CommWorks Solutions, LLC v. Microchip Technology Inc.

I'll research this case and its context before drafting. Let me run several searches in parallel.

Good initial haul. Let me dig deeper on the parties' corporate structure, the accused products, the judges, and any PTAB activity.

Case Overview and Background

Parties. CommWorks Solutions, LLC is a Georgia LLC (44 Milton Ave., Suite 254, Alpharetta, GA) that does not make or sell anything — it is a patent-assertion vehicle holding an acquired portfolio of early-2000s broadband and Wi-Fi patents. Its Rule 7.1 disclosure in this very case identifies Brainbox Innovations, LLC as its corporate parent (D.I. 2, Feb. 10, 2026), and CommWorks named Brainbox as a real party-in-interest in IPR2021-01297; Unified Patents has separately described CommWorks as "an NPE and subsidiary of IP Investments Group LLC," and Stanford's NPE Litigation Database classifies its assets as "acquired patents." The portfolio has been asserted in waves: first against cable/broadband operators (Comcast, Charter, RCN, Mediacom, Cable One, Consolidated, Vyve, and a declaratory-judgment action by Altice USA), then against equipment vendors (Adtran, Ubee, Extreme, Zyxel, DrayTek, AVM, Grandstream), and since 2025 against chip suppliers (Broadcom in C.D. Cal. 2:25-cv-02998, Marvell, STMicroelectronics, Realtek, and now Microchip). Plaintiff's counsel of record here is the Rozier Hardt McDonough PLLC team of James F. McDonough and Jonathan L. Hardt (D.I. 5); the defense appearance as of the March 2026 extension motion is Travis Jensen (D.I. 9), though I could not verify his firm from the sources available. Microchip Technology Inc. (Chandler, AZ) is a publicly traded semiconductor manufacturer (microcontrollers, analog/mixed-signal, and connectivity/networking silicon) — a component supplier, not an end-product vendor, which frames the case as one about standard-implementing functionality inside SoCs, modules, and controllers.

Accused technology, asserted patents, and posture. The complaint groups the accused products into four categories: "Microchip Wi-Fi Multimedia Products" (WMM/802.11-2007+ QoS), "Microchip WPS Products" (Wi-Fi Protected Setup push-button provisioning), "802.3ah Accused Products" (IEEE Ethernet in the First Mile), and "ITU-T Accused Products" (G.984/G.9807.1 GPON OLT silicon) — see the complaint analysis at ai-lab.exparte.com. As docketed, the complaint and its exhibits appear to assert seven patents (twice the count reflected in this case's metadata, which lists only the '979): U.S. 6,832,249 "Globally accessible computer network-based broadband communication system with user-controllable quality of information delivery and flow priority" (OSI-layer QoS monitoring and lower-layer re-provisioning; accused against the 802.3ah and GPON products); U.S. 6,891,807 "Time based wireless access provisioning" (access point provisions a device whose operation falls in an activatable time interval; claim 17 pleaded); U.S. 7,177,285 and U.S. 7,463,596 (same time-based provisioning family; the '596 claims a process for associating devices by tracking power-on or onset of signal transmission) — all three asserted against WPS; U.S. 7,911,979 "Time based access provisioning system and process" (issued Mar. 22, 2011 from Application 12/323,399; claim 1 pleaded against WPS) — the sole patent named in the case metadata; and U.S. 7,027,465 and its reissue RE44,904, both "Method for contention free traffic detection" (bit-pattern-at-offset detection of priority frames), asserted against the WMM products. The four-patent subset ('807/'285/'596/'979) is the "Time Based Wireless Access Provisioning" family identified in the earlier sections of this workspace; I could verify four family members, not five, so that figure should be treated as unconfirmed. Procedurally, the case was filed Feb. 10, 2026 in W.D. Tex. under a "7:" case-number prefix (the Midland-Odessa office where Judge David Counts sits), assigned to Judge Counts and referred to Magistrate Judge Derek T. Gilliland by Order and Advisory on Feb. 12, 2026 (D.I. 7); Microchip was served Feb. 13, 2026, and its responsive deadline was extended to April 20, 2026 (text order, Mar. 4, 2026). Notably, CommWorks's August 2025 W.D. Tex. suits against Marvell and STMicroelectronics were pulled to Judge Albright, whereas this one remained with Judge Counts — a divergence I can describe from the dockets but cannot explain from a verified rule change. Caveat: the last docket snapshot available to me is March 4, 2026 (Justia docket); I could not verify any events after that date, including Microchip's answer, a scheduling order, claim-construction activity, or any PTAB filing.

Why it matters. First, the theory is standards-based NPE assertion aimed upstream: because WPS, WMM/802.11e-type QoS, 802.3ah and GPON are implemented in ubiquitous silicon, CommWorks is effectively collecting from the supply chain rather than from end users, and a chip-level finding would ripple through every OEM that buys these parts — the same strategy it ran against Broadcom ("BCM4392" and similar WMM/802.11-2007+ chips, C.D. Cal. 2:25-cv-02998), Marvell, and STMicroelectronics. Second, the campaign has resolved fast rather than on the merits: CommWorks's suit against STMicroelectronics (7:25-cv-00363) was voluntarily dismissed with prejudice on Oct. 31, 2025, ~70 days after filing, and its Marvell (7:25-cv-00354) case ended in a notice of voluntary dismissal on the same date; prior campaigns against Zyxel, Vyve, and RCN also terminated by dismissal or consent judgment with no validity ruling — meaning these patents retain their presumption of validity and remain live against the rest of the market. That pattern makes early settlement the base case here and is the main reason a reader should watch the docket for a Rule 41 dismissal. Third, there is genuine PTAB linkage: Unified Patents has been the recurring third-party challenger to this portfolio — its ex parte reexamination request against the '249 was granted Dec. 23, 2021 (control no. 90/014,909, per Unified's news page) and it filed IPR2021-01297 against U.S. 8,923,846 — and Microchip is itself a sophisticated IPR petitioner (its five-petition campaign against HD Silicon Solutions' patents), so a § 315(b) petition against the '979 or its family members could appear up to roughly one year after the Feb. 13, 2026 service date (i.e., by ~Feb. 13, 2027). Fourth, the damages exposure may be narrower than the accused-product breadth suggests: one CommWorks complaint pleads indirect infringement of the '979 "from March of 2021 until its expiry," implying an early-2020s expiration tied to the family's 2001-era priority chain, which would confine recovery to back damages — I flag this as an inference from complaint language, not a verified expiration date. Finally, venue: W.D. Tex. remains a favored NPE forum with early disclosure obligations and (historically) a fast patent docket, yet CommWorks filed its 2026 cases against Realtek (E.D. Tex. 2:26-cv-00088) and Grandstream (E.D. Tex. 2:26-cv-00794) in the Eastern District, suggesting forum-shopping calibration by plaintiff's counsel that is worth tracking alongside this case.

I'll research the docket and related proceedings, focusing on events after the March 2026 snapshot in the prior sections.

Let me dig for post-March 2026 developments, defense motions, and any PTAB activity.

Key Legal Developments and Outcome — CommWorks Solutions, LLC v. Microchip Technology Inc., No. 7:26-cv-00043 (W.D. Tex.)

Threshold caveat — the record stops at 2026-03-04

I have to lead with the limitation, because it controls how much of this section can be stated as fact. Every accessible docket mirror for this case (Justia, CourtListener/RECAP, ai-lab.exparte) reflects a docket last retrieved 2026-03-04. My searches this pass returned no document, opinion, or news item dated after that date for this case number. I could not reach PACER directly, and I found no reported answer, counterclaim, motion to dismiss, transfer motion, stay motion, Markman order, scheduling order, PTAB petition, settlement, or dismissal.

That means the honest answer to "what happened" is: the case is in its first weeks, it has not progressed past the pleading stage on the public record, and the entire substantive litigation history is a single extension of time. Everything past 2026-03-04 below is explicitly labeled as either (a) an inference from CommWorks's documented campaign pattern, or (b) an open item requiring a PACER pull. I will not fill the gap with invented events.

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1. Chronological record — verified docket events

No defendant answer, counterclaim, appearance notice, or dispositive motion appears in the accessible record. Note the metadata tension the earlier sections already flagged: the case metadata lists only the '979 patent, but the docket and complaint analysis show seven asserted patents ('249, '807, '285, '596, '979, '465, and RE44,904). My review of the filing confirms the complaint is a multi-patent, four-product-category action; treat the '979-only metadata as an under-count.

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2. Filing & initial pleadings

• Complaint (2026-02-10): § 271 infringement across four accused-product categories — "Microchip Wi-Fi Multimedia Products" (WMM/802.11-2007+), "Microchip WPS Products," "802.3ah Accused Products," and "ITU-T Accused Products" (G.984/G.9807.1 GPON). The complaint pleads at least claim 11 of the '249, claim 17 of the '807, claim 1 of the '285, claim 1 of the '596, and claim 1 of the '979. See the complaint analysis at ai-lab.exparte.com.
• Answer / counterclaims: Not on the accessible record. The extended deadline (2026-04-20) means the answer would have been filed after the last docket pull. Whether Microchip answered, moved to dismiss/transfer, or filed invalidity counterclaims is unverified. Given the accused products are standards-implementing silicon, the predictable defense contentions are captured in the complaint analysis above (e.g., that the 802.3ah/G.984 control-plane functions do not map onto "OSI reference model layers," and that the WPS handshake is not "automatically associating"), but I found no filed pleading articulating them.

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3. Pre-trial motions of substance

None verified. I found no Rule 12(b) motion to dismiss, no § 1404(a)/§ 1406 venue-transfer motion, and no motion to stay pending IPR in any accessible source. Two points of strategic context, both from the earlier sections and consistent with what I found:

• Transfer/venue is a live defense tool here. Microchip (Chandler, AZ) is not a Texas company, and CommWorks's Marvell and STMicroelectronics W.D. Tex. suits were reportedly pulled to Judge Albright while this one stayed with Judge Counts — a docket-level divergence that may or may not signal a forthcoming venue fight. A § 1404(a) motion to Arizona or Delaware (where Microchip has litigated before, e.g., Aptiv v. Microchip, D. Del. 1:23-cv-00307, and Microchip v. Aptiv, 1:17-cv-01194) is the obvious candidate to watch. I could not verify any such motion was filed.
• A stay-pending-IPR motion is premature absent a filed petition (§ 315(b) window runs to roughly 2027-02-13), so the absence of a stay motion at this stage is unremarkable.

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4. Claim construction (Markman)

Not reached — no Markman activity exists on the record. The case is roughly eight months old and had not received its scheduling order as of 2026-03-04. For reference, the claim terms that would drive a Markman are already visible from the complaint analysis and from CommWorks's parallel complaints: "operating parameter," "onset of a signal transmission," "activatable time interval" / "time interval," and "automatically associating" in the WPS family, and "monitoring…at least one OSI reference model layer" / "layer N" in the '249 family. In the parallel CommWorks v. DrayTek complaint (E.D. Tex. 2:25-cv-00024), "operating parameter" was expressly identified as a term for construction. But no construction has issued in this case.

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5. Discovery milestones of strategic significance

None — discovery had not opened on the accessible record. There had been no scheduling order and no discovery management order as of 2026-03-04. No protective order, ESI protocol, damages-contentions exchange, or reduction-to-practice/priority-date discovery has been docketed. Given CommWorks's pattern of disposing of these cases within weeks of filing (below), discovery may never meaningfully open here.

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6. Trial, verdict, and post-trial motions

None, and none realistic at this stage. No trial date, no pretrial conference, no verdict, and no JMOL/new-trial/fee motion appear anywhere. If CommWorks follows its campaign template, this case will terminate long before trial.

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7. Settlement, dismissal, judgment, or appeal — present posture

Status: OPEN and pending. No disposition recorded. The last docketed act is the 2026-03-04 extension order; the operative deadline is Microchip's 2026-04-20 response. There is no judgment, no appeal, and no notice of dismissal in any source I could reach.

The most probative outcome evidence is the parallel-case pattern, which is strong and directly on point:

• CommWorks v. STMicroelectronics, 7:25-cv-00363 (W.D. Tex.): filed 2025-08-25 — the same WPS/'979-family package — voluntarily dismissed with prejudice under Rule 41(a)(1)(A)(i) on 2025-10-31, roughly 70 days after filing. The court's order (verbatim) held the notice self-effectuating, denied all pending motions as moot, and each side bore its own costs — with no invalidity, claim-construction, or non-infringement ruling. Sources: PatSnap litigation record; In re Amerijet Int'l, 785 F.3d 967, 973 (5th Cir. 2015).
• CommWorks v. NXP USA, 7:25-cv-00395 (W.D. Tex.): also terminated by Rule 41(a)(1)(A)(i) voluntary dismissal with prejudice on 2025-10-31 (PatSnap record).
• CommWorks v. Marvell, 7:25-cv-00354: the earlier sections report a notice of voluntary dismissal on the same date.

Implication: the base case for this case is a comparatively early Rule 41(a)(1)(A)(i) voluntary dismissal (likely with prejudice) or a confidential license-based settlement, not an adjudicated outcome. The patents consequently retain their presumption of validity and remain asserted against the rest of the market. I flag this as a well-supported pattern inference, not as a verified event in 7:26-cv-00043.

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8. Parallel PTAB proceedings on the asserted patents

No IPR/PGR against the '979 (or the other patents asserted against Microchip) surfaced in my search, and I found no PTAB petition filed by Microchip in this matter. What does exist is third-party PTAB activity against the portfolio by Unified Patents, which is real but not directed at the patents asserted here:

• Unified Patents, LLC v. CommWorks Solutions, LLC, IPR2021-01297 — challenges U.S. Patent No. 8,923,846 (a CommWorks portfolio patent; not among the patents asserted against Microchip).
• Ex parte reexamination of the '249 patent, control no. 90/014,909, request granted 2021-12-23 (per Unified's news page, as reported in the earlier sections). The '249 is asserted against Microchip's 802.3ah/GPON products, so this reexam is the one parallel-office proceeding with potential effect here — watch the certificate.

Timing for a Microchip IPR: the § 315(b) one-year bar runs from service (2026-02-13), i.e., a petition would be timely through roughly 2027-02-13. Microchip is a documented, repeat IPR petitioner — its 2021 five-plus-petition campaign against HD Silicon Solutions (IPR2021-00752, -00872, -01042, -01089, -01265, -01420, -01421) establishes the institutional appetite. No such petition against CommWorks's patents has appeared as of the available record.

Effect on the litigation: none yet. Because no IPR has been filed against an asserted patent, there is no § 315(a)/§ 315(b) trigger, no estoppel exposure, and no statutory-stay hook in this case to date.

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9. Bottom line for a reader tracking this case

As of the last retrievable docket state (2026-03-04),

I'll research this case and plaintiff's counsel. Let me start with several searches.

Good start. Let me dig deeper on the docket's attorney list and the firms involved.

Let me verify which side each attorney represents and pull the full docket/attorney list.

Plaintiff's counsel of record — CommWorks Solutions, LLC v. Microchip Technology Inc., No. 7:26-cv-00043 (W.D. Tex.)

Bottom line: Plaintiff CommWorks Solutions, LLC is represented by the Atlanta/Austin patent-monetization boutique Rozier Hardt McDonough PLLC ("RHM"). Two RHM attorneys are confirmed on the docket: James F. McDonough, III (Atlanta – lead/docket-signing counsel) and Jonathan L. Hardt (Austin – Texas/local counsel of record). No in-house counsel has appeared. One additional name in the aggregated docket entry ("Adil Anjum Shaikh") appears to be on the defense side — see the attribution caution below.

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1. James F. McDonough, III — Lead counsel (plaintiff)

2. Jonathan L. Hardt — Texas / local counsel of record

3. Other attorneys in the RHM CommWorks roster (not confirmed in this case)

CommWorks' other cases are typically staffed with Carey Matthew Rozier and Kenneth Andrew Matuszewski (both RHM) alongside McDonough and Hardt — they entered appearances in CommWorks v. VTech Holdings, 2:25-cv-00433 (PACER Monitor). Neither appears in the retrievable docket for 7:26-cv-00043; additional appearances may have been filed after the docket was last retrieved. In at least one earlier CommWorks suit (E.D. Tex., Nov. 2023), the company also used Kheyfits Belenky LLP (Andrey Belenky, Hanna G. Cohen) as co-counsel — no indication they are involved here.

4. In-house counsel

None has appeared. Plaintiff's Rule 7.1 disclosure identifies Brainbox Innovations, LLC as CommWorks' corporate parent (Dkt. 2), but no in-house attorney has entered an appearance on the docket. CommWorks is a litigation-vehicle entity (Alpharetta, GA registered office per its complaints), so all advocacy is outsourced to RHM.

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Attribution caution — do not count these as plaintiff's counsel

The Justia docket's aggregated "Represented By" field for this case lists James F. McDonough, Jonathan L. Hardt, Travis Jensen, and Adil Anjum Shaikh without distinguishing parties. The latter two are on the defense side:

• Travis Jensen filed Microchip's Unopposed Motion for Extension of Time to Answer (Dkt. 9, Mar. 3, 2026; granted Mar. 4, 2026, answer due Apr. 20, 2026).
• Adil Anjum Shaikh (USPTO Reg. No. 77490) is listed at Orrick, Herrington & Sutcliffe LLP, Austin — Orrick bio; PatentBots practitioner entry. Law360's attorney profile associates him with a Feb. 10, 2026 appearance in this case (Law360), and his pre-Orrick practice (Fish & Richardson) was defense-side — e.g., Torus Ventures and Cellspin Soft appearances for defendants. I could not retrieve a document naming the party he appeared for here, so I do not list him as plaintiff's counsel; treat him as presumptively defense-side unless a PACER pull shows otherwise.

Sourcing caveats

• I could not pull PACER directly; the docket aggregators reflect a docket last retrieved March 4, 2026, and my search results contain nothing later. Filings in the case do not appear to be sealed, but additional counsel appearances, a motion to proceed pro hac vice, or a substitution of counsel may exist after that date and would not be reflected above.
• Party names, case number, court, judges (District Judge David Counts; Magistrate Judge Derek T. Gilliland), and the Feb. 10, 2026 filing date are taken from the case metadata and the docket listings; the plaintiff's-law-firm identification is corroborated by the same RHM signature block used across CommWorks' complaints (e.g., the W.D. Tex. 7:25-cv-00101 complaint, which is signed "/s/ James F. McDonough, III … Attorneys for Plaintiff COMMWORKS SOLUTIONS, LLC").

I'll research this docket. Let me run several searches in parallel.

Key leads found: an Orrick attorney (Adil A. Shaikh) tied to this case on Law360, and a "Jensen, Travis" who filed the extension motion for Microchip. Let me dig in.

Bottom line

The public record for this docket is thin on the defense side, and I want to be explicit about that up front: as of the latest docket data available (the Justia/PACER mirror last retrieved March 4, 2026), only one attorney's name is affirmatively tied to Microchip Technology Inc. in 7:26-cv-00043 — "Travis Jensen" — and the docket contains no formal Notice of Appearance, no pro hac vice motion, and no corporate-counsel disclosure for the defense. Microchip's answer deadline was extended to April 20, 2026, so an appearance/appearance-and-answer package with the full defense team likely post-dates the accessible docket extract. Anything below is a lead, not a confirmed roster.

What the docket actually shows (verified)

Source: Justia docket mirror for W.D. Tex. 7:26-cv-00043 (last retrieved 2026-03-04), https://dockets.justia.com/docket/texas/txwdce/7:2026cv00043/1172889760

Caveat on the "Jensen" attribution: the docket's parenthetical "(Jensen, Travis)" identifies the CM/ECF filer account, which in W.D. Tex. practice is very often local counsel, not lead merits counsel. I was unable to verify Travis Jensen's firm, office, or patent-litigation history from an independent source within this research pass — I am not going to guess at a firm for him. Treat his firm as unconfirmed.

Counsel lead from a litigation-tracking source (corroborating, not docket-confirmed)

Law360's firm/attorney tracker lists an Orrick, Herrington & Sutcliffe LLP attorney as appearing in this exact case on its filing date:

• Adil A. Shaikh — Senior Associate, Orrick, Herrington & Sutcliffe LLP, Austin, TX office. Law360's attorney-case table shows "February 10, 2026 — CommWorks Solutions, LLC v. Microchip Technology Inc., Texas Western."
  • Source: https://www.law360.com/firms/orrick-herrington/attorneys/adil-a-shaikh
  • Firm bio: https://www.orrick.com/en/People/A/1/2/Adil-Shaikh — former software engineer (Sabre, Nokia, Cisco); practice focused on patents "in complex software technology and semiconductors"; "appearances in over 120 cases." Registered patent agent (Reg. No. 77490), Austin, TX.
  • Role (inferred): most likely a merits/technical member of the defense team rather than lead. This is an inference from seniority and from Law360's generic "attorney on case" tagging — it is not a substitute for a docketed Notice of Appearance, which I could not find.

Note the pattern from the search results: Law360 attorney pages also show Shaikh on other W.D. Tex. defense-side patent matters (e.g., VE Opening LLC v. Dropbox, Nov. 19, 2025; UMBRA Technologies v. Zscaler, E.D. Tex., Oct. 23, 2025), and he was earlier on the Cellspin Soft v. ByteDance defense team in E.D. Tex. (withdrawn May 26, 2026, Dkt. 112). That is consistent with him being a go-to associate on the defense side of W.D. Tex./E.D. Tex. patent dockets.

Firm-level context for Microchip's patent defense (verified from other dockets)

This is useful because it tells you who is likely to populate the W.D. Tex. roster once appearances are filed — but none of these attorneys are confirmed in 7:26-cv-00043:

• Orrick, Herrington & Sutcliffe LLP is a known Microchip patent-defense firm. In Aptiv Technologies AG v. Microchip Technology, Inc., D. Del. 1:23-cv-00307, Microchip moved for pro hac vice appearance of Alyssa Caridis and Jason Yu, both of Orrick (motion filed Apr. 15, 2026; granted Apr. 16, 2026 by Judge Joshua D. Wolson). Sources: CourtListener docket for 1:23-cv-00307. Orrick appears to be Microchip's national merits counsel; expect the W.D. Tex. team to be drawn from the same group, with Shaikh as an identified Austin-based member.
• Shaw Keller LLP (Wilmington, DE) — local Delaware counsel for Microchip in that same Aptiv action (Travis Murray as filer). Not relevant to Texas venue.
• Slayden Grubert Beard PLLC, 401 Congress Ave., Suite 1650, Austin, TX (Bruce W. Slayden II, William "Bill" Beard Jr., and colleagues) — appeared for Microchip in Microchip Technology Inc. v. Aptiv Services US LLC, D. Del. 1:17-cv-01194 (per the proposed pretrial order). An Austin firm with deep W.D. Tex. patent experience; a plausible local-counsel candidate here, but pure inference — not confirmed in this case.
• DLA Piper LLP (US), Wilmington DE (Edward Tulin, Jeff Castellano, et al.) — appears in the older Microchip v. Aptiv matter.

In-house

Microchip is headquartered in Chandler, Arizona and staffs a dedicated IP-litigation function: its Legal Department has a "Senior Corporate Counsel II – IP Litigation" role reporting to the Director & Assistant General Counsel – IP & Litigation, expressly responsible for managing outside counsel and IPR strategy. No individual Microchip in-house attorney has been identified as counsel of record in 7:26-cv-00043 in any accessible source. Do not assume a name here.

What I could not establish (and why)

1. No docketed Notice of Appearance for any defense attorney appears in the accessible docket extract. W.D. Tex. local rules require a Notice of Appearance; none is shown as of March 4, 2026.
2. No pro hac vice motions for out-of-state defense counsel are shown — expected if the Orrick merits team (Austin/Los Angeles/SF) intended to appear; their absence suggests the extract predates the appearance package.
3. Sealing: nothing in the accessible entries indicates defense filings are sealed; the gap is staleness of the mirror, not sealing. PACER itself should be pulled for entries after 2026-03-04 (particularly anything filed on or after 2026-04-20, the extended answer date) to capture the answer, any Notices of Appearance, pro hac vice motions, and any in-house/outside-counsel designations.
4. Travis Jensen's firm and role — unverified. He may be local counsel, in-house, or a merits lawyer; the "(Jensen, Travis)" bracket alone doesn't tell you.
5. No confirmed IPR filings by Microchip against the '979 patent surfaced in this pass; given the complaint's notice-letter allegations (Microchip's knowledge of the '979 patent traced to a March 2021 notice letter in parallel CommWorks campaigns) and Microchip's documented practice of filing IPRs through outside counsel, an IPR track is worth checking separately.

Recommended next pull

Request from PACER the full docket sheet for 7:26-cv-00043 for the period 2026-03-04 through 2026-09-21, focusing on: Microchip's Answer/Motion to Dismiss (due 2026-04-20), any Notice of Attorney Appearance, any Motion for Pro Hac Vice Admission (which will name the Orrick attorneys admitted), and the Rule 7 / corporate disclosure. That set of documents — not any aggregator — is the only authoritative source for "counsel of record" in this case.