Litigation
Cedar Lane Technologies Inc. v. (Korean defendant "B", large corp.)
Settled6:22-cv-01410
- Court
- D. Del.
- Filed
- 2022-10-26
- Terminated
- 2022-11-29
Patents at issue (1)
Plaintiffs (1)
Summary
Korean-defendant case from KIPO-published table; defendant anonymized as 'B', large corp.
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 to verify the parties, patent, and procedural details.
Let me dig into the specific docket number and identify the defendant.
Let me verify the defendant identification and the docket details.
Case Overview — Cedar Lane Technologies Inc. v. Boston Dynamics, Inc. (D. Del.)
Parties. Plaintiff Cedar Lane Technologies Inc. is a Canadian non-practicing entity (NPE/PAE) formed in British Columbia on April 29, 2019, with attorney Greg Benoit as director and a business address corresponding to IP-licensing firm Pigott & Co.; it acquired a portfolio of roughly 180 patents — largely former Intellectual Ventures assets routed through Steephill Technologies LLC — and has monetized them through mass infringement filings, almost always with Isaac Rabicoff of Rabicoff Law as counsel and David W. deBruin as Delaware local counsel (Justia docket; RPX via Mondaq; Seyfarth NPE Showcase). The defendant, recorded in the case metadata as a large Korean corporation anonymized as "B," is identified on the public docket as Boston Dynamics, Inc., the Waltham, Massachusetts robotics company (Spot, Atlas, Stretch) that has been majority-owned by Korea's Hyundai Motor Group since its June 2021 acquisition — consistent with KIPO/KOTRA-style tables classifying the defendant by Korean parentage, and with Cedar Lane's documented pattern of suing Korean imaging and camera companies (LG Electronics, Vieworks, Cravis, IDIS America, Hanwha Techwin America) (MoneyS, Aug. 2022). Caveat: the "Korean large corp" characterization is metadata; the docket itself names a U.S.-incorporated Hyundai subsidiary, not a Korean entity.
Accused technology and patents. The complaint (D.I. 1, filed Oct. 26, 2022, jury demand) asserts U.S. Patent No. 6,972,790 ("Host interface for imaging arrays," filed Dec. 21, 2000, issued Dec. 6, 2005, inventor Mark Suska) and, per the AO-120 report to the Commissioner, also U.S. Patent No. 8,537,242 (same title, application filed Oct. 27, 2005, issued Sept. 17, 2013 — a later member of the same family) (Justia docket, D.I. 3; IPWatchdog roundup, Nov. 3, 2022). The '790 patent claims, in one line, an interface — preferably on the same die as a CMOS image sensor — with a memory (typically a FIFO) that buffers imaging-array data and the sensor's clocking signals at the sensor clock rate, a signal generator that asserts an interrupt or bus-request to the host processor when the buffered data reaches a threshold, and a transfer circuit that drains the memory at the host's own rate, thereby decoupling sensor and processor timing without glue logic (see the patent's abstract and claim 1 as reproduced in the parallel Cedar Lane complaints, e.g., Cedar Lane v. Alps Alpine, W.D. Wash.; Patsnap patent record). The specific accused Boston Dynamics products are identified only in the claim-chart exhibits (Exs. 1–4 to D.I. 1), which I could not retrieve; in the dozens of cookie-cutter complaints from the same campaign the allegations target camera/imaging products built on integrated CMOS sensor interfaces, and the '790 patent's estimated term expired around Aug. 1, 2023, closing the damages window.
Posture, venue, and significance. Filed in the U.S. District Court for the District of Delaware, Wilmington, and assigned to Judge Richard G. Andrews (the judge handling a large share of Cedar Lane's Delaware docket), the case was terminated roughly five weeks later on Nov. 29, 2022 — the same trajectory as its siblings filed that day, which were dismissed under Rule 41(a)(1)(A)(i) without prejudice before any answer (compare Cedar Lane v. Autel Robotics, 1:22-cv-01411, dismissed Nov. 2, 2022, and Cedar Lane v. Video Network Security, 1:22-cv-01405). Two data notes: the metadata's docket number 6:22-cv-01410 carries the W.D. Tex. Waco division prefix, while the Delaware docket is 1:22-cv-01410 (filed the same day, Oct. 26, 2022, as the ~13-case Delaware batch 1:22-cv-01402 through -01414, alongside a parallel W.D. Tex. batch); and the metadata lists only the '790 patent although the docket's Patent Office report lists both '790 and '242. The case matters less as a merits dispute than as a data point in the most prolific patent-assertion campaign of the period: per Lex Machina's 2024 report Cedar Lane filed more patent suits than any other plaintiff in 2021–2023, and Korea's IP Protection Agency (KIPO/KOIPA) counted about 275 Cedar Lane suits by mid-2022, with the '527/'790/'242 trio accounting for 179 (65%) of them and 134 of those closed by voluntary dismissal (MoneyS). It is also a clean illustration of (i) Delaware's role as the default NPE venue after the W.D. Tex. filing surge, (ii) the "sue-and-settle" pattern Seyfarth describes — no Cedar Lane case has reached trial, and the campaign has drawn sanctions findings (N.D. Cal. Judge Vince Chhabria, Oct. 2020, sanctioning Cedar Lane and Rabicoff for frivolous positions and referring Rabicoff to the court's professional-conduct committee), and (iii) the lack of PTAB check: I found no IPR petition against the '790 patent in the available databases, so validity was never tested administratively before the patent expired.
Sourcing caveats: The defendant identity, filing date, judge, and asserted patents are verified from the Justia docket extract and IPWatchdog's filing table. The Nov. 29, 2022 termination date comes from your metadata — the public docket extract I retrieved was last updated Oct. 26, 2022, so I could not independently confirm the dismissal order or its terms, though the sister cases in the same batch were all dismissed by notice within days to weeks. The identity of the accused Boston Dynamics products is not verified.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
I'll research this case and the asserted patent across the sources you named.
Bottom line first
This was not a litigated patent case. It was a one-month, pre-answer, high-volume NPE filing that ended in voluntary dismissal before the defendant ever appeared. There is no answer, no Rule 12 motion, no transfer/stay motion, no Markman, no discovery, no summary judgment, no trial, no fees motion, and no appeal. Any chronology you build for this docket will be almost entirely front-loaded onto a single day (2022-10-26) and a single closing event (~2022-11-29).
Case identification — two caveats you should know about
1. The docket number/party match. The metadata gives the case as 6:22-cv-01410 in D. Del. Those two things are inconsistent: D. Del. uses a 1: prefix; 6: is the Waco division prefix in W.D. Tex., where Cedar Lane actually filed most of this campaign (Rabicoff Law). The docket that matches the number 01410, the filing date 2022-10-26, the court D. Del., and the '790 patent is:
Cedar Lane Technologies Inc. v. Boston Dynamics, Inc., No. 1:22-cv-01410 (D. Del., filed 2022-10-26), assigned to Judge Richard G. Andrews.
Docket: https://dockets.justia.com/docket/delaware/dedce/1:2022cv01410/80515
2. The "Korean defendant B" label. Boston Dynamics is a Massachusetts company, but since June 2021 it has been majority-owned by Korea's Hyundai Motor Group — which is the most plausible way a KIPO-derived table would capture it as a Korean-affiliated "large corp." defendant beginning with "B." I could not independently verify the KIPO table entry, so treat the "B = Boston Dynamics" identification as inferred, not confirmed. If your table's "B" is instead a Korean manufacturer (e.g., a Waco-division defendant), that would be a different docket, and the analysis below about this filing's structure would still hold, but the defendant identity would need re-checking.
Everything below is about No. 1:22-cv-01410 (Boston Dynamics).
Chronological developments
2022-10-26 — Complaint filed (Doc. 1)
Cedar Lane Technologies Inc. (Nelson, B.C., Canada) filed a jury-demanded § 271 complaint against Boston Dynamics, Inc., with two patents pleaded:
- U.S. 6,972,790 ("Host interface for imaging arrays"), issued 2005-12-06 from an application filed 2000-12-21;
- U.S. 8,537,242 ("Host interface for imaging arrays"), issued 2013-09-17, a divisional of the '790 application.
Your metadata lists only the '790; the docket itself lists both '790 and '242 (Doc. 3, the § 290/AO 120 report to the Commissioner, names both). That matters: the '242 is a divisional, so both patents stand or fall on the same priority/specification, and Cedar Lane routinely pleaded them as a pair.
Same-day ministerial filings:
- Doc. 2 — Notice, Consent and Referral forms re magistrate-judge jurisdiction.
- Doc. 3 — Report to the Commissioner of Patents and Trademarks (6,972,790; 8,537,242).
- Doc. 4 — Rule 7.1 Disclosure Statement: no parent/affiliate.
- Doc. 5 — Summons issued as to Boston Dynamics.
- Notice of appearance of David W. deBruin filed with the complaint.
Substance of the pleading: the usual Cedar Lane template, not a product-specific analysis. The complaint asserts "one or more claims" and incorporates infringement theories by reference to claim-chart exhibits rather than pleading elements in the body. Representative independent claim 1 of the '790 recites an image-sensor interface comprising a memory clocked by the sensor, a signal generator responsive to the quantity of data in the memory, and a circuit transferring data at the processor's rate. The '242 claims the corresponding method (FIFO counter vs. FIFO limit → interrupt). Damages theory was generic "damages adequate to compensate," with no specific royalty model pleaded.
Immediately after filing — case assignment
Assigned to Judge Richard G. Andrews (RGA) as part of the same-day batch of Cedar Lane Delaware filings (Cedar Lane's D. Del. wave that day ran at least 1:22-cv-01402 through 1:22-cv-01423, including Vantage Robotics (01406), Teal Drones (01407), Skydio (01408), Brinc Drones (01409), Boston Dynamics (01410), Autel Robotics (01411), Adesso (01413), and Security Camera Warehouse (01414)). See IPWatchdog's Patent Filings Roundup, 2022-11-03: https://ipwatchdog.com/2022/11/03/patent-filings-roundup-old-ip-edge-filings-explode-no-new-discretionary-denials-fortress-backed-divx-rolls/
2022-11 (during) — No answer, no counterclaims, no motions
The retrieved docket shows no answer, no counterclaims, no extension motion, no Rule 12(b) motion, and — notably — no summons returned executed. The case was resolved before the defendant's appearance or answer deadline. There is therefore no defensive pleading record, no invalidity contentions, no non-infringement contentions, and no § 101/§ 112 challenge on this docket.
2022-11-29 — Termination by dismissal (per case metadata)
The case is recorded as terminated 2022-11-29 — 34 days after filing — in the "Settled" posture your metadata describes. This is the signature of a pre-answer, confidential nuisance-value resolution followed by a plaintiff-side voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A), with the customary § 290 report to the PTO.
Sourcing caveat: I was able to confirm the filing date, judge, parties, patents, and the Doc. 1–5 docket entries, but I did not retrieve the dismissal docket entry itself (the Justia docket snapshot was last pulled 2022-10-26). The 2022-11-29 termination date and "settled" characterization come from your case metadata, and are consistent with the docket's silence on any appearance. If you need the dismissal document number and whether it was with or without prejudice, that requires a direct PACER pull of the D. Del. docket.
What did not happen (and why that is the analytically important part)
| Stage | Status |
|---|---|
| Answer / counterclaims | None — defendant never appeared |
| Motion to dismiss (Rule 12(b)(2)/(3)/(6)) | None |
| Motion to transfer venue | None |
| Motion to stay pending IPR | None — no IPR existed to stay for |
| Markman / claim construction | Never reached; no scheduling order, no JCCS, no Phillips briefs |
| Discovery (incl. ESI, source code, damages) | Zero — no Rule 26(f) conference, no Rule 26(a)(1) disclosures, no contention interrogatories |
| Summary judgment (incl. § 101) | None |
| Trial / verdict | None |
| Post-trial (JMOL, new trial, § 285 fees) | None |
| Appeal to the Federal Circuit | None |
Parallel PTAB proceedings
I found no IPR, PGR, or CBM petition against U.S. 6,972,790 in searching PTAB/PTAB-tracking and litigation coverage. This is consistent with the broader pattern: the '790 was asserted in roughly 52 district court cases (see the Patsnap litigation index: https://www.patsnap.com/resources/blog/litigation/patent/us6972790b2/ and Stanford NPE Litigation Database: https://npe.law.stanford.edu/patent/6972790), yet the campaign generated essentially no institution-stage PTAB validity testing, because defendants had no economic reason to spend $300k+ on an IPR when cases resolved in weeks for less.
Effect on this litigation: nil. Had a petition been filed, it would necessarily have been filed after this case closed, and § 315(b) would never have been triggered as to Boston Dynamics.
Strategic read
- This docket is a data point in a volume campaign, not a dispute. Cedar Lane acquired the '790 (and its Psion Teklogix-lineage family) from Intellectual Ventures in May 2019 and used Rabicoff Law / Napoli Shkolnik (later deBruin Law) to file hundreds of complaints. Commentators noted already in October 2022 that "Cedar Lane does not appear to take their cases much past the pleadings stage and seems to have little appetite for protracted litigation… conventional patent-based nuisance litigation designed to generate a large quantity of modest settlements." See NPE Showcase – Cedar Lane Technologies, 2022-10-04: https://www.mondaq.com/unitedstates/patent/[1237392](/patent/1237392)/npe-showcase-cedar-lane-technologies
- The 34-day lifecycle is the outcome. For a defendant like Boston Dynamics, the cheapest correct play was a quick low-value license; the file bears no trace of a merits defense because none was mounted.
- The claim charts were never adjudicated. Because the complaint pleaded infringement only "by reference" to exhibits and nothing was ever tested, this case produced no claim-construction, validity, or damages precedent for the '790. It has essentially zero precedential value; its only value is as a marker of the campaign's pricing and speed.
- Reputational overlay. Cedar Lane and its counsel had been sanctioned in 2020 by Judge Vince Chhabria (N.D. Cal.) for objectively frivolous positions taken in bad faith, with a referral to the N.D. Cal. Standing Committee on Professional Conduct — relevant background to how these filings were received, though it played no role on this docket.
If you need this airtight
Three items remain unverified and should be pulled from PACER directly: (a) the dismissal entry (date, document number, with/without prejudice, any confidentiality provision) on No. 1:22-cv-01410-RGA; (b) whether a license/consent judgment rather than a bare Rule 41 dismissal was entered — the sibling D. Del. matters
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Gawthrop Greenwood
- David W. deBruin · lead counsel
I'll start by researching the case docket and Cedar Lane's counsel.
Key finding: D. Del. 1:22-cv-01410 is Cedar Lane v. Boston Dynamics ('790 patent). Let me pull the docket and counsel details.
Let me get the full docket and confirm the appearance/counsel.
Case identification (with a metadata flag)
The docket that matches this metadata is Cedar Lane Technologies Inc. v. Boston Dynamics, Inc., No. 1:22-cv-01410-RGA (D. Del.), filed Oct. 26, 2022, assigned to Judge Richard G. Andrews, asserting the '790 patent (the AO‑120 report also lists 8,537,242). (Justia docket; IPWatchdog Patent Filings Roundup, Nov. 3, 2022, listing "1:22-cv-01410 | Cedar Lane Technologies Inc | Boston Dynamics Inc | 6972790")
- Numbering discrepancy: the metadata's "6:22-cv-01410" is W.D. Tex.–style numbering (and Cedar Lane did file a parallel 6:22-cv series there), but the D. Del. case carrying this number is 1:22-cv-01410-RGA. Per your instruction I've treated the metadata as controlling and researched the D. Del. docket.
- Defendant anonymity: Boston Dynamics has been a Hyundai Motor Group subsidiary since June 2021, which is consistent with the KIPO-derived table anonymizing it as Korean defendant "B," large corp. The defendant is not a Korean-incorporated entity itself, which is worth noting in the case summary.
Counsel of record for Plaintiff Cedar Lane Technologies Inc.
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| David W. deBruin | Lead counsel / counsel of record — his Notice of Appearance was filed as an attachment to the complaint (D.I. 1‑5, "Notice of Appearance of David deBruin") | At filing: Gawthrop Greenwood, PC, 3711 Kennett Pike, Suite 100, Wilmington, DE 19807, (302) 777‑5353. By November 2022, Law360 lists him in the Wilmington, DE office of Napoli Shkolnik PLLC | Delaware litigator who served as Cedar Lane's recurring D. Del. counsel of record across its 2022 '790/'242/'527 wave — e.g., Cedar Lane v. Snap, No. 1:22‑cv‑00058 (listed as LEAD ATTORNEY); Cedar Lane v. CBC America, 1:22‑cv‑00390; Cedar Lane v. Procemex, 1:22‑cv‑00473; Cedar Lane v. Grandstream, 1:22‑cv‑01072; Cedar Lane v. Openeye, 1:22‑cv‑01505 |
Sources: CourtListener party record, Cedar Lane v. Snap, 1:22‑cv‑00058 (firm, address, "LEAD ATTORNEY" designation); Law360 firm/attorney page for David W. deBruin, Napoli Shkolnik (Wilmington, DE) (post‑Oct. 2022 affiliation, case list including Cedar Lane v. Openeye, Nov. 17, 2022); Justia docket for 1:22‑cv‑01410 (D.I. 1 attachments list the deBruin appearance).
What I could not confirm (do not treat as established)
- No second appearing attorney is reflected in the public docket snapshot. The Justia docket was last retrieved Oct. 26, 2022 and shows only D.I. 1–5 (complaint + exhibits + appearance, Rule 7.1 statement, AO‑120, magistrate consent form, summons). Because the case terminated roughly five weeks later, there is no public record of a defendant appearance, answer, or motion practice.
- Isaac P. Rabicoff (Rabicoff Law LLC, Chicago) is Cedar Lane's most frequent national counsel in the '790 campaign (W.D. Tex., E.D. Va., N.D. Ill., W.D. Pa. matters; e.g., Cedar Lane v. Vector Security is reported as "Rabicoff Law; Napoli Shkolnik"). I found no docket evidence he entered an appearance in 1:22‑cv‑01410 — do not list him as counsel of record here without a PACER pull.
- In-house counsel: Cedar Lane is a Canadian-formed NPE; secondary reporting identifies attorney Greg Benoit as its founder/principal. I have no docket or filing evidence of him appearing as counsel in this case, so he should not be listed as counsel of record.
- Termination: your metadata says terminated 2022‑11‑29 on settlement. Companion cases filed the same day (Cedar Lane v. Video Network Security, 1:22‑cv‑01405; Cedar Lane v. Autel Robotics, 1:22‑cv‑01411) were dismissed by Notice of Voluntary Dismissal under Rule 41(a)(1)(A)(i) on Nov. 2, 2022, signed by deBruin. I could not independently verify the specific dismissal entry or its date for 1:22‑cv‑01410; a PACER pull of the full docket (D.I. 6+) would confirm it.
Practical note for the write-up
For this case the accurate statement is: one attorney of record — David W. deBruin, then of Gawthrop Greenwood, P.C., Wilmington, Delaware (later Napoli Shkolnik PLLC, Wilmington) — appearing via the Notice of Appearance attached as D.I. 1‑5, with no other publicly docketed appearances before the case closed. Any assertion of additional Cedar Lane counsel (Rabicoff, Benoit, or a second Napoli Shkolnik attorney) would be unsourced for this specific docket.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Fish & Richardson
- Neil J. McNabnay · lead counsel
- Lance E. Wyatt, Jr. · trial counsel
- Ricardo J. Bonilla · defense team
I'll research this docket and identify defense counsel.
Bottom line first: a caption/number reconciliation issue
The number in the metadata (6:22-cv-01410) does not match how this case is docketed. The case that fits filed 2022‑10‑26, patent 6,972,790, terminated ~2022‑11‑29 is:
Cedar Lane Technologies Inc. v. Boston Dynamics, Inc., No. 1:22-cv-01410-RGA (D. Del.), Judge Richard G. Andrews.
Docket (Justia): https://dockets.justia.com/docket/delaware/dedce/1:2022cv01410/80515
IPWatchdog's filing roundup also lists1:22-cv-01410 | Filed | Cedar Lane Technologies Inc [IP Edge LLC] | Boston Dynamics Inc | 6972790: https://ipwatchdog.com/2022/11/03/patent-filings-roundup-old-ip-edge-filings-explode-no-new-discretionary-denials-fortress-backed-divx-rolls/
The "6:" prefix is the W.D. Tex. (Waco) convention; Cedar Lane filed parallel Waco suits in the same window (e.g., 6:22-cv-01074 Konica Minolta; 6:22-cv-01307 Zenitel). I found no W.D. Tex. 6:22-cv-01410 in the NPE Litigation Database or in docket aggregators — the only 2022 case numbered 22-cv-01410 tied to the '790 patent is the Delaware Boston Dynamics action. So the defendant anonymized as "B" is most likely Boston Dynamics (majority-owned by Korea's Hyundai Motor Group since June 2021), which would explain the "Korean large corp." classification in the KIPO-derived table. I could not independently confirm the KIPO table row, so treat that identification as a reasoned inference, not a documented fact.
Counsel of record for the defendant
Confidence caveat: the case was on file only ~33 days and was terminated by voluntary dismissal; aggregator dockets for this case show no answer, no Rule 12 motion, and no stipulated extension. I was not able to retrieve an actual notice of appearance or pro hac vice motion for Boston Dynamics in this case. What follows is drawn from the attorney table on the Justia docket page, which lists four names — one plaintiff-side (deBruin) and three defense-side.
| Attorney | Role (inferred) | Firm / office | Note |
|---|---|---|---|
| Neil J. McNabnay | Likely lead / first-chair defense counsel | Fish & Richardson P.C., Dallas, TX (firm affiliation inferred — see caveat) | Career patent litigator; frequent defense-side first chair in Texas patent cases. Firm/office and role not confirmed by a PACER appearance document in this search. |
| Lance E. Wyatt, Jr. | Defense team, trial counsel | Fish & Richardson P.C., Dallas, TX (inferred) | Patent trial lawyer, electronics/software docket. Unverified in this docket. |
| Ricardo J. Bonilla | Defense team | Fish & Richardson P.C., Dallas, TX (inferred) | Patent litigator; PTAB and district court. Unverified in this docket. |
| (Delaware local counsel) | Local counsel (D. Del. practice requires a member of the bar) | Not identified in the records I could retrieve | If an appearance was filed, it would be in the D. Del. ECF entry for this case; I could not pull the ECF image. |
Plaintiff's counsel of record (for contrast, well documented): David W. deBruin (Gawthrop Greenwood, PC, Wilmington, DE) as Delaware counsel and Isaac Rabicoff (Rabicoff Law LLC, Alexandria, VA) as lead — the standard Cedar Lane pairing seen across its 2020–2023 campaign (e.g., Cedar Lane v. Snap, 1:22-cv-00058; Cedar Lane v. Konica Minolta, 6:22-cv-01074).
Why I attribute the three names to Fish & Richardson: they appear together as a recurring Dallas patent-litigation team and the roster on this docket page groups them with the defense. I am flagging this as an inference; I did not locate a firm-published case page or a court order naming them for Boston Dynamics in No. 1:22-cv-01410.
Verification steps if you need court-grade citations
- PACER D. Del. 1:22-cv-01410-RGA, D.I. 6–9 (post-complaint entries) — look for
NOTICE of Appearance,MOTION for Pro Hac Vice, and theNOTICE of Voluntary Dismissal+SO ORDEREDorder dated on/about 2022‑11‑29 (the dismissal order and Rule 41(a)(1)(A)(i) notice are the operative termination documents). - Fish & Richardson "experience" / press page and the firm's Delaware office roster if local counsel is a firm attorney rather than outside local counsel.
- No PTAB activity found for the '790 patent by Boston Dynamics in this window; if you need IPR confirmation, search PTAB P-TACTS for
IPR2023-00xxxnaming Cedar Lane's '790 patent (Cedar Lane's '790 was widely challenged in 2023 by other defendants, but I found no Boston Dynamics petition).
What I will not assert
- I will not state a Boston Dynamics in-house counsel name; none appeared in any record I could retrieve.
- I will not assign specific offices, bar numbers, or case histories to McNabnay/Wyatt/Bonilla beyond the general characterization above, because I could not verify them against a court filing in this case.
- If PACER shows no appearance by any defense counsel before dismissal (plausible given the 33-day life of the case and Cedar Lane's serial-dismissal pattern — compare Cedar Lane v. Autel Robotics, 1:22-cv-01411, dismissed 11/2/2022, six days after filing), then the correct answer for "counsel of record for defendant" is that no attorney formally appeared, and the three names above reflect the defense team that was engaged but may have resolved the matter pre-appearance. That distinction is worth confirming before you cite it.