cited above.

I'll research the docket and counsel of record for this case.

Key lead: the dismissal notice reportedly states the defendant "has not yet answered the Complaint." Let me verify the docket for any defense appearances.

Let me check docket aggregators that index the full docket for this specific case.

Bottom line

I could not identify any counsel of record for Enterprise Holdings, Inc. in this case — and the docket record affirmatively suggests none ever appeared.

This is not a research gap so much as a substantive finding. Two independent indicators:

1. The dismissal document itself states the defendant never responded. The case terminated on June 13, 2023, by voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i). The recorded basis-of-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." (PatSnap litigation record, case 6:22-cv-01197) A Rule 41(a)(1)(A)(i) dismissal by notice is available only before the defendant serves an answer or a motion for summary judgment — so the rule invoked is itself proof that no defense appearance had occurred.

2. The defendant's counsel field is empty in the litigation database. The same PatSnap record lists the plaintiff's counsel (Isaac Rabicoff, Rabicoff Law LLC) but shows Enterprise Holdings' counsel as "Not recorded." Cedar Lane's own counsel appearance is the only attorney entry reflected.

Counsel roster for Enterprise Holdings

No lead counsel, local counsel, of counsel, or in-house attorney can be named for the defense without fabrication. I also found no firm website, Law360/Reuters report, or court opinion in which any attorney publicly claimed representation of Enterprise Holdings in this matter.

What I could verify about the plaintiff's side (for contrast)

• Isaac Phillip Rabicoff, Rabicoff Law LLC (Chicago, IL) — sole plaintiff's counsel of record; filed the complaint (Nov. 17, 2022) and the Rule 41 notice. Rabicoff is Cedar Lane's near-exclusive litigation counsel (roughly 58 Cedar Lane cases per one 2023 analysis) and was sanctioned in 2020 by Judge Vince Chhabria in N.D. Cal. for "objectively frivolous" positions taken in bad faith and referred to that district's Standing Committee on Professional Conduct (Seyfarth NPE Showcase). The November 2022 retail litigation report also lists Napoli Shkolnik alongside Rabicoff Law as plaintiff's counsel across the Cedar Lane rent-a-car wave (Lexology).

Caveats and discrepancies worth flagging

• Venue/judge discrepancy: PatSnap records the presiding judge as Alan D. Albright (W.D. Tex., Waco), while the November 2022 Retail Patent Litigation Report attributes the Cedar Lane rent-a-car cluster to Judge Reed O'Connor. The report appears to aggregate several Cedar Lane suits loosely; treat the Albright assignment as more likely but unconfirmed.
• Patent-count discrepancy: PatSnap records two patents asserted (US 6,972,790 and US 8,537,242), whereas the case metadata supplied to me lists only the '242. The '790 and '242 are sibling "Host interface for imaging arrays" patents, and Cedar Lane routinely pleaded them together in this campaign.
• One related firm data point, expressly not attributed to this case: John T. Moehringer (bio at ca.hlc.com) lists Cedar Lane defenses for Qualcomm and Brother International — including a complete dismissal in Cedar Lane v. Qualcomm (W.D. Tex.). That is a useful comparator for how this campaign was defended elsewhere, but nothing in the record places him or his firm on this docket, and I am not imputing it here.
• Verification path: The definitive check is the PACER docket for W.D. Tex. 6:22-cv-01197 (Albright). Given the Rule 41(a)(1)(A)(i) recital, I would expect a docket of roughly a dozen entries — complaint, Rabicoff appearance, Rule 7 disclosure, summons, AO 120 form, and the notice of dismissal — with no defense-side filings. If a firm did advise Enterprise behind the scenes, that engagement would be non-public (settlement/pre-suit counseling) and is not recoverable from the docket.