Cedar Lane Technologies Inc. v. Xerox Corp.

I'll research this case thoroughly before drafting the overview.

Let me dig into the complaint specifics, Cedar Lane's background, and any IPR history.

Now let me pin down the complaint's accused products, the amended complaint, and any PTAB history.

Case overview: Cedar Lane Technologies Inc. v. Xerox Corp., No. 6:22-cv-01153-ADA (W.D. Tex., Waco Div.)

The parties. Cedar Lane Technologies Inc. is a Canadian patent-assertion entity (NPE/PAE), incorporated in British Columbia in April 2019 and run by Greg Benoit, a lawyer with a long NPE-litigation background; it has no operating business, no public website, and a portfolio assembled largely through acquisitions (Chinese IP-protection-center reporting and IAM both describe its patents as sourced substantially from Intellectual Ventures). By the time it sued Xerox, Cedar Lane had filed roughly 270–325 U.S. patent suits — Lex Machina's 2022 report ranked it the single most active patent plaintiff in the country for 2021 — with a filing pattern overwhelmingly concentrated in the Western District of Texas before Judge Alan D. Albright and a reported settlement rate near 96% and median case life of roughly 77–90 days (IAM, "Examining the practice of Cedar Lane Technologies – America's top-filing NPE," Mar. 2023; Shenzhen IP Protection Center risk alert, Oct. 2022). Xerox Corp. is the multinational document-technology incumbent (MFPs, printers, scanners, production presses, imaging software) — a deep-pocketed OEM defendant with its own substantial patent portfolio, not a typical small-camera-maker target, which is why its appearance on Cedar Lane's docket stands out. Xerox appears to have retained its customary Rochester-area relationship counsel: Stacey V. Reese (Stacey V. Reese Law PLLC) entered an appearance on Dec. 8, 2022 (Doc. 9), and Jeremy P. Oczek of Bond, Schoeneck & King was admitted pro hac vice on Jan. 10, 2023 (Doc. 14). Cedar Lane was represented throughout by Isaac Rabicoff of Rabicoff Law LLC (Alexandria, Va.).

The technology and patents. This suit was one of many in Cedar Lane's camera/imaging-pipeline family, aimed at the interface between an image sensor and a host processor. The public complaint (Doc. 1, filed Nov. 3, 2022) pleaded three patents — U.S. 6,473,527 ("Module and method for interfacing analog/digital converting means and JPEG compression means"; Mustek Systems lineage, filed 1999, issued 2002, term expired June 1, 2019, so only pre-expiry back damages under § 286 were available); U.S. 6,972,790 ("Host interface for imaging arrays"; inventor Mark Suska; priority Jan. 21, 2000; issued Dec. 6, 2005), claiming an on-sensor interface with a FIFO/addressable buffer, a signal generator that asserts an interrupt or bus request when

I'll research this case across the sources you listed. Let me start with parallel searches.

Good — I have the core docket. Now let me pull the full docket and check for IPR activity on the '242 patent.

Let me check PTAB activity on Cedar Lane's imaging patents and pin down the amended complaint / dual dismissal notices.

Bottom line

This is a 98-day, pre-answer case that never reached the merits. The complete docket is 21 entries; there was no answer, no counterclaims, no motion to dismiss/transfer/stay, no Markman, no scheduling order or discovery, no trial, no judgment, and no appeal. The entire substantive history is procedural: service, three extensions of Xerox's response deadline, an amended complaint filed the same day as a first dismissal notice, and a self-executing Rule 41(a)(1)(A)(i) dismissal on 2023-02-09. No IPR/PGR on the '242 was located.

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1. Filing and initial pleadings

2022-11-03 — Complaint filed. Cedar Lane Technologies Inc. v. Xerox Corp., No. 6:22-cv-01153-ADA, W.D. Tex. (Waco Div.), 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" — i.e., Cedar Lane's mass-filing campaign in WDTX. Complaint sought infringement, declaratory judgments of validity/enforceability, damages under § 284, and an exceptional-case finding under § 285, with a jury demand. (Patexia docket; UniCourt docket)

• 2022-11-03/04: Rule 7.1 disclosure (Doc. 3); summons requested (Doc. 4) and issued (Doc. 7, 2022-11-04); AO 120 form forwarded to USPTO (Doc. 5); Notice of Related Case filed (Doc. 6) — Cedar Lane's standard flag for its parallel suits/targeted consolidation.
• Plaintiff counsel: Isaac Rabicoff, Rabicoff Law LLC (Alexandria, VA). Napoli Shkolnik is reported as campaign co-counsel in Cedar Lane's broader filings but does not appear on this docket.
• 2022-12-08: Xerox appeared through Stacey V. Reese (Stacey V. Reese Law PLLC) (Doc. 9). 2023-01-05/2023-01-10: Jeremy P. Oczek (Bond, Schoeneck & King PLLC) admitted pro hac vice for Xerox (Docs. 13, 14).

Patent discrepancy to flag. Your case metadata lists only U.S. Patent No. 8,537,242 ("Host interface for imaging arrays," issued 2013-09-17, filed 2005-10-27 as a divisional of the '790 application, priority 2000-01-21). Third-party aggregators describe the complaint as asserting three Cedar Lane imaging patents — the '242 plus 6,972,790 and 6,473,527 — and the Lexology November 2022 retail report lists all three. A complaint-level analysis notes that the specific asserted claims and accused products were incorporated only by reference to claim-chart exhibits not attached to the publicly filed complaint. I have treated the '242 as the patent at issue per your metadata, but the three-patent version of the complaint is the better-supported reading of the pleading itself; treat the metadata's single-patent listing as a scoping convention, not a docket fact. (Complaint analysis; Lexology)

No answer or counterclaims were ever filed. Xerox's response deadline was extended three times: a "Notice of Agreed Extension" to 2023-01-27 (Doc. 8, which drew a deficiency notice, Doc. 10, on 2022-12-08 because it was filed as a notice rather than a motion); an unopposed motion (Doc. 11, 2022-12-09) granted by text order resetting the deadline to 2023-01-27; and a further joint motion/stipulation (Docs. 15, 17, 2023-01-23, with another deficiency notice at Doc. 16) seeking more time. Consequently Xerox never served an answer or a summary-judgment motion — the precise predicate Cedar Lane recited for Rule 41(a)(1)(A)(i).

2022-12-12 — Referral vacated. Judge Albright entered an order vacating the magistrate referral (Doc. 12), so the case stayed entirely with the district judge.

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2. Pre-trial motions of substance

None. No Rule 12(b) motion to dismiss, no § 1404(a) transfer motion, no motion to stay pending IPR, no summary-judgment motion, no discovery motions, and no motion for fees. The only motions on the docket were (i) extension motions (Docs. 11, 15) and (ii) a pro hac vice application (Doc. 13). This is consistent with Cedar Lane's business model — IAM reported in March 2023 that Cedar Lane was the top-filing NPE of 2022 and had a 96% settlement rate among terminated cases, i.e., cases were engineered to resolve before contested motion practice. (IAM)

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3. Claim construction (Markman)

Did not occur. No scheduling order issued, so no Markman hearing, no joint claim construction statement, and no claim construction order. The case was dismissed roughly 8 weeks before any of that machinery would ordinarily have begun in an Albright case.

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4. Discovery milestones

None of record. No Rule 26(f) conference, no Rule 26(a)(1) disclosures, no protective order, no written discovery, no depositions, and no discovery disputes. The public docket contains no discovery entries.

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5. Trial, verdict, post-trial motions

None. No trial setting, no verdict, no JMOL/Rule 59 motion, no § 285

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

Plaintiff's Counsel of Record — Cedar Lane Techs. Inc. v. Xerox Corp., No. 6:22-cv-01153-ADA (W.D. Tex.)

Bottom line

The docket in this case shows one and only one attorney of record for Cedar Lane: Isaac Rabicoff of Rabicoff Law LLC. He signed the complaint, filed the Rule 7.1 disclosure, the AO 120 form, the related-case notice, the extension motions, the amended complaint, and both voluntary-dismissal notices. There is no local counsel, no second plaintiff-side appearance, and no in-house counsel entry anywhere in the 21-entry docket. No plaintiff-side filing is sealed; the case was dismissed under Rule 41(a)(1)(A)(i) on Feb. 9, 2023 (Dkt. 20), so the record closed with Rabicoff as sole counsel.

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

Practice note on admission: The docket as retrieved contains no pro hac vice motion for Rabicoff (contrast Xerox's counsel, whose PHV motion for Jeremy P. Oczek was granted at Dkt. 14). That is consistent with his already being admitted to practice before the W.D. Tex. from prior Cedar Lane filings in the district; the docket does not independently confirm his bar status.

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2. Attorneys sometimes reported as plaintiff's counsel — with a caution

Several secondary sources report Cedar Lane's November 2022 filing wave as "Rabicoff Law; Napoli Shkolnik" (Retail Patent Litigation Report, Nov. 2022, drawing on Docket Navigator; Lexology/illinoislawyernow reprints). That listing covers the group of Xerox/Openeye/Enterprise/Hertz/Orlando Rentco/SIXT/Avis cases filed that month across W.D. Tex., D. Del., and N.D. Tex. — not necessarily this docket.

For this case, no Napoli Shkolnik attorney (e.g., David W. deBruin or Paul J. Napoli) filed a notice of appearance. deBruin's appearances in the Cedar Lane campaign were concentrated in the Delaware filings (e.g., Cedar Lane v. Video Network Security, No. 1:23-cv-00337 (D. Del.), where he signed the dismissal; Cedar Lane v. Vantage Robotics, No. 1:23-cv-00336) and Napoli Shkolnik later filed letters of dissociation from Cedar Lane's Delaware representation in May 2023. I would not list any Napoli Shkolnik attorney as counsel of record here without a PACER confirmation of an appearance; on the docket as reported by Patexia, UniCourt, and CourtListener-derived sources, there is none.

Likewise, no in-house Cedar Lane attorney appears — consistent with Cedar Lane being a Canadian (Ontario) patent-assertion entity that litigates entirely through outside counsel.

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3. Corroboration and sourcing

• Docket entry text and document list: Patexia litigation record for Case 6:22-cv-01153 ("Documents" tab) — https://services.patexia.com/lawsuits/Cedar-Lane-Technologies-Inc-v-Xerox-Corporation-id-[183166](/patent/183166)/documents; UniCourt case page — https://unicourt.com/case/pc-db5-cedar-lane-technologies-inc-v-xerox-corporation-[1331336](/patent/1331336)
• Signature block confirming firm and address: Plaintiff's Notice of Voluntary Dismissal Without Prejudice, dated Feb. 9, 2023 (Dkt. 20), reproduced at https://www.action-intell.com/wp-content/uploads/2023/02/Cedar-Lane-v-Xerox-dismissed.pdf ("/s/ Isaac Rabicoff … Rabicoff Law LLC, Alexandria, VA … Counsel for Plaintiff Cedar Lane Technologies Inc.")
• Counsel summary: PatSnap litigation profile for 6:22-cv-01153 — https://www.patsnap.com/resources/blog/litigation/cedar-lane-technologies-v-xerox-imaging-array-patent-dismissal-patsnap/ ("Isaac Rabicoff is recorded as counsel for plaintiff Cedar Lane Technologies")
• Batch-level "Rabicoff Law; Napoli Shkolnik" listing: November 2022 Retail Patent Litigation Report — https://www.illinoislawyernow.com/2024/02/november-2022-retail-patent-litigation-report/ (and Lexology reprint)

Caveat: I was not able to pull the raw PACER docket sheet directly in this session; the above rests on multiple independent docket-mirror sources that agree on a single plaintiff-side appearance (Dkt. 2) and on the identity of the signing attorney. Also note the case as filed asserted three patents — the '527, '790, and '242 — not just the '242 listed in the case metadata.

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

Now let me verify the attorneys' firms, offices, and backgrounds.

Let me dig into the BSK profile page, the pro hac vice filing, and the amended complaint that narrowed the case before dismissal.

Counsel of Record — Xerox Corp., No. 6:22-cv-01153-ADA (W.D. Tex.)

The docket in this case is short and entirely public — no sealed filings and no in-house counsel appearance. Only two attorneys ever appeared for Xerox, and neither filed an answer: the case died on a Rule 41(a)(1)(A)(i) notice 98 days in.

1. Jeremy P. Oczek — lead counsel

• Firm/office: Bond, Schoeneck & King PLLC, Buffalo, New York (200 Delaware Avenue); BSK's IP litigation group, admitted pro hac vice in W.D. Tex. in January 2023. Email form used in BSK filings: jpoczek@bsk.com.
• Role note: BSK's own biography expressly lists this matter — "Represented Xerox as lead counsel in the defense of a patent lawsuit involving multi-function printers… Cedar Lane Technologies Inc. v. Xerox Corporation (W.D. Tex.)" — and states the case was dismissed by the plaintiff after Xerox flagged deficiencies in both the original and amended complaints (bsk.com/people/jeremy-p-oczek).
• Experience: Career patent/IP litigator (Boston College Law School, J.D. 2000); Best Lawyers in "Litigation – Patent" since 2018. Prior-firm representations include Analog Devices (BIAX Corp. v. Analog Devices, E.D. Tex.), Hypertherm (Hypertherm v. American Torch Tip, D.N.H.), Ivoclar (PSN Illinois v. Ivoclar Vivadent — SJ of non-infringement affirmed by the Federal Circuit), MKS Instruments, and Transamerica (Lincoln National Life v. Transamerica — reversal of a ~$13M judgment on appeal). He is also Xerox's repeat defense counsel in Cedar Lane-type campaigns, having handled a separate Xerox authentication/access-control patent case in W.D.N.Y.

2. Stacey V. Reese — local counsel

• Firm/office: Stacey V. Reese Law PLLC, Austin, Texas (910 West Avenue, Suite 15). Sole practitioner/boutique she founded in 2013 after ~7 years at McGinnis, Lochridge & Kilgore; licensed in Texas since 2006; admitted in all four Texas federal districts and the Fifth Circuit.
• Role note: Classic W.D. Tex. local-counsel posture — she entered her appearance first (Doc. 9, Dec. 8, 2022), then moved for Oczek's pro hac vice admission (Doc. 13) and handled the joint extension filings (Docs. 15, 17). Her public bio describes her as frequently retained as local/"of counsel" on complex litigation teams.
• Experience: General commercial/business litigator whose practice includes IP disputes (trade secret, non-compete, trademark/online-identity matters) rather than a patent-trial specialist; Super Lawyers (Business Litigation) 2020–2026. Not a registered patent attorney as far as the public record shows.

Procedural notes relevant to who was representing whom

• No in-house Xerox attorney and no additional BSK or Texas counsel ever appeared. Docs. 1–21 show only Rabicoff (plaintiff) and Reese/Oczek (defendant).
• Xerox's appearances were followed by nothing but extensions: agreed extension to Jan. 27, 2023 (Doc. 8, stricken via deficiency notice Doc. 10), then joint motions to further extend (Docs. 15, 17). Xerox never answered or moved.
• Cedar Lane filed an Amended Complaint on Jan. 31, 2023 (Doc. 18), the same day it filed a first Notice of Voluntary Dismissal (Doc. 19), then re-filed the dismissal on Feb. 9, 2023 (Doc. 20) — the self-executing Rule 41(a)(1)(A)(i) notice that closed the case. Caveat: I could not retrieve the text of Doc. 18, so I can't confirm from the public record whether the amendment narrowed the asserted patents; the case metadata lists only the '242 patent, while the original complaint asserted three (the '527, '790 and '242 — see the Nov. 2022 retail patent litigation report and the complaint analysis). Treat that narrowing as an inference, not a verified fact.
• Also note the public complaint did not attach the claim charts/exhibits identifying accused products — asserted claims were incorporated by reference to exhibits absent from the public filing. Nothing on this docket was sealed.

Sourcing / confidence

• High confidence on the two attorneys, their roles, and firms: docket entries Doc. 9, 13, 14, 15, 17, 20 as reflected in PACER-derived aggregators (Patexia docket; UniCourt) plus BSK's own case listing.
• Medium confidence on Reese's precise firm name as docketed ("Reese Law PLLC" vs. "Stacey V. Reese Law PLLC") — aggregators differ; both refer to her Austin firm at 910 West Ave.
• I did not have direct PACER access, so treat the docket-entry citations as second-hand from the aggregators above rather than from the court's own ECF system.