Litigation

Cedar Lane Technologies Inc. v. Longse Technology Limited

6:22-cv-00655

Patents at issue (1)

Summary

Cedar Lane Technologies Inc. sued Longse Technology Limited in W.D. Tex.; family-level listing.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

I'll research this case across multiple sources.

Case Overview — Cedar Lane Technologies Inc. v. Longse Technology Ltd., No. 6:22-cv-00655 (W.D. Tex.)

Parties and business profiles. Plaintiff Cedar Lane Technologies Inc. is a Canadian patent-holding entity — the Stanford NPE Litigation Database classifies it as a non-practicing entity holding acquired patents, and Korean trade-agency (KOTRA) litigation tracking likewise tags it "Canada / NPE" (Stanford NPE DB – case 257439; KOTRA dispute record). It does not make or sell products; it monetizes a small portfolio of imaging/image-sensor interface patents. Defendant Longse Technology Limited is an operating manufacturer headquartered at No. 18 Dongming 3rd Road, Huangpu District, Guangzhou, China — a CCTV/security-surveillance OEM (est. 2006, affiliated with 长视科技股份有限公司 / Longse Technology Co., Ltd.) that makes IP cameras, HD analog/AHD cameras, XVR/NVR/DVR recorders, Wi-Fi and fisheye cameras, and exports to 150+ countries (product literature, longse.com; company profile; Baidu Baike company entry). In short, this is a classic PAE-vs.-foreign-hardware-maker mismatch: a one-lawyer-firm shell plaintiff suing a Chinese surveillance-equipment exporter.

The accused technology and the patents. The complaint was filed 23 June 2022 and, per multiple trackers, asserted three patents — U.S. 6,473,527, 6,972,790 and 8,537,242 — not the single '527 patent reflected in the case metadata supplied here (IPWatchdog filings roundup, 1 July 2022; KOTRA; Stanford NPE DB – patent 6473527). Technical sketches: the '527 patent ("Module and method for interfacing analog/digital converting means and JPEG compression means") claims an interface module between an A/D converter and a JPEG compressor that uses a small internal line buffer sized to match the compressor's built-in memory (e.g., eight image lines = one 8×8 block), eliminating a discrete external RAM chip; it is drafted in means-plus-function form ("read control means," "memory means," "output control means") (ex parte complaint analysis of parallel Cedar Lane pleadings). The '790 patent ("Host interface for imaging arrays," issued 6 Dec. 2005, priority 21 Jan. 2000) claims a FIFO-based interface, preferably integrated on the image-sensor die, that buffers sensor data at the sensor clock rate and generates an interrupt or bus-request signal when a threshold is reached so the host processor can read at its own pace. The '242 patent (issued 17 Sept. 2013) is a divisional of the '790 application with method claims covering the FIFO-count/compare-to-limit/interrupt sequence, and is subject to a terminal disclaimer over the '790 patent (Patsnap patent record). Consistent with Cedar Lane's campaign-wide pleading template, the public docket text does not itemize specific accused model numbers; the infringement theories live in claim-chart exhibits (the complaint attached Exhibits 1–6) aimed at Longse's camera/recorder imaging pipelines, and in parallel cases the chart exhibits were not always included in the public filing — so any claim that specific Longse SKUs were charted is not verified from the public record. The case metadata's family-level listing of only the '527 patent appears to be an under-inclusive artifact; the pleading asserted three patents.

Procedural posture and why it is notable. The case landed in the Waco Division of the Western District of Texas before Judge Alan D. Albright (the "6:" prefix denotes Waco), with Isaac Rabicoff of Rabicoff Law LLC as plaintiff's counsel (UniCourt docket summary; Patexia document list). Venue mattered enormously: in 2021–22 W.D. Tex. was the nation's dominant patent forum, and IAM's profile of Cedar Lane identifies it as the single top-filing patent plaintiff of 2022, a Canadian company that "strongly favours the Western District of Texas" and had achieved a ~96% settlement/dismissal rate among terminated cases, under president Greg Benoit (IAM, 20 March 2023). Longse's case is a textbook instance of that model: summons issued and documents dispatched for foreign service by FedEx (Doc. 6–7), a waiver of service returned 12 July 2022 with answer due 11 October 2022 (Doc. 8), Albright's updated standing orders docketed 16–17 September 2022, and then — before any answer, motion to dismiss, transfer motion, or claim construction — Cedar Lane filed a Doc. 9 "Motion to Dismiss (Notice of Voluntary Dismissal Without Prejudice)" on 24 October 2022, followed by the AO-120 report to the USPTO (Doc. 10, 25 October 2022). The docket I reviewed shows no appearance, answer or motion practice by Longse, and the case terminated roughly four months after filing — the cost-of-defense settlement-and-walk-away pattern that made Cedar Lane a target of NPE-reform commentary (by January 2022 its campaign had already exceeded 150 defendants, per Mondaq/RPX coverage). It is also worth noting that this suit was filed on 23 June 2022, just before the widely reported late-July 2022 change to Waco patent-case assignment practices; I have not verified the details of

Key legal developments & outcome

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

I'll research this case across dockets, court records, PTAB, and legal press.

Important early lead: the docket shows a voluntary dismissal in October 2022. Let me verify whether the case was later reopened or refiled, and check PTAB activity.

Cedar Lane Technologies Inc. v. Longse Technology Limited, No. 6:22-cv-00655 (W.D. Tex.)

Bottom line up front: this case never reached any contested milestone. It was filed 2022-06-23 and voluntarily dismissed without prejudice on 2022-10-24 — roughly four months later — before Longse ever appeared, answered, or filed a counterclaim. There was no Rule 12 motion, no transfer motion, no stay motion, no Markman, no discovery on the merits, no trial, and no appeal. It is one data point in Cedar Lane's high-volume, short-duration settlement/dismissal campaign rather than a litigated dispute.


Chronological developments

Date Event Source
2022-06-23 Cedar Lane Technologies Inc. (Canada; NPE) files Complaint for Patent Infringement (Doc. 1) in W.D. Tex., assigned to Judge Alan D. Albright. Asserted patents: US 6,473,527 ("Module and method for interfacing analog/digital converting means and JPEG compression means"), US 6,972,790 and US 8,537,242 (both "Host interface for imaging arrays"). Counsel: Isaac Rabicoff (Rabicoff Law LLC); Mann Law Group also listed in trade-press reporting on the filing wave. Same-day filings: Notice of Appearance (Doc. 2), Rule 7.1 Disclosure Statement (Doc. 3), Summons Request (Doc. 4), AO-120 Patent/Trademark Form (Doc. 5), Summons Issued (Doc. 6). Patexia docket; UniCourt docket; IPWatchdog roundup
2022-06-24 Foreign-service documents received in Clerk's Office for FedEx service on the Chinese defendant (Doc. 7). Patexia
2022-07-12 Waiver of Service returned executed; waiver sent 2022-07-12, answer due 2022-10-11 (Doc. 8). Longse thus avoided formal service of process but never filed a responsive pleading. Patexia; UniCourt
2022-09-16/17 Clerk's notice that parties must comply with Judge Albright's updated Standing Order Governing Proceedings – Patent Cases and Amended Pretrial Procedures Order. Patexia
2022-10-11 Answer deadline passes with no answer, no Rule 12(b) motion, and no counterclaims on the docket. Inference from docket (docs. 9–10 are the only later entries)
2022-10-24 Cedar Lane files Doc. 9, captioned "MOTION to Dismiss (Notice of Voluntary Dismissal Without Prejudice)" with proposed order. Because Longse had not served an answer or summary-judgment motion, this was in substance a Rule 41(a)(1)(A)(i) notice of dismissal, which terminates the case without prejudice without need for a court order. Patexia docket
2022-10-25 Report on Patent/Trademark sent to USPTO (Doc. 10) — the AO-120 closure report the Clerk transmits when a patent case is terminated. Case terminated. Patexia docket

What did not happen (and why that matters)

  • No answer or counterclaims. Longse — a Guangzhou-based camera/CCTV OEM — never appeared. There is therefore no declaratory-judgment counterclaim of invalidity or non-infringement, and no adjudication of any kind on the merits.
  • No pre-trial motions of substance. No 12(b)(6)/12(b)(2) motion, no § 1404(a) or forum non conveniens transfer motion (the obvious defense theory for a foreign defendant), no motion to stay pending IPR, no summary judgment.
  • No Markman. The case was gone before the § 4-3 Joint Claim Construction Statement deadline in Judge Albright's standing order. Note the terms that would have driven claim construction on the '527 patent: "read control means," "memory means," and "output control means" — all § 112(f) means-plus-function limitations whose scope is confined to the disclosed read control device 22 / memory device 24 / output control device 23 architecture of Fig. 2. That structural narrowness, plus the patent's 2019 expiration, made the '527 count a weak candidate for a litigated win. (Third-party complaint analysis of parallel Cedar Lane '527 suits: exparte.com.)
  • No discovery milestones — no Rule 26(f) conference, no initial or infringement/contentions disclosures, no ESI order, no depositions.
  • No trial, verdict, JMOL/new-trial motion, or § 285 fee motion.
  • No appeal.

Parallel PTAB proceedings

None identified. My searches of PTAB/IPR databases, IPWatchdog's petition roundups, and the Stanford NPE Litigation Database surfaced no IPR or PGR petition against the '527, '790, or '242 patents in connection with this case, and no PTAB proceeding that influenced the dismissal. Because Cedar Lane dismissed before Longse answered, Longse never had the opportunity to file a petition within the § 315(b) one-year window, and no § 315(e) estoppel attached. Caveat: I could not run a direct PTAB Patent Trial and Appeal Board Endpoint / PTAB docket query in this session, so treat "no IPR" as a well-supported negative rather than a certified one.


Final disposition and present posture

  • Final disposition: dismissed without prejudice on 2022-10-24 (Doc. 9), with the AO-120 report transmitted to the USPTO on 2022-10-25 (Doc. 10). No settlement agreement, license, consent judgment, or money changed hands on the public record — nothing was filed. Any payment, if one occurred, is not documented in the docket.
  • Present posture: closed/terminated. The Stanford NPE Litigation Database lists this as the only Cedar Lane case against Longse, so there is no refiled follow-on suit in W.D. Tex. or D. Del. that I could locate. Because dismissal was without prejudice, Cedar Lane remains free to refile — but the practical window is narrow (see below).

Strategic significance in the broader Cedar Lane campaign

  1. This was a "demand-letter-with-a-docket-number." Cedar Lane filed as the most prolific patent plaintiff in the U.S. in 2022, overwhelmingly in W.D. Tex. before Judge Albright, and reports a ~96% settlement/termination rate across its cases (IAM, 2023-03-20, interview with Cedar Lane president Greg Benoit). The 4-month, no-answer lifecycle here — waiver of service, then unilateral dismissal — is the modal Cedar Lane outcome, not an anomaly. (Comparable pattern: Cedar Lane v. Drift Innovation, D. Del. 1:20-cv-00766, notice of voluntary dismissal 2020-06-16; Cedar Lane v. Hubbell, D. Del. 1:23-cv-00381, dismissed with prejudice 2023-06-20.)
  2. The '527 patent expired 2019-06-01, and had already been asserted in roughly 124 district court cases (Chinese IP-protection-center risk alert on the parallel Shenzhen case, 6:22-cv-01079). Expiration caps exposure to the § 286 six-year lookback — from the 2022-06-23 complaint date, damages could only reach infringement from 2016-06-23 to 2019-06-01, roughly a 2.4-year royalty base. That materially lowered Longse's cost of ignoring the suit.
  3. Caveat on the case metadata: your family-level summary lists only the '527 patent. The operative complaint actually asserted three patents — '527, '790, and '242 — as confirmed by both the IPWatchdog filing table and the June 2022 Retail Patent Litigation Report. Worth correcting in the case file.
  4. Venue drift. Cedar Lane shifted its 2023 filing wave to D. Del. (e.g., Hubbell, Video Network Security, Vantage Robotics) and by 2025 was filing in S.D.N.Y. against financial-services defendants — consistent with the post-In re: Judge Albright / random-assignment changes in W.D. Tex. that eroded its Waco home-field advantage.

Sourcing gaps I want to flag

  • I verified the docket through the Patexia and UniCourt mirrors of the W.D. Tex. docket, not native PACER. Neither mirror shows a separate order granting the dismissal, which is consistent with Rule 41(a)(1) automatic dismissal but should be confirmed against the PACER "terminated" flag.
  • No document in the record explains Longse's non-appearance or Cedar Lane's decision to dismiss (e.g., a licensing deal, a Longse cessation of U.S. sales, or a purely administrative dismissal). Any stated reason would be speculation. There is no public settlement document.
  • Contact/counsel for Longse never appears on this docket — no defense firm can be attributed.

Plaintiff representatives

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

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

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Bottom line: The docket in Cedar Lane Techs. Inc. v. Longse Tech. Ltd., No. 6:22-cv-00655-ADA (W.D. Tex., Judge Alan D. Albright) reflects exactly one attorney appearing for the plaintiff — Isaac Phillip Rabicoff of Rabicoff Law LLC — and no local counsel, no co-counsel, and no in-house appearance. The case was filed June 23, 2022 and voluntarily dismissed without prejudice on October 24, 2022, so the appearance list never grew beyond the filing team.

Attorney roster

# Attorney Role Firm / office Appearance & activity
1 Isaac Phillip Rabicoff (USPTO Reg. No. 74,147) Lead counsel and sole counsel of record Rabicoff Law LLC — at filing: 5680 King Centre Dr., Suite 645, Alexandria, VA 22315; firm now principally listed at 4311 N. Ravenswood Ave., Suite 315, Chicago, IL 60613 (additional VA and Harrison, NY addresses) Notice of Attorney Appearance, Dkt. 2 (June 23, 2022). Signed the complaint (Dkt. 1), Rule 7 disclosure statement (Dkt. 3), summons request (Dkt. 4), AO 120 form (Dkt. 5), waiver-of-service return (Dkt. 8, July 12, 2022), and the Notice of Voluntary Dismissal Without Prejudice (Dkt. 9, Oct. 24, 2022). No other filing in the case is attributed to any other lawyer.

Role notes and relevant experience

  • Rabicoff — lead counsel. He is effectively Cedar Lane's captive enforcement counsel: Lex Machina's 2024 patent-litigation report ranks Rabicoff Law second among plaintiff-side filers with 578 cases across 25 districts (2021–2023), and commentary describes Cedar Lane's W.D. Tex. wave (including sixteen cases filed the week of September 12, 2022) as "all by Isaac Rabicoff of Rabicoff Law." Cedar Lane itself is a Canadian NPE incorporated in 2019 asserting acquired Intellectual Ventures-origin patents, and it has filed hundreds of suits — the Longse case is one of that campaign. See Seyfarth Shaw, "NPE Showcase – Cedar Lane Technologies" (Oct. 2022), https://www.mondaq.com/unitedstates/patent/[1237392](/patent/1237392)/.
  • Notable adverse ruling (relevant to his track record). In Cedar Lane Techs. Inc. v. Blackmagic Design Inc., No. 3:20-cv-01302-VC (N.D. Cal.), Judge Vince Chhabria sanctioned Rabicoff $1,000 under Rule 11 and the court's inherent authority (Nov. 19, 2020), found he had made "objectively frivolous" arguments in bad faith, denied his pro hac vice motion, and referred him to the N.D. Cal. Standing Committee on Professional Conduct; the Committee's final report required him to pay $9,193 in unpaid pro hac vice fees for 29 matters. Order and Committee report available at https://cases.justia.com/federal/district-courts/nevada/nvdce/3:2025cv00103/[173189](/patent/173189)/37/0.pdf. He later self-reported that sanction in a 2025 Nevada filing.
  • Practice profile. Rabicoff is a registered patent attorney whose docket is dominated by short-lived, settlement-oriented NPE complaints; consistent with that pattern, this case never progressed past the pleadings — no answer, no scheduling order, no Markman, and no IPR activity on U.S. Patent 6,473,527 that I could locate for this defendant.

Sealing / non-appearance caveats

  • No sealed or under-seal appearances. Every entry in this docket is public; nothing about counsel is sealed.
  • No local counsel appeared. This is worth flagging because W.D. Tex. practice often pairs an out-of-state plaintiff with Texas local counsel (compare the same plaintiff's W.D. Wash. filings, where Philip P. Mann of Mann Law Group PLLC, Bainbridge Island, WA, signed as counsel "together with Isaac Rabicoff (pro hac forthcoming)" — https://storage.courtlistener.com/recap/gov.uscourts.wawd.[317813](/patent/317813)/gov.uscourts.wawd.317813.1.0.pdf). Rabicoff filed here without any pro hac vice motion and without local counsel, which indicates he was appearing on his own admission rather than via a Texas sponsor; the docket does not state his bar admission expressly, so treat that as an inference. A June 2022 Retail Patent Litigation Report (Lexology/LexBlog) lists "Mann Law Group; Rabicoff Law" for the Cedar Lane case group, but Mann does not appear in this case's docket — that report aggregates the campaign, not this docket.
  • No in-house counsel of record. Cedar Lane (a Canadian NPE) has no lawyer entered on this docket in a corporate/in-house capacity.

Case-status cross-check (affects the value of the counsel list)

The complaint asserted three patents — 6,473,527, 6,972,790 and 8,537,242 — although the case metadata here lists only '527. See IPWatchdog, "Patent Filings Roundup" (July 1, 2022), https://ipwatchdog.com/2022/07/01/patent-filings-roundup-centripetal-sees-iprs-microsoft-engineer-sues-seven-waco/. Service was waived July 12, 2022 (Dkt. 8, answer due Oct. 11, 2022), and plaintiff dismissed the case without prejudice on October 24, 2022 (Dkt. 9), with the AO 120 report to the USPTO docketed October 25, 2022 (Dkt. 10). Longse never appeared through counsel, so there is no opposing-side counsel roster to compare against.

Sourcing note: The W.D. Tex. CM/ECF docket itself is paywalled; the appearance and filing attributions above are drawn from the public docket mirrors at UniCourt (https://unicourt.com/case/pc-db5-cedar-lane-technologies-inc-v-longse-technology-limited-[1227152](/patent/1227152)) and Patexia (https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Longse-Technology-Limited-id-[164511](/patent/164511)/documents), each of which reproduces the docket text including the "(Rabicoff, Isaac)" filer tag on Dkts. 1–5, 8, and 9. Firm addresses are corroborated by Rabicoff's own signature blocks in other matters and by Virginia SCC registration records for Rabicoff Law LLC.

Defendant representatives

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

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

Key finding emerging: the docket appears to show no defense appearance at all. Let me verify against CourtListener and other docket mirrors.

Docket data shows only plaintiff's counsel. Let me confirm via CourtListener/Justia docket mirrors and check for any later Cedar Lane–Longse suits.

Bottom line

No attorney ever entered an appearance for Longse Technology Limited in this case. There is no counsel of record for the defendant — not a lead counsel, not local counsel, not of counsel, and (so far as the docket reflects) not even an in-house attorney admitted pro hac vice. Cedar Lane voluntarily dismissed the case roughly four months after filing, before Longse's answer deadline, so the defense never had to staff the matter on the record.

This is not a sealed-filing situation — it is simply an empty defense side of the docket.

Docket evidence

The complete docket (11 entries, June–October 2022) contains filings by exactly one attorney, Isaac Rabicoff of Rabicoff Law LLC, and he appears only on behalf of the plaintiff:

Date Doc. Entry Filer
06/23/2022 1 Complaint for Patent Infringement (U.S. Pat. 6,473,527; also 6,972,790 and 8,537,242 per the complaint) Rabicoff (plaintiff)
06/23/2022 2 Notice of Attorney Appearance — on behalf of Cedar Lane Rabicoff
06/23/2022 3–5 Rule 7 Disclosure Statement; Summons Request; AO 120 Rabicoff
06/23/2022 6 Summons Issued as to Longse Technology Limited Clerk
06/24/2022 7 Foreign-service documents received by Clerk (FedEx) Clerk
07/12/2022 8 Waiver of Service Returned Executed as to Longse; waiver sent 7/12/2022, answer due 10/11/2022 Rabicoff
09/16/2022 — Albright standing-order compliance notice Clerk (bot)
10/24/2022 9 MOTION to Dismiss (Notice of Voluntary Dismissal Without Prejudice) + proposed order Rabicoff
10/25/2022 10 Report on Patent/Trademark sent to USPTO Clerk

Sources: UniCourt docket mirror for No. 6:22-cv-00655, https://unicourt.com/case/pc-db5-cedar-lane-technologies-inc-v-longse-technology-limited-1227152 (last synced 08/22/2022, which is why it shows the case as "Pending"); Patexia litigation record, https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Longse-Technology-Limited-id-164511/documents (captures the October termination entries); Stanford NPE Litigation Database case page, https://npe.law.stanford.edu/case/[257439](/patent/257439) (lists Rabicoff as the sole attorney of record on either side); IPWatchdog's new-filings roundup confirming the 06/23/2022 filing and the three asserted patents, https://ipwatchdog.com/2022/07/01/patent-filings-roundup-centripetal-sees-iprs-microsoft-engineer-sues-seven-waco/.

Why the defense side is empty — and what it implies

  • Service by waiver, not summons. Longse executed a waiver of service in July 2022 (Doc. 8), which is why the Clerk's FedEx foreign-service packet (Doc. 7) never ripened into proof of service on a Guangzhou-based entity. A waiver is typically signed by the defendant's corporate representative or its non-U.S. counsel; those signatures appear on the waiver form, which is not an appearance and does not identify counsel on the docket.
  • No responsive pleading was ever filed. The answer deadline of 10/11/2022 passed with nothing on the docket, and Cedar Lane moved to dismiss under Rule 41(a)(1)(A)(i) thirteen days later (Doc. 9). Cedar Lane's standard-form dismissal notice in its parallel 2022 cases recites that "Defendant has not yet answered the Complaint or moved for summary judgment" — see, e.g., the Konica Minolta dismissal, No. 6:22-cv-01074-ADA-DTG (W.D. Tex. Nov. 14, 2022), https://www.action-intell.com/wp-content/uploads/2022/11/Cedar-Lane-dismisses-suit-against-Konica-Minolta.pdf. I have not reviewed the Longse dismissal itself, so I cannot quote its recitals verbatim.
  • Outcome consistent with Cedar Lane's settlement model. Cedar Lane (Canadian; principal Greg Benoit) has publicly reported a ~96% settlement rate among terminated cases, which fits a July waiver followed by an October walk-away. See IAM Media interview with Benoit, 20 March 2023, https://www.iam-media.com/index.php/industry/hardware-devices-electronic-equipment?page=104.

The only attorney of record in the case (plaintiff side, for completeness)

  • Isaac Philip Rabicoff — sole counsel for Cedar Lane; Rabicoff Law LLC, 5680 King Centre Drive, Suite 645, Alexandria, VA 22315. He is a prolific serial filer of patent suits (reportedly 49 patent cases in one district in about two years) and was referred to the N.D. Cal. Standing Committee on Professional Conduct in In re Isaac Rabicoff, No. 20-mc-80206-JD, over pro hac vice fee avoidance in his patent practice; the Committee's final report is reproduced in the Blackmagic Design record, https://cases.justia.com/federal/district-courts/nevada/nvdce/3:2025cv00103/173189/37/0.pdf. Note: he did not seek pro hac vice admission in this W.D. Tex. case on the docket as mirrored, notwithstanding that he is Alexandria-based.

Research caveats — please read before relying on this

  1. I could not pull the live PACER docket in this session; the findings rest on two independent docket mirrors (UniCourt and Patexia) plus the Stanford NPE database. All three agree that no defense appearance exists.
  2. The waiver form (Doc. 8, attachment) is the one document that might name a signatory acting for Longse. If you need to know who, in fact, negotiated the waiver and the dismissal — as opposed to who appeared — that exhibit is the place to look, and it is not an appearance of record in any event.
  3. No evidence of parallel PTAB activity. Longse is a Chinese OEM/IP-camera maker with no U.S. litigation footprint of its own (Stanford NPE database lists this as its only U.S. patent case: https://npe.law.stanford.edu/party/longse-technology-limited), so there was no in-house litigation department or prior-firm relationship to infer counsel from.
  4. No second Cedar Lane–Longse suit was identified in the databases searched; the single dismissal appears to have ended the dispute.

Recommendation: if a filing needs a defense-counsel citation, the correct statement is that Longse appeared only through a waiver of service and was never represented by counsel of record; there is no name to cite.