Litigation

Cedar Lane Technologies Inc. v. Samriddhi Automations Pvt. Ltd.

6:22-cv-00956

Patents at issue (1)

Summary

Cedar Lane Technologies Inc. sued Samriddhi Automations Pvt. Ltd. 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 thoroughly before drafting. Let me start with the docket and the patent.

Good — I have the docket basics and the patent. Now let me identify the defendant's business and pin down the asserted patent and the dismissal.

Now let me verify the asserted patents in the actual complaint and check the '527 patent's origins and any PTAB activity.

Case Overview & Background

Cedar Lane Technologies Inc. v. Samriddhi Automations Pvt. Ltd., No. 6:22-cv-00956 (W.D. Tex., filed Sept. 15, 2022) is a short-lived patent strike suit that is best understood as one data point in the largest NPE filing campaign of 2022 rather than as a litigated dispute.

The parties. Cedar Lane Technologies Inc. is a Canadian patent-assertion entity, incorporated in 2019, that acquires patents — frequently portfolios originating with Intellectual Ventures — and monetizes them through high-volume, low-value licensing demands. It is represented in this case by Isaac Rabicoff of Rabicoff Law LLC (Chicago), its near-exclusive outside counsel and the architect of its filing program. IPWatchdog's September 23, 2022 roundup tags this specific complaint as an "[IV selloff]" assertion, and the Stanford NPE Litigation Database classifies Cedar Lane as a non-practicing entity asserting "acquired patents." Cedar Lane is not an operating company: it makes no products and has no relevant manufacturing or R&D. Its 2022 volume was extraordinary — IAM reported in March 2023 that Cedar Lane was "America's top-filing NPE," having filed the most patent cases of any plaintiff that year, with a reported 96% settlement rate among terminated cases and a pronounced preference for W.D. Tex. The defendant, Samriddhi Automations Pvt. Ltd., is by contrast a genuine Indian manufacturer — a Noida/Haridwar, Uttarakhand-based maker of electronic video surveillance equipment founded in 2002 (incorporated 2005) and operating under the flagship brand Sparsh CCTV. Sparsh holds the distinction of being the first Indian company to manufacture CCTV cameras domestically (2008), sells through a channel network spanning 120+ Indian cities, and in April 2025 became the first Indian firm to obtain full STQC certification across its CCTV range under the government's "Make in India" procurement regime. In other words, the archetypal asymmetry: a two-person Canadian licensing shop suing an indigenous Indian hardare manufacturer over millennium-era image-processing patents.

The accused technology and the patents. The case metadata identifies U.S. Patent No. 6,473,527 — "Module and method for interfacing analog/digital converting means and JPEG compression means" — as the patent at issue. In one line: the '527 patent claims a hardware interface module that sits between an image sensor's A/D converter and a JPEG compression chip, using a small line buffer sized to match the compressor's internal block memory so that a complete image block (e.g., an 8×8 pixel block) can be streamed directly into the compressor, eliminating a discrete external frame memory. Claim 1 is drafted in means-plus-function form ("read control means," "memory means," "output control means"), with corresponding structure disclosed as read control device 22, memory 24, and output control device 23 in Figure 2 — a § 112(f) construction fight waiting to happen, and one that would have required Cedar Lane to prove structural equivalence in Sparsh's camera architectures. Importantly, contemporaneous database records (Stanford's NPE Litigation Database and Unified Patents' litigation portal) also associate this docket with U.S. Patent Nos. 6,972,790 and 8,537,242, both titled "Host interface for imaging arrays" and both directed to a buffered interface that decouples image-sensor data rates from a host processor (a buffer plus a signal generator that alerts the host when a threshold quantity of data has accumulated). The complaint's six exhibits (Dkt. 1, Attachments 1–6) are consistent with Cedar Lane's standard three-patent package of three patent copies plus three claim charts. Given that the patents claim the image-capture-and-compression pipeline of digital cameras, the accused instrumentalities were Sparsh's IP/network camera and DVR product lines. Caveat: the claim charts (Exhibits 4–6) and the specific accused-product identification were not publicly retrievable in the records I could access, and sibling-case analyses note that Cedar Lane routinely incorporates claim charts by reference without attaching them to the public filing. The precise accused-product list should therefore be treated as unverified pending a PACER pull of Dkt. 1.

Procedural posture, venue, and why it matters. Filed in the Waco Division of the Western District of Texas before Judge Alan D. Albright, with automatic referral to Magistrate Judge Derek T. Gilliland — the referral notation states the case was "directly assigned to Judge Alan D Albright and REFERRED to Magistrate Judge Derek T. Gilliland due to previously filed cases as having same Plaintiff and patent case numbers," a fingerprint of how the court was batching Cedar Lane's filings. Venue was the point: in September 2022 W.D. Tex. was the nation's dominant patent venue under Albright's plaintiff-friendly rules (early Markman, firm trial dates, no staying for IPR), which is precisely why Cedar Lane filed sixteen cases in a single week there. Sparsh was served on September 21, 2022 — six days after filing, and served in the United States, which strongly implies a domestic agent or affiliate for service of process — with an answer due October 12, 2022. No answer ever appeared. The case then went dormant, and on April 26, 2023, Judge Albright issued an Order to Show Cause (Dkt. 9) requiring Cedar Lane to explain the absence of a Case Readiness Status Report "within one week" and to show cause "why the Court should not dismiss this case for want of prosecution," warning of sua sponte dismissal without prejudice. That order is itself the most legally interesting document in the file: it reflects Albright's post-2022 turn toward aggressive docket hygiene aimed at exactly the sort of parked NPE case Cedar Lane was running. On April 27 the referral to Judge Gilliland was withdrawn (Dkt. 10), and on April 28, 2023 Cedar Lane filed a Notice of Voluntary Dismissal (Dkt. 11), with the PTO report following the same day (Dkt. 12). Because no answer had been served, dismissal was as of right under Rule 41(a)(1)(A)(i) and therefore without prejudice — meaning the dismissal cost Cedar Lane nothing but the filing fee and preserved its ability to refile or, more likely, to extract a license on the same claim charts outside court.

Why the case is notable. Four reasons. First, it is a specimen of the 2022 Cedar Lane wave — a campaign that, per IAM and Docket Navigator data, made Cedar Lane the country's top patent filer and then abruptly stopped in 2023, contributing materially to the year-over-year drop in NPE filings; this docket shows the campaign's terminal mechanics (file, serve, go quiet, dismiss on the courthouse's prompting). Second, it illustrates the W.D. Tex. venue story in transition: filed at the peak of Albright's dominance, it was caught in the court's own reassignment and case-management tightening that, by 2023, had helped the Eastern District of Texas overtake W.D. Tex. as the top patent venue. Third, it is a cross-border enforcement data point — an Indian "Make in India" CCTV champion, later a beneficiary of domestic-preference procurement rules, pulled into a Texas court over JPEG-interface patents from the early 2000s, a mismatch that raises real questions about extraterritorial reach, damages exposure on imported cameras, and the practical ability of a mid-sized Indian manufacturer to defend in Texas. Fourth, it fits Cedar Lane's documented pattern of nuisance-value assertion backed by patents with vague, means-plus-function claims: per Seyfarth's NPE Showcase, none of Cedar Lane's cases has ever reached trial, and a 2020 decision by Judge Vince Chhabria in the Northern District of California sanctioned both Cedar Lane and Rabicoff for "taking positions in his filings that were objectively frivolous … and did so in bad faith," noting Rabicoff "is a serial filer of patent lawsuits" who was not admitted in that district and had "made misleading statements about the procedural history of the case," and referring him to the court's Standing Committee on Professional Conduct.

Sourcing caveats. The docket entries, judges, service date, show-cause order, and dismissal are verified via the Patexia and UniCourt docket mirrors of the W.D. Tex. CM/ECF record. Party characterizations are sourced to IAM (March 20, 2023), Seyfarth Shaw's NPE Showcase (JD Supra), the Stanford NPE Litigation Database (case 268531), IPWatchdog's Sept. 23, 2022 Patent Filings Roundup, and Unified Patents' litigation portal. Two things I could not verify and would not assert: (1) the exact accused-product identification in the complaint, since Exhibits 4–6 and the claim-chart text were not publicly available; and (2) any inter partes review petition against the '527, '790, or '242 patents tied to this defendant — I found no PTAB linkage, and readers should not infer that one exists. The '527 patent's original assignee and inventor chain likewise warrants a USPTO assignment-record pull before being characterized beyond the "IV selloff" tag IPWatchdog applied to the campaign.

Key legal developments & outcome

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

I'll research this case systematically, starting with the docket and complaint.

Let me dig into the docket details and any PTAB proceedings.

Let me confirm the docket and the complaint contents for this specific case.

Cedar Lane Techs. Inc. v. Samriddhi Automations Pvt. Ltd., No. 6:22-cv-00956 (W.D. Tex.)

Bottom line up front: This is a very short, low-substance file. It was a docket-only NPE strike suit that Cedar Lane abandoned roughly seven months after filing — before any answer, counterclaim, motion practice, scheduling order, Markman, or discovery of note. There is no claim construction ruling, no summary judgment, no trial, no appeal, and no PTAB proceeding on the asserted patent. It terminated by the plaintiff's own notice of voluntary dismissal after Judge Albright threatened sua sponte dismissal for want of prosecution. Docket sources: Patexia docket, No. 6:22-cv-00956; UniCourt case page; Stanford NPE Litigation Database.


1. Filing and initial pleadings

Date Event Docket
2022-09-15 Complaint for patent infringement filed by Cedar Lane Technologies Inc. (Canadian NPE, founder Greg Benoit) against Samriddhi Automations Pvt. Ltd. (Indian security-equipment manufacturer), with Exhibits 1–6 and civil cover sheet. Filing fee $402. Dkt. 1
2022-09-15 Notice of appearance of Isaac Rabicoff (Rabicoff Law LLC), Rule 7.1 disclosure statement (no parents/affiliates), AO-120 patent form, Notice of Related Case, summons requested and issued. Dkt. 2–7
2022-09-15 Case directly assigned to Judge Alan D. Albright and referred to Magistrate Judge Derek T. Gilliland "due to previous filed cases as having same Plaintiff and patent case numbers" — i.e., the case was flagged as part of Cedar Lane's Waco wave. Docket text
2022-09-16/17 Court's standing-order notice: parties directed to comply with Judge Albright's Standing Order Governing Proceedings – Patent Cases and Amended Standing Order on Pretrial Procedures. Docket text
2022-09-21 Defendant served (per return filed 2022-09-30); answer due 2022-10-12. Dkt. 8

Patents asserted. The case metadata lists only U.S. Patent No. 6,473,527 ("Module and method for interfacing analog/digital converting means and JPEG compression means," orig. Mustek Systems, assigned to Cedar Lane in May 2019). Practitioners should note that contemporaneous reporting lists three Cedar Lane patents in this case — the '527 plus U.S. Pat. Nos. 6,972,790 and 8,537,242 (both "Host interface for imaging arrays") — which is consistent with the six exhibits attached to the complaint (three patents + three claim charts). Compare the IPWatchdog Patent Filings Roundup of 2022-09-23, which lists 6,473,527 / 8,537,242 / 6,972,790 for this case number. Because the complaint and its claim-chart exhibits are not in the public free-text record, I flag this as sourced-but-unconfirmed: the '527 is unquestionably asserted; the '790/'242 may also have been pleaded.

Answer / counterclaims: none. The docket runs to 12 entries, and no answer, no Rule 12 motion, and no counterclaim ever appeared. The 2022-10-12 answer deadline passed with no filing reflected and no request for clerk's entry of default by Cedar Lane. This is the single most probative fact about the case: Cedar Lane never prosecuted it against a non-appearing foreign defendant, and never sought default judgment.


2. Pre-trial motions of substance

None. No motion to dismiss, no § 1404(a)/§ 1406 transfer motion, no motion to stay pending IPR, no summary judgment motion, no Motions in Limine, no Daubert motion. The case never generated a scheduling order or a Case Readiness Status Report (see below). There is no reported or unreported opinion in this case.


3. Claim construction (Markman)

Not reached. No Markman briefing, no Markman order, no claim-construction hearing. The '527 patent's claim 1 is written in means-plus-function form ("read control means," "memory means," "output control means"), and § 112(f) construction would have been the pivotal issue had the case progressed — the accused devices' internal image buffers would have been measured against the disclosed "read control device 22 / memory device 24 / output control device 23" structure of Figure 2. That fight never happened here, though the same construction question surfaced in Cedar Lane's other '527 suits.


4. Discovery milestones

None of record. No Rule 26(f) conference, no joint discovery/case management plan, no protective order, no infringement or invalidity contentions, no expert reports, no depositions. The absence of even a Rule 26(f) report is what triggered the Court's order (below).


5. Trial, verdict, post-trial motions

None. No trial setting, no verdict, no JMOL, no new-trial motion, no fee motion, no bill of costs.


6. Disposition — the operative chronology

Date Event Docket
2023-04-26 Order to Show Cause (Judge Albright): Cedar Lane "ORDERED to explain the absence of a CRSR [Case Readiness Status Report] within one week of this order and why the Court should not dismiss this case for want of prosecution," with express notice that "in the absence of a reasonable explanation, the Court may sua sponte dismiss this case without prejudice." Dkt. 9
2023-04-27 Order: "CASE NO LONGER REFERRED to Magistrate Judge Derek T. Gilliland." Dkt. 10
2023-04-28 Notice of Voluntary Dismissal by Cedar Lane (with proposed order). Dkt. 11
2023-04-28 Report on Patent/Trademark (AO-120) sent to the USPTO. Dkt. 12

Final disposition: voluntary dismissal, two days after the show-cause order. The docket does not, in the free sources available, state whether the dismissal was with or without prejudice. Because it was taken by notice rather than by stipulation, the default rule of Fed. R. Civ. P. 41(a)(1)(A)(i) would make it without prejudice; the total absence of any litigation activity is consistent with that. I would characterize this as likely without prejudice but treat it as unconfirmed — the text of Dkt. 11 is not in the public excerpt.

No appeal was taken (Cedar Lane, not Samriddhi, was the dismissing party, and dismissal without prejudice on the plaintiff's own notice is not appealable by the plaintiff; Samriddhi never appeared and had nothing to appeal). Present posture: closed, terminated 2023-04-28.

Strategic read. The April 2023 sequence is characteristic of Cedar Lane's Texas campaign: file en masse in Waco, extract a nuisance-value settlement, and if the defendant is a foreign company that never appears and never pays, let the case lapse until Judge Albright's docket-management orders force a dismissal. Cedar Lane's overall record fits this — reporting indicates roughly 80% of its suits settled, with a median resolution around 77–90 days, and no Cedar Lane case ever reaching trial. See Seyfarth Shaw, "NPE Showcase – Cedar Lane Technologies"; Shenzhen IP Protection Center risk alert on Cedar Lane. Note also the 2020 sanctions history in the N.D. Cal., where Judge Chhabria found Cedar Lane and Rabicoff had taken frivolous positions in bad faith and referred Rabicoff to the Standing Committee on Professional Conduct — relevant to interpreting why a case like this was filed and then walked away from, though it is not a ruling in this case.

Damages-window wrinkle worth noting. The '527 patent expired on 2019-06-01 (filed 1999-06-01; issued 2002-10-29), and the '790/'242 patents expired 2023-08-01. Cedar Lane can recover only for the six-year window preceding suit under 35 U.S.C. § 286 — here roughly 2016-09-15 through 2019-06-01 — which sharply capped the value of the case and is one reason a foreign, non-appearing defendant was never worth chasing.


7. Parallel PTAB proceedings

None identified on the '527 patent. I found no IPR, PGR, or CBM petition challenging U.S. Pat. No. 6,473,527, and therefore no PTAB institution decision, no Fintiv stay fight, and no estoppel effect touching this litigation. Likewise nothing on the case docket referencing a PTAB proceeding (no stay motion, no § 315(b) service-date dispute).

Context: Cedar Lane's portfolio saw limited PTAB activity overall. Reporting indicates that the only notable early challenge was Unified Patents' October 2019 IPR against one Cedar Lane patent, which Unified won — but that was not the '527 and I could not verify which patent it was. Any suggestion that the '527 was subject to an IPR should be treated as unsourced.


Honest sourcing caveats

  1. The dismissal's prejudice status (Dkt. 11) is not confirmed from a primary source; I infer without-prejudice from Rule 41(a)(1)(A)(i) and the docket form.
  2. The number of patents asserted — metadata says '527 only; the IPWatchdog roundup and the six-exhibit complaint structure suggest three. The complaint PDF was not retrievable in free sources.
  3. No opinion, order, or ruling of substance exists in this case; every "no" above reflects a genuine absence in the docket (12 entries total), not a research gap. If you need PACER-certified confirmation, the full docket in W.D. Tex. 6:22-cv-00956 is short enough to pull in full for a few dollars.

Plaintiff representatives

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

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

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Case No. 6:22-cv-00956 (W.D. Tex.) — Cedar Lane Techs. Inc. v. Samriddhi Automations Pvt. Ltd.
Patent at issue: U.S. Pat. No. 6,473,527

Bottom line

The docket reflects exactly one attorney appearing for the plaintiff — Isaac Phillip Rabicoff of Rabicoff Law LLC — who acted as sole/lead counsel from filing to voluntary dismissal. There is no local counsel, no of-counsel, and no second attorney of record in this case. The case was closed by voluntary dismissal on April 28, 2023, so the appearance list is final.


1. Isaac Phillip Rabicoff — Lead counsel (sole attorney of record)

Field Detail
Role Lead counsel; filed the complaint and every substantive paper on behalf of Cedar Lane
Firm Rabicoff Law LLC
Office Chicago, IL — 4311 N. Ravenswood Ave., Suite 315, Chicago, IL 60613 (address of record in Cedar Lane matters); firm has also used 73 W. Monroe St., Chicago and an Arlington, VA office (1655 Fort Myer Dr., Suite 724B)
Contact of record isaac@rabilaw.com / (773) 669-4590
Bar admissions Illinois; registered patent attorney (USPTO Reg. No. 74,147); U.S. Supreme Court; Fed. Cir.; 7th Cir.; E.D. Tex.; N.D. Ill. (Trial Bar); W.D. Wis.

Docket appearances and filings (Dkt. entries):

  • Dkt. 1 (Sept. 15, 2022) — Complaint for Patent Infringement, with Exs. 1–6 (signed by Rabicoff; filing fee receipt ATXWDC-16527656).
  • Dkt. 2 (Sept. 15, 2022) — Notice of Attorney Appearance on behalf of Cedar Lane Technologies Inc.
  • Dkt. 3 (Sept. 15, 2022) — Rule 7 Disclosure Statement.
  • Dkt. 4–6 (Sept. 15, 2022) — Request for Issuance of Summons; AO 120 Patent/Trademark Form; Notice of Related Case.
  • Dkt. 8 (Sept. 30, 2022) — Summons Returned Executed (Samriddhi served Sept. 21, 2022; answer due Oct. 12, 2022).
  • Dkt. 11 (Apr. 28, 2023) — Notice of Voluntary Dismissal, with proposed order.

Procedural context for the plaintiff's side: After service, the case went dormant — no answer, no scheduling order activity — until Judge Albright issued an Order to Show Cause (Dkt. 9, Apr. 26, 2023) directing Cedar Lane to explain the absence of a Case Readiness Status Report and show cause why the case should not be dismissed for want of prosecution. The referral to Magistrate Judge Derek T. Gilliland was withdrawn (Dkt. 10, Apr. 27, 2023), and Cedar Lane dismissed voluntarily the next day (Dkt. 11), with the AO 120 report sent to the USPTO (Dkt. 12). This "file, serve, dismiss" pattern is consistent with Cedar Lane's high-volume licensing campaign rather than merits litigation.

Relevant experience / notable matters (one-liner):
Rabicoff is the architect of Cedar Lane's national assertion campaign — Seyfarth Shaw's "NPE Showcase" identified him as the filer of sixteen Cedar Lane suits in the W.D. Tex. in the single week of September 12, 2022, and Lex Machina ranked his firm among the top three most active patent-litigation firms in 2017; he has led licensing campaigns against Amazon, Microsoft, Sony, Apple, LG, Huawei, Samsung and Google, argued before the Federal Circuit, and defeated institution of IPR/CBM petitions (including a Mastercard CBM).

Cautionary flag (relevant to evaluating this counsel): On November 19, 2020, Judge Vince Chhabria of the N.D. Cal. sanctioned Rabicoff and Cedar Lane in Cedar Lane Techs. Inc. v. Blackmagic Design Inc., No. 20-cv-01302-VC (N.D. Cal.), finding positions "objectively frivolous" and taken in bad faith, denying his pro hac vice motion, and referring him to the court's Standing Committee on Professional Conduct; the Committee's Final Report (In re Isaac Rabicoff, No. 20-mc-80206-JD) recorded an informal resolution requiring payment of $9,193 in unpaid pro hac vice fees across 29 N.D. Cal. cases and a commitment to future compliance. A related 2025 Nevada order (Cedar Lane v. Blackmagic, D. Nev. No. 3:25-cv-00103) imposed Rule 11 sanctions and a further committee referral.


2. Attorneys who did not appear in this case (explicitly excluded)

To avoid misattribution — the following lawyers appear for Cedar Lane in other matters but have no appearance on this docket, and I am not listing them as counsel here:

  • Orville Ricardo Cockings and Stephen F. Roth (Lerner David LLP) — appeared for Cedar Lane in S.D.N.Y. matters (e.g., Cedar Lane v. TIAA-CREF, 1:25-cv-09538).
  • Raeann Warner (Bayard, P.A.) — Delaware local counsel in Cedar Lane's D. Del. cases (e.g., Cedar Lane v. Enplug, 1:20-cv-00634; Cedar Lane v. TCL Communication).
  • Brian Philip Lanciault (Thompson Hine LLP) and Excylyn Janaize Hardin-Smith — local counsel appearances in E.D.N.Y./S.D.N.Y. Cedar Lane suits.
  • Greg Benoit — president of Cedar Lane Technologies (Toronto, Canada); a party executive, not an attorney of record.

3. Sourcing caveats

  • I could not query PACER directly. The docket particulars above are drawn from the UniCourt and Patexia docket aggregations of the W.D. Tex. CM/ECF record and the Stanford NPE Litigation Database entry for case 6:22-cv-00956, which are consistent as to all 12 docket entries and the single plaintiff appearance.
  • No sealed filings are indicated on this docket, and nothing in the record suggests a withheld or under-seal appearance.
  • Notably, the docket shows no pro hac vice motion for Rabicoff in this case (unlike his practice in several other districts). Because W.D. Tex. does not require local counsel as a matter of course before Judge Albright, no local-counsel appearance should be expected — but readers should treat the absence of a PHV motion as an inference from the aggregator docket rather than a verified PACER check.

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 of record for the defendant in this case.

Key indicator: the docket appears to contain no defense filings. Let me verify against RECAP/CourtListener and other docket mirrors.

Let me pull the full docket from CourtListener/Justia and check for any defense-side filings.

Bottom line

No attorney ever entered an appearance for Samriddhi Automations Pvt. Ltd. in this case. The docket for W.D. Tex. No. 6:22-cv-00956 contains zero defense-side filings — no notice of appearance, no answer, no Rule 12 motion, no waiver of service, no corporate disclosure statement, and no counterclaim. The only counsel of record in the entire case is plaintiff's counsel, Isaac Rabicoff (Rabicoff Law LLC).

Accordingly, I cannot name lead counsel, local counsel, of counsel, or in-house counsel for the defendant — not because the information is sealed, but because the record shows no such appearance was ever made. I am declining to name any attorney for Samriddhi, since any name I supplied would be invented.

What the docket shows

The complete docket (13 numbered entries plus text orders, docs. 1–12), as reflected in two independent PACER-derived mirrors:

Date Doc. Entry Filing party
09/15/2022 1 Complaint for Patent Infringement (6 exhibits) Cedar Lane (Rabicoff)
09/15/2022 2 Notice of Attorney Appearance — Isaac Rabicoff Cedar Lane
09/15/2022 3 Rule 7 Disclosure Statement Cedar Lane
09/15/2022 4–7 Summons request/issuance, AO-120, Notice of Related Case Cedar Lane / clerk
09/16/2022 — Standing-orders text entry (Albright orders) clerk
09/30/2022 8 Summons Returned Executed — served 9/21/2022, answer due 10/12/2022 Cedar Lane
04/26/2023 9 Order to Show Cause re: absence of a Case Readiness Status Report; notice of possible sua sponte dismissal for want of prosecution Court (Albright)
04/27/2023 10 Order: case no longer referred to Mag. J. Gilliland Court
04/28/2023 11 Notice of Voluntary Dismissal (with proposed order) Cedar Lane (Rabicoff)
04/28/2023 12 Report on Patent/Trademark to USPTO clerk

Sources: Patexia litigation document list for case 6:22-cv-00956 (https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Samriddhi-Automations-Pvt-Ltd-id-[181096](/patent/181096)/documents); UniCourt docket mirror of the W.D. Tex. CM/ECF record, last synced 11/14/2022 (https://unicourt.com/case/pc-db5-cedar-lane-technologies-inc-v-samriddhi-automations-pvt-ltd-[1293121](/patent/1293121)), whose "Attorney/Law Firm Details" section lists only "Plaintiff Attorney: Isaac Rabicoff" and no defendant attorney block. Case metadata cross-checks: Stanford NPE Litigation Database, case 268531 (https://npe.law.stanford.edu/case/268531) and patent 6,473,527 page (https://npe.law.stanford.edu/patent/6473527); IPWatchdog Patent Filings Roundup, Sept. 23, 2022 (https://ipwatchdog.com/2022/09/23/patent-filings-roundup-western-district-waters-tested-ip-edge-runs-disclosure-delaware/), listing the 9/15/2022 filing of 6:22-cv-00956.

Why the absence of counsel is a reliable reading, not a data gap

Three independent features of the record corroborate it:

  1. The dismissal mechanism. Cedar Lane terminated the case by unilateral notice of voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i), not by stipulated dismissal. That rule is available as of right only where the defendant has not yet served an answer or a motion for summary judgment. Plaintiff's election of that route is itself evidence that no answer or dispositive motion was on file — i.e., no defense appearance.
  2. The order to show cause (doc. 9). Judge Albright issued the OSC against plaintiff only, complaining of the absence of a Case Readiness Status Report and threatening dismissal for want of prosecution. In this District, a case with an active, appearing defendant typically generates a joint Rule 26(f) report/scheduling submissions; a one-sided OSC is the signature of a case where the defendant never showed up.
  3. The 7-month gap. Answer was due 10/12/2022; the docket is dead silent from doc. 8 (9/30/2022) until the April 2023 OSC. No extension motions, no answer, no default-judgment motion — the latter being notably absent, which is consistent with Cedar Lane's documented campaign practice of extracting settlements and dismissing rather than litigating.

This is also consistent with the broader campaign pattern. Cedar Lane was the nation's top-filing patent plaintiff in 2022 and resolved matters rapidly at the pleadings/pre-appearance stage; commentators noted none of its cases reached trial. See Seyfarth Shaw, "NPE Showcase – Cedar Lane Technologies" (https://www.jdsupra.com/legalnews/npe-showcase-cedar-lane-technologies-[1171526](/patent/1171526)/); IAM, "Examining the practice of Cedar Lane Technologies – America's top-filing NPE" (Mar. 20, 2023).

About the defendant entity (identity, not counsel)

Samriddhi Automations Pvt. Ltd. appears to be an Indian company; public corporate/recruiting material places a Samriddhi Automations Pvt. Ltd. in Sector 63, Noida, operating as Sparsh CCTV (electronic security/surveillance hardware). See Samriddhi Automations job posting for In-House Legal Counsel, Noida (Glassdoor). Treat this corporate-affiliate identification as unverified — I found no court filing or corporate disclosure confirming the entity's business identity, and it played no role in the counsel question. Service on an Indian entity was recorded as effected 9/21/2022 (doc. 8), just six days after filing, which is unusually fast for foreign service and may indicate service on a U.S. agent or affiliate; the docket text does not say.

For contrast: what a defense appearance looks like in sibling cases

To calibrate what "counsel of record" would look like here, in the contemporaneous Cedar Lane v. VIDEOR E. Hartig GmbH, No. 6:22-cv-00630 (W.D. Tex.), the German defendant appeared through Neil J. McNabnay and Lance E. Wyatt, Jr., then of Foley & Lardner LLP (Austin/Dallas), filing a notice of appearance (doc. 7), an answer with counterclaim (doc. 8), and a Rule 7 disclosure statement (doc. 9) in July 2022 — see the UniCourt docket for that case (https://unicourt.com/case/pc-db5-cedar-lane-technologies-inc-v-videor-e-hartig-gmbh-[1222616](/patent/1222616)). I am citing this only as a benchmark; there is no indication in the record that Foley, McNabnay, Wyatt, or any other firm was ever retained or appeared for Samriddhi in No. 6:22-cv-00956.

Caveats and residual uncertainty

  • Not sealed — simply empty. I found no sealed entries, no motions for leave to file under seal, and no indication that an appearance exists but is hidden. The docket is short and fully visible.
  • Aggregator coverage. The two docket mirrors I used agree with each other and with the case metadata, but neither is a live PACER pull as of today (the UniCourt record reflects a 11/14/2022 sync; Patexia's document list is truncated at the exhibit level). Because the case terminated in April 2023 and the last defense-relevant date (answer due 10/12/2022) precedes the UniCourt sync, a later-created defense appearance would have had to be filed and then withdrawn within a narrow window — implausible, but not formally excluded by these sources.
  • Settlement counsel off-docket. It is common for defendants in Cedar Lane matters to negotiate through counsel who never files an appearance. The public record cannot reveal who, if anyone, negotiated the 2023 dismissal, and I am not speculating. A Rule 41 dismissal also leaves no judicial opinion, so no opinion citation exists (contrast the 2020 N.D. Cal. sanctions decision against Cedar Lane and Rabicoff discussed in the Seyfarth piece above).
  • No PTAB activity found. I found no indication of an IPR/PGR petition by Samriddhi against U.S. Patent No. 6,473,527. I did not verify this to a primary source (PTAB docket), so treat as an absence of evidence.
  • Patent scope note. Your case metadata lists only U.S. Patent No. 6,473,527. IPWatchdog's roundup of this filing lists it alongside 8,537,242, and the complaint carried six exhibits, so the complaint may have asserted more than one patent. Worth reconciling if you plan to rely on the "patent at issue" field.

Recommended verification before publication

  1. Pull the live PACER docket for 6:22-cv-00956 (W.D. Tex.) and confirm the "party/attorney" tab shows no defendant counsel; order a copy of doc. 11 (notice of dismissal) to confirm it recites Rule 41(a)(1)(A)(i) rather than a stipulation.
  2. Check W.D. Tex. ECF for any ex parte sealed or withdrawn appearance (the "Attorney Appearance" query by party name).
  3. If a settlement/license is suspected, the usable public hook is the USPTO AO-120 report (doc. 12) and Cedar Lane's assignment/license records — neither of which would name defense counsel.