Litigation

Cedar Lane Technologies Inc. v. Hanwha Techwin America

settled

2:22-cv-05091

Court
D.N.J.
Filed
2022-08-17
Terminated
2023-03-22

Patents at issue (2)

Summary

KIPO NPE report ties this D.N.J. Cedar Lane Technologies Inc. suit to US 6,473,527 and reports settlement on 2023-03-22; IPWatchdog separately lists this docket as Hanwha Techwin America and as asserting only 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 and the parties/patents involved before writing.

Good initial findings. Let me dig into the patents themselves and the IPR/litigation campaign context.

Let me verify the asserted patents from the complaint itself and check for IPR activity on these specific patents.

Overview and Background

The parties. Plaintiff Cedar Lane Technologies Inc. is a Canadian patent-assertion entity incorporated in 2019 with a stated principal place of business in Nelson, British Columbia (560 Baker Street, Suite 1) — the address recited in its boilerplate complaints in this campaign (see, e.g., Cedar Lane v. Alps Alpine N. Am., W.D. Wash. No. 2:23-cv-00001, Compl. ¶ 2). It does not make or sell products; Stanford's NPE litigation database classifies it as a non-practicing entity asserting only acquired patents (NPE Database). A Chinese IP-protection-center risk alert on this exact campaign reports that Cedar Lane held roughly 193 U.S. patents, 191 of them acquired, and that it had filed on the order of 325 U.S. district court suits, making it (per Lex Machina data cited there) the most frequent patent plaintiff in the U.S. in 2021; it also identifies Cedar Lane's founder as Greg Benoit, a lawyer with NPE-litigation experience (Shenzhen IP Protection Center alert). Cedar Lane's counsel of record here was David W. deBruin of Gawthrop Greenwood, PC (the same Delaware/New Jersey local counsel it used in dozens of dockets); its most frequent national counsel in this period was Isaac Rabicoff of Rabicoff Law LLC (CourtListener). Defendant Hanwha Techwin America, Inc. is the U.S. sales and support subsidiary of Korea's Hanwha Techwin Co., Ltd. (formerly Samsung Techwin, acquired by Hanwha Group in 2015), a major manufacturer of Wisenet network and analog video-surveillance cameras, NVRs, and VMS software (Hanwha case study). Hanwha was represented by Jones Day, which publicly describes the case as one in which it "successfully represented" Hanwha and "secur[ed] … an early victory" (Jones Day experience page).

The accused technology and the patents. The accused instrumentalities are Hanwha's security-camera and imaging products — the complaint used Cedar Lane's standard-form "Exemplary Defendant Products" placeholder tied to external claim charts rather than naming models in the narrative. Jones Day characterizes the asserted patents as "generally related to image processing technology and JPEG compression," which maps to Cedar Lane's standard three-patent imaging-interface package. U.S. Patent No. 6,473,527, "Module and method for interfacing analog/digital converting means and JPEG compression means" (inventor Wang Chia-Ying; originally Mustek Systems Inc., Taiwan; filed June 1, 1999; issued Oct. 29, 2002), claims a buffer sized to hold a few image lines so 8×8 pixel blocks can be fed directly into a JPEG compressor's built-in memory, eliminating an external frame buffer; claim 1 is drafted in means-plus-function form ("read control means," "memory means," "output control means"). U.S. Patent No. 6,972,790, "Host interface for imaging arrays" (inventor Mark Suska; originally Psion Teklogix Systems Inc., Mississauga, Canada; filed Dec. 21, 2000; issued Dec. 6, 2005; priority to provisional 60/177,496 of Jan. 21, 2000), claims an interface — preferably on the same die as the CMOS sensor — with a FIFO/addressable buffer that asserts an interrupt or bus-request signal "in response to the quantity of data in the memory" and then transfers data at the host processor's rate (see the PTO Official Gazette abstract and claim 1, US 6,972,790 B2). The '242 patent in the same family, U.S. Patent No. 8,537,242 ("Host interface for imaging arrays," issued Sept. 17, 2013, a divisional filed Oct. 27, 2005), is a near-duplicate disclosure and was asserted alongside the other two in virtually every Cedar Lane complaint of this era (see the Lexology November 2022 Retail Patent Litigation Report, listing "'527; '790; '242" for the parallel Xerox/OpenEye/Enterprise/Hertz/Sixt/Avis complaints). Notably, the '527 patent's term expired June 1, 2019 and the '790 patent's term is recorded as expiring August 1, 2023, so by filing date these were end-of-life assets supporting only a pre-expiration damages window (bounded further by 35 U.S.C. § 286's six-year lookback).

Posture, venue, and why it matters. Cedar Lane filed in the District of New Jersey on August 17, 2022 (D.N.J. No. 2:22-cv-05091), initially before Judge Esther Salas and Magistrate Judge Leda D. Wettre; on October 3, 2022 the case was reassigned by Chief Judge Wolfson to District Judge John Michael Vazquez with Magistrate Judge Jose R. Almonte (Justia docket). Hanwha was not served until February 24, 2023 (Dkt. 5), with answer due March 17, 2023; a stipulated extension to April 17, 2023 was sought on March 13, 2023 (Dkt. 6) and granted the same day (Dkt. 7); Cedar Lane then filed a notice of voluntary dismissal without prejudice on March 20, 2023 (Dkt. 8), and Judge Vazquez signed the order of dismissal on March 22, 2023 (Dkt. 9) — ending the case roughly seven months after filing and about a month after service (Patexia docket). The venue was essentially "follow the defendant": after TC Heartland, Cedar Lane filed where the accused U.S. seller was established, and D.N.J. became one of its favored forums (compare Cedar Lane v. ZKTeco USA, 2:23-cv-01693, and Cedar Lane v. Leica Camera, 2:23-cv-01322, both D.N.J.). The case is notable less for doctrinal content — no claim construction, no

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

I'll research the docket, the dismissal mechanics, and any PTAB activity on the two asserted patents.

Now let me check PTAB proceedings on the three patents, plus the broader campaign's invalidity history.

Key legal developments and outcome

Bottom line

This docket produced no merits ruling of any kind. It is a pure "plead-and-fold" file: complaint filed, service delayed roughly six months, one extension motion, and a plaintiff-initiated voluntary dismissal under Rule 41(a)(1)(A)(i) before any defendant response. There is no answer, no counterclaim, no Rule 12 motion, no transfer motion, no stay motion, no scheduling order, no discovery, no Markman, no summary judgment, no trial, no fee motion, and no appeal. The legal significance is therefore almost entirely (a) in the dismissal mechanics and their preclusive effect (none), and (b) in what the absence of activity tells us about the defense posture and the economics of Cedar Lane's end-of-life patent campaign.

Chronology of substantive events

Date Event Docket / source
2022-08-17 Complaint filed (jury demand), with 11 attachments — six numbered exhibits plus corporate disclosure, civil cover sheet, patent report, appearance of counsel, summons Dkt. 1 (Patexia)
2022-08-22 Case assigned to Judge Esther Salas / M.J. Leda D. Wettre docket minute entry
2022-08-26 Summons issued; AO120 patent/trademark report filed (Dkt. 2) Dkt. 2, 3 (Justia)
2022-10-03 Reassigned to Judge John Michael Vazquez / M.J. Jose R. Almonte by Chief Judge Wolfson Dkt. 4
2023-02-24 Hanwha served; answer due 2023-03-17 Dkt. 5 (entered 2023-02-27)
2023-03-13 Plaintiff moves for (and obtains) extension of Hanwha's response deadline to 2023-04-17 Dkt. 6, 7
2023-03-20 Plaintiff files notice of voluntary dismissal without prejudice Dkt. 8
2023-03-22 Judge Vazquez signs Order of Voluntary Dismissal without prejudice; case terminated Dkt. 9

Pleadings stage. There was no responsive pleading. Because Hanwha never answered, it also never pleaded invalidity, never filed counterclaims, and never triggered the 35 U.S.C. § 315(b) one-year IPR bar. Cedar Lane's complaint followed its template exactly: "Exemplary Defendant Products" defined by reference to chart exhibits rather than models named in the narrative, and no claim-by-claim identification of asserted claims (Compl. ¶¶ 12, 21 in the materially identical sister complaints). The Dkt. 1 attachment list — six numbered exhibits — is consistent with three patent copies plus three corresponding claim charts; that reading is an inference from the parallel complaints rather than something I could confirm from the public docket text.

Pre-trial motions of substance: none. The only motion on the docket is Dkt. 6, and it is procedurally odd in a way worth flagging: it was filed by the plaintiff, styled as a "First MOTION for Extension of Time to File Answer, Move, or otherwise Respond to Plaintiff's Complaint" — i.e., Cedar Lane moved to extend its adversary's deadline. That is the classic signature of a case in settlement/standstill negotiation: the plaintiff wants to keep the defendant's response (and any Rule 12 or transfer motion) off the docket while paperwork is finalized. The magistrate granted it the same day (Dkt. 7). I could not locate the motion's supporting papers, so the settlement-standstill characterization is an inference, not a documented fact. Notably, no motion to dismiss, no § 1404(a)/§ 1406 transfer motion, and no motion to stay pending PTAB review was ever filed — Hanwha never had to litigate venue in D.N.J., even though a Korean-parent/U.S.-subsidiary structure would have supported a TC Heartland / convenience challenge.

Claim construction: none. No Markman scheduling order, no joint claim construction statement, no hearing. This matters because the '527 patent's claim 1 is drafted in means-plus-function form ("read control means," "memory means," "output control means"), and the § 112(f) structural-scope question (whether the disclosed "read control device 22"/memory 24 arrangement in Fig. 2 reaches modern integrated SoC architectures) was the case's most obvious dispositive battleground. It was never teed up.

Discovery: none. No Rule 26(f) conference, no Rule 16 scheduling order, no initial disclosures, no infringement or invalidity contentions, no ESI protocol or protective order. Cedar Lane obtained nothing from Hanwha; Hanwha produced nothing.

Trial, verdict, post-trial motions: none. No JMOL, no new trial motion, no Rule 54(d)/§ 285 fee motion, no bill of costs. Nothing was awarded to either side on the public record; I could not verify from the docket text whether the dismissal order allocated costs.

Disposition and its actual legal effect

Cedar Lane dismissed under Rule 41(a)(1)(A)(i) — a unilateral notice filed before Hanwha served an answer or moved for summary judgment. The dismissal was without prejudice (Dkt. 8, 9). Three consequences:

  1. No preclusion. Hanwha obtained no judgment on the merits, so nothing prevents Cedar Lane from re-suing on the same patents. Jones Day's characterization of this as an "early victory" (Jones Day experience page) is a defense-side win in the practical sense — zero discovery, zero claim construction, zero payment — not a merits adjudication. Jones Day's own write-up attributes the dismissal to "quickly developing several key defenses" and says the asserted patents were "three patents generally related to image processing technology and JPEG compression."
  2. The re-filing option was essentially worthless. The '527 patent expired 2019-06-01 — before this suit was filed — so its only value was a § 286 six-year lookback window (2016-08-17 to 2019-06-01). The '790 patent and its '242 divisional both carried a recorded expiry of 2023-08-01. Any re-filed case would have captured at most a few months of post-dismissal damages. In substance the without-prejudice dismissal was close to a final walk-away.
  3. No appellate or review path. The case is terminated and no appeal was taken; the dismissal is not reviewable at Hanwha's behest anyway, since it got the relief it wanted.

Parallel PTAB proceedings on the asserted patents

This is a negative finding, and I want to be explicit about the limits of my search. Across PTAB/P-TACTS-adjacent sources, Docket Alarm, and patent-level litigation records, I found no IPR, PGR, or CBM proceeding on U.S. 6,473,527, 6,972,790, or 8,537,242 — neither pending nor instituted, and no final written decision. Patent-level records for the '790 list "Validity challenges: None recorded" (Patsnap case record) despite the '242 having been asserted in roughly 217 district court cases and the '527 in roughly 124 (per the Shenzhen IP Protection Center's patent tables, risk alert). That asymmetry is itself the analytically interesting point: the campaign's defendants overwhelmingly chose cheap settlement or early dismissal over PTAB challenge, almost certainly because the asserted patents were expiring and the per-case settlement value was below the cost of a petition. No stay motion was ever possible here for the same reason — there was no petition to stay for.

Because no IPR existed, the litigation never faced the Fintiv/§ 315 discretionary-denial dynamics that dominate most 2022–2023 NPE dockets, and Cedar Lane never faced the estoppel or amendment pressure that a PTAB challenge would have created.

Campaign context: the dismissal was part of a synchronized March 2023 wave

Read against Cedar Lane's other dockets, Dkt. 8 looks less like a Hanwha-specific capitulation and more like a portfolio-wide shutdown timed to the '790/'242 expiry:

  • Cedar Lane v. Renesas Elecs., W.D. Tex. 6:22-cv-01031 — '790 and '242 asserted; voluntarily dismissed 2023-03-09.
  • Cedar Lane v. Hertz Global Holdings, W.D. Tex. 6:22-cv-01216 (one of the seven complaints in the November 2022 wave listed by the Lexology Retail Patent Litigation Report) — dismissed (with prejudice per the filed notice) 2023-03-29.
  • Cedar Lane v. ZKTeco USA, D.N.J. 2:23-cv-01693 — voluntary dismissal 41 days out, 2023.
  • Cedar Lane v. Leica Camera, D.N.J. 2:23-cv-01322 — dismissed 42 days out, 2023.

Hanwha's 2023-03-22 dismissal sits inside that cluster. The campaign-level settlement record is consistent: the Shenzhen center's data showed nine concluded Shenzhen-defendant cases, all settled, median 77 days, and the broader Patsnap docket table for this technology class shows outcomes dominated by voluntary dismissal and consent judgment rather than adjudication.

Contradictions with the case metadata I am flagging

  1. Number of patents asserted. The metadata lists two patents ('527, '790), and prior sections of this summary relied on an IPWatchdog listing that named only the '790. The contemporaneous Korean IP Protection Center / KOTRA record for this exact case number lists three patents — "US6473527 | US6972790 | US8537242" ([KOTRA record](https://dream.kotra.or.kr/dream/cms/link/actionBoard

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Bottom line: the docket shows exactly one attorney who appeared for the plaintiff — David W. deBruin of Gawthrop Greenwood, PC. He signed the complaint, every subsequent plaintiff-side filing, and the voluntary dismissal. No pro hac vice motion, notice of appearance, or admission of additional counsel ever appears on this nine-entry docket, even though Cedar Lane's form complaints from this period typically named Isaac Rabicoff (Rabicoff Law LLC) as national counsel "pro hac vice forthcoming." Whether Rabicoff was named in the signature block of this complaint is something I could not verify — see the caveat below.

Attorney table

# Attorney Role in this case Firm / office Experience note
1 David W. deBruin Lead (and only) counsel of record; ECF filing attorney for plaintiff Gawthrop Greenwood, PC — 3711 Kennett Pike, Suite 100, Wilmington, DE 19807 (tel. 302-777-5353); firm also has a West Chester, PA office The signature attorney on hundreds of Cedar Lane complaints and Rule 41 dismissals filed 2021–2023 in D. Del., D.N.J., W.D. Tex., E.D.N.Y. and elsewhere; CourtListener's party records in parallel Cedar Lane suits list him as "LEAD ATTORNEY" for the plaintiff
2 Isaac Rabicoff (not of record here) Presumptive national/lead counsel in Cedar Lane's campaign — no appearance, PHV motion, or docket entry in this case Rabicoff Law LLC — 5680 King Centre Dr., Suite 645, Alexandria, VA 22315 Filed the volume of Cedar Lane's Texas/New York suits personally and appeared pro hac vice; sanctioned $1,000 and referred to the N.D. Cal. Standing Committee in Cedar Lane v. Blackmagic Design (N.D. Cal. No. 20-cv-01302-VC); publicly reprimanded by the Virginia State Bar (Dec. 2022). None of that occurred in this docket.

Docket support for deBruin as counsel of record

Every plaintiff-side filing is attributed to him:

  • Dkt. 1 (Aug. 17, 2022) — Complaint, filed "(DEBRUIN, DAVID)"; attachments included Exhibit 10, "Appearance of Counsel" (Justia docket; UniCourt).
  • Dkt. 5 (Feb. 27, 2023) — Summons Returned Executed (service 2/24/2023) (DEBRUIN, DAVID).
  • Dkt. 6 (Mar. 13, 2023) — First Motion for Extension of Time to Answer (DEBRUIN, DAVID); granted at Dkt. 7.
  • Dkt. 8 (Mar. 20, 2023) — Notice of Voluntary Dismissal Without Prejudice (DEBRUIN, DAVID); order at Dkt. 9 (Mar. 22, 2023) (Patexia docket).
  • UniCourt's party/attorney block lists a single "Plaintiff Attorney: DAVID W. DEBRUIN."

His standard signature block in the parallel Cedar Lane matters is: "GAWTHROP GREENWOOD, PC /s/ David W. deBruin — David W. deBruin (No. 4846), 3711 Kennett Pike, Suite 100, Wilmington, DE 19807, (302) 777-5353, ddebruin@gawthrop.com, Counsel for Plaintiff Cedar Lane Technologies Inc." (see, e.g., D. Del. C.A. No. 1:21-cv-01428-RGA, D.I. 7 and D.I. 11, CourtListener RECAP). CourtListener's docket for Cedar Lane v. Snap Inc. (D. Del. 1:22-cv-00058) lists him with that same Wilmington address and flags him "LEAD ATTORNEY" (parties page).

Caveats and negative findings (stated expressly)

  1. No second appearance in this docket. The case has only nine docket entries, and none is a notice of appearance, pro hac vice motion, or application for admission of out-of-state counsel. D.N.J. L. Civ. R. 101.1(d) would have required a PHV application (with local counsel) for Rabicoff to appear; none was filed before dismissal.
  2. Rabicoff's status here is inferential, not documented. Cedar Lane complaints of this vintage carry his name in the signature block as "Pro hac vice application forthcoming" — confirmed, for example, in the D. Del. Cedar Lane v. Philips Electronics N.A. complaint (RPX document) and in W.D. Tex. filings he signed himself (e.g., Cedar Lane v. Xerox, No. 6:22-cv-01153-ADA, Notice of Voluntary Dismissal dated Feb. 9, 2023). I could not retrieve the Hanwha complaint PDF itself to confirm whether his name appears on it, so treat that as unverified. What is verified is that he never entered an appearance in D.N.J. No. 2:22-cv-05091.
  3. Bar admissions. DeBruin's Delaware bar number (No. 4846) is documented in his Delaware filings. I did not find a confirmed New Jersey attorney ID or a Gawthrop Greenwood attorney bio page confirming his New Jersey admission in the sources reviewed; his D.N.J. filings in this and sister cases would be consistent with either N.J. admission or local-counsel arrangement, so I am not asserting a specific N.J. bar number.
  4. Nothing sealed. All nine entries are public; there are no sealed filings or sealed appearances in this docket.
  5. Adverse counsel (for completeness, not the question asked): Jones Day represented Hanwha Techwin America and publicly describes obtaining the voluntary dismissal (Jones Day experience page). Individual Jones Day attorneys do not appear on the D.N.J. docket because Hanwha never filed an answer or appearance before dismissal (Dkt. 9), so I cannot name them without inventing facts.

Practical read: the appearance record is thin because the case died in seven months — deBruin was the only attorney ever "of record," and the case closed on a Rule 41(a)(1) notice before any pro hac vice admission (and thus before any second counsel) was needed.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

I'll research the defendant's counsel of record through the docket, firm announcements, and related filings.

The docket appears to show only plaintiff-side filings. Let me check the full docket and the extension motion for defense counsel's appearance.

Counsel of record for Hanwha Techwin America — findings

Bottom line: there is no attorney appearance docketed for the defendant in this case. The public docket reflects filings only by plaintiff's counsel, and no notice of appearance, pro hac vice motion, corporate disclosure statement, answer, or motion to dismiss was ever filed on Hanwha's behalf before the case was dismissed. Representation can therefore be established only at the firm level — Jones Day — not by named attorney, on the record available.

What the docket actually shows

Dkt. Date Filing Filer (per docket)
1 8/17/2022 Complaint + exhibits David W. deBruin (Cedar Lane)
2–3 8/26/2022 AO120 form; summons issued Clerk
4 10/3/2022 Reassignment to Judge Vazquez / M.J. Almonte Clerk
5 2/27/2023 Summons returned executed (served 2/24/2023) deBruin
6 3/13/2023 "First MOTION for Extension of Time to File Answer … until and including … April 17, 2023" deBruin (plaintiff)
7 3/13/2023 Order granting Dkt. 6 M.J. Almonte
8 3/20/2023 Notice of voluntary dismissal without prejudice deBruin
9 3/22/2023 Order of voluntary dismissal Judge Vazquez

Sources: Justia docket; Patexia docket/documents; UniCourt.

Two docket details are worth flagging for the counsel question:

  1. Docket 6 is docketed as filed by Cedar Lane, not by Hanwha. Cedar Lane's standard practice in this campaign was to file the agreed extension itself in advance of any defense appearance (compare its Rule 41(a)(1)(A)(i) notice in Cedar Lane v. Konica Minolta, W.D. Tex. No. 6:22-cv-01074, signed by Isaac Rabicoff as "Counsel for Plaintiff," stating "Defendant has not yet answered the Complaint" — filed copy). That is consistent with an agreed extension negotiated with unidentified defense counsel, but the docket entry itself names no defense attorney.
  2. No defense counsel appeared because none had to. The dismissal came under Rule 41(a)(1)(A)(i) in the pre-answer window (the answer deadline had been pushed to 4/17/2023 and the notice was filed 3/20/2023), which is precisely the posture in which a defendant's counsel can litigate, negotiate, and obtain a walk-away without ever entering an appearance.

The firm: Jones Day (confirmed), client: Hanwha Techwin Co., Ltd.

Jones Day's own experience entry lists the client as Hanwha Techwin Co., Ltd. and states that "Jones Day successfully represented defendant Hanwha Techwin America, Inc. ('Hanwha'), a manufacturer of security cameras, in a patent litigation matter in the District of New Jersey," that plaintiff "asserted infringement of three patents generally related to image processing technology and JPEG compression," and that "[a]fter quickly developing several key defenses, Plaintiff voluntarily dismissed the case" (Jones Day experience page). Note two things about that page: it is a firm-level case description with no attributed lawyers, and it independently corroborates the three-patent reading of the case ('527, '790, and '242) against the IPWatchdog listing that named only the '790 — a point already flagged in the earlier overview.

Why I am not naming individual attorneys

The available public sources do not identify any Jones Day lawyer on this matter, and I will not infer one:

  • No appearance on the docket by any individual, so there is no attorney signature block to cite. (Justia's docket was last retrieved 10/3/2022; Patexia captures the docket through the 3/22/2023 dismissal order and likewise shows only deBruin's filings.)
  • The Jones Day page omits the team. Jones Day's practice-experience entries sometimes carry a "Lawyers" listing; this one, as indexed, does not.
  • No court opinion, Law360 appearance report, or Reuters Legal piece surfaced tying a named Jones Day attorney to 2:22-cv-05091.

I did not locate a PACER-stamped copy of Dkt. 6 or its attachments. That motion — and specifically any attached stipulation or Rule 7.1/101.1 disclosure, plus the transmittal email or certification of conferral — is the single most likely place a defense counsel name would appear, and it should be pulled from PACER directly (D.N.J. 2:22-cv-05091, Dkts. 6 and 6-1 through 6-3) before any name is reported.

Two practical notes if you need the name

  • Local-counsel gap. D.N.J. Local Civil Rule 101.1(c) requires a member of the court's bar to appear as local counsel for any out-of-state attorney, and Jones Day has no New Jersey office (its closest offices to Trenton are New York and Philadelphia). Had the case proceeded past the pleading stage, a New Jersey local-counsel appearance would have been expected. None was ever docketed — another marker of how early this case ended.
  • Adjacent Hanwha matters are not a substitute. Names appearing in other Hanwha litigations (e.g., the Maxeon v. Hanwha Solutions and Water Street Capital v. Hanwha Q Cells dockets) are different entities, different counsel, and different subject matter; none of those appearances should be attributed to this case.

Recommended verification path, in order: (1) PACER docket for 2:22-cv-05091, full entry text for Dkts. 6 and 6-1 to 6-3 and any "Notice of Appearance" that may have been filed and later withdrawn or unindexed; (2) Jones Day's New York/Philadelphia IP practice pages and attorney bios for security-camera/imaging work; (3) Law360/Reuters appearance lines from March 2023. Until then, the defensible statement is: Hanwha Techwin America was represented by Jones Day (firm-level), with no individual attorney of record appearing on the docket.