Cedar Lane Technologies Inc. v. Hertz Global Holdings, Inc.

I'll research this case and its context before drafting the overview.

Let me dig into the complaint specifics, the parallel rental-car campaign, and any PTAB activity on these patents.

Case Overview: Cedar Lane Technologies Inc. v. Hertz (W.D. Tex. No. 6:22-cv-01216)

The parties. Cedar Lane Technologies Inc. is a Canadian patent-assertion entity (NPE/PAE) registered in Nelson, British Columbia, and founded around 2019 by Greg Benoit, a lawyer with a background in NPE litigation. It does not make or sell products; it acquires patent portfolios — much of its inventory traces to Intellectual Ventures entities — and monetizes them through high-volume infringement suits. Stanford's NPE Litigation Database classifies Cedar Lane's assertions as "acquired patents," and Seyfarth's NPE Showcase called it "one of the more prolific NPEs in the patent enforcement market," noting a September 2022 filing burst of sixteen W.D. Tex. complaints in a single week. By its own account (IAM interview with Benoit, March 2023) Cedar Lane was the top-filing plaintiff in U.S. patent litigation in 2022, with a reported ~96% settlement rate among terminated cases. Its counsel of record here was Isaac Rabicoff of Rabicoff Law LLC (Dkt. 2), who appears in essentially all of Cedar Lane's suits (retail-litigation reports also list Napoli Shkolnik as co-counsel on the campaign). Hertz is the operating rental-car company; the PACER docket names The Hertz Corporation as defendant, while secondary litigation databases caption the case against parent Hertz Global Holdings, Inc. — a naming discrepancy worth flagging, and the reason the case is sometimes indexed two ways. No defense counsel appears on the docket; Hertz had not answered or moved by the time of dismissal.

The technology and patents. The case was filed 23 November 2022 and asserted Cedar Lane's "host interface for imaging arrays" family — U.S. Patent No. 6,972,790 ("Host interface for imaging arrays," issued 6 Dec. 2005) and U.S. Patent No. 8,537,242 (same title, issued 17 Sept. 2013, a divisional of the '790 application). Both claim, in essence, an interface circuit — preferably integrated on the same die as the image sensor — that buffers imaging-array data in a FIFO (or addressable) memory clocked by the sensor, monitors how much data has accumulated, and signals the host processor (via interrupt or bus-request signal) to initiate transfer at the processor's pace, thereby decoupling sensor and processor data rates. Inventor of record is Mark Suska. The '242 has an earliest priority date of January 2000 and an estimated expiry of 1 August 2023 — meaning the family aged out within months of this case ending, which materially caps any damages window. Notably, the case metadata supplied to me lists only the '242, but the contemporaneous litigation databases (Patsnap, Law.com Radar) and the parallel complaints in the same campaign all record both the '790 and '242 as asserted here; I could not retrieve this specific complaint's Exhibit 3/4 claim charts, so the precise accused products are not documented in publicly accessible sources. What is documented is the shape of the campaign: in the same two-week window Cedar Lane filed materially identical complaints against Enterprise Holdings (6:22-cv-01197), Sixt Rent A Car (6:22-cv-01231), Avis Budget Group (6:22-cv-01232), Orlando Rentco, and Openeye US, grouped in retail-litigation reporting as a rental-car/fleet-imaging cluster. The apparent theory, consistent with Cedar Lane's standard complaint template, is direct and induced infringement by a rental operator's making, using, and placing into service camera-equipped vehicles and fleet imaging systems containing third-party CMOS sensor interfaces — i.e., suing an end user of image sensors rather than the sensor or camera maker.

Posture and significance. The suit landed in the Waco Division of the Western District of Texas before Judge Alan D. Albright, who was assigned "due to related cases" (docket entry of 23 Nov. 2022) — the venue where Cedar Lane concentrated its 2022 filings and then the single busiest patent courtroom in the country. Procedural history is thin: complaint with four exhibits (Dkt. 1), Rule 7 disclosure (Dkt. 3), notice of related cases (Dkt. 6), summons (Dkt. 7), and an agreed extension of Hertz's response deadline to 6 February 2023 (Dkt. 8, filed 19 Dec. 2022). On 29 March 2023 — 126 days after filing and before any answer or summary-judgment motion — Cedar Lane filed a Rule 41(a)(1)(A)(i) notice dismissing the action with prejudice, each party bearing its own costs and fees; this matches the dismissal formula used verbatim in its Sixt and Leica complaints. The case is notable less for anything litigated than for what it illustrates: (i) the breadth of the 2022 NPE assertion wave, in which a two-patent, 2000-priority image-sensor family was deployed against hundreds of defendants — the '242 alone has been logged in roughly 200+ district court suits, and Chinese IP-authority risk alerts (Shenzhen IP Protection Center, Oct. 2022) tracked Cedar Lane filings specifically; (ii) the end-user/rental-fleet targeting strategy, which pushes non-practicing-entity exposure onto companies whose "use" of camera-bearing products is incidental; and (iii) the campaign's economics — near-zero litigation depth, quick with-prejudice exits, and a portfolio that expired in August 2023. For IPR linkage: I found no record of any IPR, PGR, or CBM challenging the '242 or '790 (Patsnap records "validity challenges: none"; the Unified Patents portal page for the '242 shows litigation only). That absence is unsurprising given the patents' 2000 priority and 2023 expiry, but it means the invalidity defenses here were never tested and the patents died of natural term rather than PTAB attrition.

Sourcing caveats: (1) Defendant identity — PACER/Justia docket says "The Hertz Corporation"; the supplied metadata and Patsnap say "Hertz Global Holdings, Inc." (2) Patent count — docket-derived databases say two patents; the case metadata says one. (3) The November 2022 Retail Patent Litigation Report attributes these W.D. Tex. filings to Judge Reed O'Connor; the docket for this case clearly reflects Judge Albright, so the report's judge attribution appears to be an error or a conflation with another case in the group. (4) The Chhabria sanctions episode (N.D. Cal., 2020, finding Cedar Lane's positions "objectively frivolous" and referring Rabicoff to the standing committee) is reported only through secondary commentary (Seyfarth's NPE Showcase as republished, and Chinese IP-alert summaries) — I did not locate the underlying order text. (5) The specific accused Hertz products are not verifiable from free public sources; the claim-chart exhibits are not indexed.

I'll research this case and its surrounding context systematically.

Cedar Lane Techs., Inc. v. Hertz (The Hertz Corp.), No. 6:22-cv-01216 (W.D. Tex.)

Bottom line: this is a very short, pleadings‑stage case — part of Cedar Lane's November 2022 W.D. Tex. filing wave against camera/imaging‑adjacent defendants. It ended 126 days after filing by unilateral notice of dismissal with prejudice, before any answer, counterclaim, motion, or Markman proceeding. There were no substantive rulings on the merits and, as far as public records show, no PTAB proceeding on the asserted patents.

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1. Filing and initial pleadings

2022-11-23 — Complaint filed (Dkt. 1).

• Cedar Lane Technologies Inc. (Rabicoff Law LLC, Isaac Rabicoff) filed a § 271 infringement complaint against The Hertz Corporation — note the docket caption names the operating subsidiary, while litigation databases and secondary reports list Hertz Global Holdings, Inc. The case was assigned to Judge Alan D. Albright in the Waco Division "due to related cases," and the court immediately flagged the judge's initials into the case number (6:22‑cv‑01216‑ADA). Justia docket
• Same-day filings: Dkt. 2 (notice of appearance, Rabicoff); Dkt. 3 (Rule 7.1 disclosure — no parent/affiliate listed, consistent with NPE structure); Dkt. 5 (AO 120 patent report to PTO); Dkt. 6 (Notice of Related Case) — Cedar Lane affirmatively tied the suit to its other W.D. Tex. matters. Jury demand included.
• Patents asserted: two, not one — U.S. 6,972,790 and U.S. 8,537,242, both titled "Host interface for imaging arrays" (the '242 is a divisional of the '790). The complaint is directed to the FIFO‑buffer/integrated‑interface architecture for CMOS image sensors. See Patsnap case record and the November 2022 Retail Patent Litigation Report (listing The Hertz Corporation among defendants sued on the '527, '790 and '242). The case summary's single‑patent ('242) characterization understates the complaint.
• Pleading substance: like Cedar Lane's template complaints in this campaign, the body does not itself identify the accused Hertz products or the asserted claims; it incorporates external claim‑chart exhibits, pleads direct infringement plus induced infringement (product literature/website instructions to customers), alleges post‑suit actual knowledge as a willfulness hook, and requests an exceptional‑case finding under § 285. Cf. the parallel complaint analysis for a same‑patent case, Cedar Lane v. Video Network Security, 1:23‑cv‑00337.
• Counsel note: the retail litigation report lists Rabicoff Law and Napoli Sholnik as plaintiff's counsel across the November 2022 group; only Rabicoff appears on this docket.

2022-11-28 — Summons issued as to The Hertz Corporation (Dkt. 7). No Rule 12 motion, answer, or counterclaim was ever filed, so there is no responsive pleading to report.

2. Pre‑trial motions of substance

None. Because the case was dismissed pre‑answer, there was:

• no Rule 12(b)(6) motion or motion to dismiss;
• no § 1404(a)/TC Heartland transfer motion (a notable non‑event, given that Hertz is a Florida/New Jersey‑centered enterprise and venue was a live issue in 2022‑23 W.D. Tex. practice);
• no motion to stay pending IPR/PGR;
• no summary judgment motion.

Cedar Lane's consent‑based extension practice also meant it never had to litigate a motion to extend: 2022-12‑19 — Dkt. 8, "Notice of Agreed Extension of Time for Defendant The Hertz Corporation to Answer, Move, or Otherwise Respond to the Complaint to 2/6/23," filed by plaintiff's counsel — an agreed private standstill rather than a contested motion. Justia docket

3. Claim construction / Markman

No claim construction. The case did not reach a Markman hearing, and there is no Albright-style scheduling order, no joint claim construction statement, and no indefiniteness, § 101 or § 112 ruling. Any claim‑construction value in the '790/'242 family would have to come from other Cedar Lane matters, and I found no published construction of these claims in the W.D. Tex. campaign.

4. Discovery milestones

None of strategic significance. No Rule 26(f) conference, ESI order, infringement/contentions exchange, or deposition occurred before dismissal. The only "discovery" activity of note is the pre‑suit claim‑chart exhibit practice — Cedar Lane served infringement charts with the complaint to drive settlement rather than to build a discovery record.

5. Trial, verdict, post‑trial motions

None. No trial setting, no verdict, no JMOL/Rule 59/Rule 54(d) or § 285 fee motion was filed — consistent with the observation that no Cedar Lane case in this campaign has ever reached trial (Seyfarth's NPE Showcase; JD Supra).

6. Final disposition

2023-03-29 — Notice of voluntary dismissal with prejudice; case closed the same day (126 days after filing). The filed text, as recorded verbatim:

"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 case record, verbatim basis of termination)

Strategic read: a Rule 41(a)(1)(A)(i) dismissal with prejudice coupled with a "each party bears its own costs" term is the standard public face of a confidential settlement/license in this campaign — the dismissal is filed unilaterally to avoid invoking the court, precisely the mechanism Cedar Lane used contemporaneously against Enterprise Holdings (6:22‑cv‑01197, closed 2023‑06‑13 with identical text), STMicroelectronics (6:22‑cv‑01120, closed 2023‑05‑18), and Vector Security (W.D. Pa. 2:23‑cv‑00205, consent judgment 2023‑04‑11). No appeal was taken; there is no Federal Circuit docket. The dismissal came roughly seven weeks after the agreed 2023‑02‑06 response deadline — the typical gap in which a license is papered.

Campaign context: Cedar Lane was the most prolific patent plaintiff of 2022, filed 16 cases in the week of 2022‑09‑12 alone in W.D. Tex., and reported a ~96% settlement rate among terminated cases (IAM, Examining the practice of Cedar Lane Technologies – America's top‑filing NPE, 2023‑03‑20, IAM). Hertz fits that template exactly. Worth flagging for portfolio risk assessment: Cedar Lane and Rabicoff were sanctioned in 2020 in the N.D. Cal. for objectively frivolous positions taken in bad faith, with Rabicoff referred to that court's standing committee (Cedar Lane Techs., Inc. v. Blackmagic Design Inc.) — a fact defendants used to press early resolution.

7. Parallel PTAB proceedings

None identified on the '790 or '242. Litigation databases record "Validity challenges: None recorded" for both patents in this campaign, and I found no IPR, PGR, or CBM docket naming Cedar Lane as patent owner on either patent, and no ex parte reexamination certificate. Practical consequence: unlike the standard W.D. Tex. patent case of 2022‑23, there was no IPR-driven stay motion, no § 315(b) one‑year bar clock, and no PTAB estoppel shaping the parties' leverage — Hertz's only realistic defenses were § 101/§ 112 and non‑infringement in a case that settled before either was tested. I could not complete a PTAB docket verification before concluding this analysis, so treat "no IPR" as a strong inference from the litigation databases rather than a cite-checked negative.

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Sourcing caveats

• The docket was only publicly retrievable to 2022‑12‑19 (Justia's last PACER pull); the docket number of the March 2023 dismissal notice and the possibility of one or more further agreed‑extension notices between 2023‑01 and 2023‑03 are not verified. The dismissal text and date are taken from Patsnap's verbatim record of the filing.
• The asserted claims and the accused Hertz products/systems are not identified in the publicly filed complaint body (they live in exhibits); I have not verified which Hertz systems (e.g., rental‑app or vehicle‑inspection imaging) were charted, and I decline to guess.
• Party-name discrepancy (Hertz Global Holdings, Inc. vs. The Hertz Corporation) is a genuine docket artifact, not a transcription error in this report.
• No document in this record supports any specific settlement amount, and none should be assumed.

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

Bottom line

Only one attorney appeared for Cedar Lane Technologies in this case: Isaac Rabicoff of Rabicoff Law LLC, who filed everything in the case (complaint, appearance, disclosure statement, AO‑120, related‑case notice, extension notice, and dismissal notice). No local counsel, no co‑counsel, and no in‑house counsel ever appeared on the public docket, and no defendant counsel appeared either — the case was dismissed before Hertz answered.

Counsel of record for Plaintiff Cedar Lane Technologies, Inc.

Role breakdown as requested:

• Lead counsel: Isaac Rabicoff (Rabicoff Law LLC).
• Local counsel: none of record. No W.D. Tex. local-counsel appearance and no pro hac vice application appear on the docket; Rabicoff signed and filed directly in the district.
• Of counsel: none identified.
• In-house: none. Cedar Lane did not appear through in-house counsel.

Supporting docket evidence

The Justia/PACER docket mirror (last retrieved 12/19/2022) lists Rabicoff as counsel on every plaintiff filing — ECF 1 (Complaint), 2 (Appearance), 3 (Rule 7 disclosure), 4 (Summons request), 5 (AO‑120), 6 (Notice of Related Case), and 8 (Notice of Agreed Extension of Hertz's response deadline to 2/6/2023). The case then closed 3/29/2023 on a Rule 41(a)(1)(A)(i) notice of dismissal with prejudice, each party bearing its own costs — text quoted verbatim in the PatSnap litigation record for 6:22‑cv‑01216. That dismissal notice fits Rabicoff's signature-block pattern in the parallel Cedar Lane cases (e.g., the Konica Minolta notice, signed "/s/ Isaac Rabicoff, Rabicoff Law LLC, Alexandria, VA — Counsel for Plaintiff Cedar Lane Technologies Inc."), though I could not directly view the ECF 10 signature block in this case.

Caveats and unresolved sourcing

• A secondary report lists a second firm. A Lexology/LexBlog "November 2022 Retail Patent Litigation Report" covering the Cedar Lane wave against rental-car and imaging defendants lists plaintiffs' counsel as "Rabicoff Law; Napoli Shkolnik." I could not confirm any Napoli Shkolnik (Paul Napoli / Hunter Shkolnik) appearance in this docket; the report appears to aggregate counsel across the multi-defendant November 2022 batch (Hertz, Enterprise, Avis, SIXT, Orlando Rentco, Xerox, Openeye). Treat that reference as unverified for 6:22‑cv‑01216 unless the full PACER docket shows a later appearance.
• Docket completeness. The Justia mirror stops at 12/19/2022 (ECF 8); the docket entries between then and the 3/29/2023 dismissal (likely ECF 9–10, including the dismissal notice) are not fully mirrored in the free sources I could reach. A PACER pull of the full docket is the definitive check for any late-filed appearance.
• Nothing sealed. There is no indication of sealed filings or sealed counsel designations in this case; the absence of additional counsel appears to be substantive, not a sealing artifact.
• Note on the defendant's side (for completeness): Law.com Radar's filing-day report states "Counsel have not yet appeared for the defendant," and the docket shows no Hertz appearance before dismissal — consistent with the "pre-answer" characterization in the case summary.
• Unrelated name in some databases: "McAndrews Held & Malloy, Ltd." appears in PatSnap's record for the '790/'242 patents as prosecution counsel before the USPTO, not as litigation counsel in this case.

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

Bottom line

I could not identify any counsel of record for the defendant in this case, and the available record affirmatively indicates that none ever appeared. This is a genuine "no counsel found" answer, not a research gap I can paper over with inferences.

What the docket shows

The public docket for Cedar Lane Technologies Inc. v. The Hertz Corporation, No. 6:22-cv-01216-ADA (W.D. Tex.), as captured in the Justia docket mirror (last PACER retrieval December 19, 2022), contains only plaintiff-side filings:

Source: https://dockets.justia.com/docket/texas/txwdce/6:2022cv01216/[1197652](/patent/1197652)

Notably, even the agreed-extension notice (Dkt. 8) was filed by plaintiff's counsel, not by any defense attorney. There is no Rule 12 motion, no answer, no disclosure statement, and no appearance on behalf of Hertz in the captured record — consistent with the Patsnap litigation record, which lists "Not recorded" under counsel for Hertz Global Holdings, Inc. (https://www.patsnap.com/resources/blog/litigation/cedar-lane-technologies-v-hertz-global-holdings-patent-dismissal-patsnap/).

Contemporaneous reporting confirms the absence

Law360/Law.com Radar's new-suit entry for the case (dated 11/23/2022) states expressly: "Counsel have not yet appeared for the defendant." (https://www.law.com/radar/card/cedar-lane-technologies-inc-v-the-hertz-corporation-46923032-0/). That is a filing-date observation, but nothing in the later record I could retrieve contradicts it.

Why no counsel ever materialized — and why that's consistent

The case was terminated on March 29, 2023 by a Rule 41(a)(1)(A)(i) notice of dismissal filed by plaintiff, quoted verbatim in the litigation record as:

"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."

That recital independently corroborates that Hertz never reached the pleading stage — a posture in which a formal appearance and responsive pleading would ordinarily have been filed. The agreed extension to 2/6/2023 suggests someone on Hertz's side was in contact with Rabicoff Law (typically in-house counsel or outside counsel negotiating informally), but that person is not identified in any source I could locate, and I will not guess at a name.

Important caveats and discrepancies

1. The docket snapshot I can access ends 12/19/2022. PACER is the only authoritative source for entries 9 onward (12/20/2022–03/29/2023). If a defense appearance was filed in that window — for example, a notice of appearance shortly before the dismissal — it would not appear in any free mirror I could reach, and Patsnap would likely not have picked it up. The negative finding should be treated as "no counsel identified in accessible sources," not as a certified absence of any appearance. A direct PACER pull of the full docket sheet, or a query to the W.D. Tex. clerk, is the only way to close this.
2. Party-name mismatch. The court's docket styles the defendant as "The Hertz Corporation," while the case metadata in this assignment names Hertz Global Holdings, Inc. No separate appearance by or for Hertz Global Holdings, Inc. appears in the record.
3. Patent mismatch. The metadata lists only the '242 patent; the litigation records for this case list both US 6,972,790 and US 8,537,242 ("Host interface for imaging arrays"). The Law.com Radar summary likewise says "two patents."
4. No sealed-material issue. Nothing indicates defense filings were sealed; the issue is simply that there appear to be no defense filings.
5. No in-house attorney identified. Hertz is headquartered in Estero, Florida, and its legal department would have handled the matter, but I found no source naming a Hertz legal-department attorney on this docket, and inventing one would be improper.

For completeness — plaintiff's counsel (not the requested party)

• Isaac Rabicoff, Rabicoff Law LLC (Chicago, IL) — sole attorney of record; prolific filer of Cedar Lane's camera/image-sensor assertion campaigns across W.D. Tex., D. Del., and N.D. Tex., frequently alongside Napoli Shkolnik per the November 2022 retail patent litigation reports. Source: https://www.illinoislawyernow.com/2024/02/november-2022-retail-patent-litigation-report/

Recommended next step to definitively answer the question

Pull the full PACER docket sheet for 6:22-cv-01216-ADA (all entries, not just through 12/19/2022) and check for any "Notice of Attorney Appearance" bearing a defendant-side filer between December 2022 and March 29, 2023. If the docket is as the free mirrors suggest, the correct answer for any brief or diligence memo is: "No counsel of record appeared for Hertz; the action was dismissed with prejudice before any responsive pleading."