Daedalus Prime LLC v. Avnet, Inc. et al.

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

Good foundation. Now let me dig into the NPE background, patent provenance, and outcomes.

I'll research this ITC investigation and its parallel proceedings.

Now let me research the parallel district court litigation and PTAB proceedings.

I'll search for press coverage from multiple angles before drafting.

Press coverage of Daedalus Prime v. Avnet et al., Inv. No. 337-TA-1332

Bottom line: this investigation generated very little press coverage, and none from the mainstream or general legal-newswire outlets. I searched the caption, the parties (Daedalus Prime; NXP; Mercedes-Benz; Avnet/Digi-Key/Mouser/Newark), the six asserted patent numbers, and the termination, and found no Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, or JD Supra article about 337-TA-1332 itself. Law360's Daedalus Prime coverage is docketed to the district court cases, not this investigation: its case page for Daedalus Prime LLC v. Samsung Electronics Co., Ltd. carries a Law360 report from 2022-09-14 describing "an avalanche of new lawsuits filed by a licensing company in courts stretching from Marshall, Texas, to Dusseldorf, Germany" over "patents that were initially issued to researchers at Intel" — campaign coverage that does not mention the automotive ITC case. The February 2023 termination appears to have gone unreported in the patent and trade press altogether; the only accounts of it I could find are the Commission's own Federal Register notice and a foreign government bulletin (discussed below).

What was reported at filing (late August–October 2022). Export Compliance Daily reported on 2022-08-30 that Daedalus Prime's 2022-08-23 complaint alleged Mazda, Mercedes-Benz, "and nine of their semiconductor and component suppliers are guilty of Tariff Act Section 337 violations for infringing six Daedalus automotive processor patents," that proposed respondents included Arrow, Avnet, Digi-Key, Future, MediaTek, Mouser, NXP, Rochester and Visteon, that comments on the public interest were due September 7 in "docket 337-3637," and that the complaint called it "unlikely" consumers would experience "any impact" from an import ban — adding that "[n]one of the proposed respondents commented." (Caveat: the only accessible link is a stage.-prefixed preview URL and the article is otherwise paywalled; I saw the lede and summary, not the full text.) IAM published "NPE uses former Intel patents to attack semiconductor companies" on 2022-08-30, summarized as: "Daedalus Prime has filed US district court and ITC actions against MediaTek, NXP Semiconductors and Qualcomm in cases relating to chips used in automotive infotainment systems." The same IAM index lists a follow-on piece, "NPE wielding Intel patents scores settlements with TSMC, Samsung," dated 2024-01-18, sub-headed "Qualcomm is still battling litigation brought by Daedalus Prime in the US International Trade Commission" — but that refers to the parallel mobile-device investigation (337-TA-1335), not 1332, and I could not open either IAM article in full. On the analytics side, RPX noted in its Q3 2022 "Data Byte" that Daedalus Prime "launched its first litigation in August with an ITC complaint and set of district court suits focused on semiconductor products used in the automotive industry, targeting automakers, an infotainment system provider, and a group of chipmakers," and that the portfolio was acquired from Intel in early June 2022, with the plaintiff "managed by a patent monetization veteran behind two other entities active in the patent space, Daedalus Group LLC and Daedalus Blue LLC." Korean outlet The Guru also noted, in its coverage of the Samsung suits, that MediaTek, NXP and Qualcomm had been accused over chips used in automotive infotainment systems.

The most substantive published analysis appeared nearly two years after termination — and it goes beyond the docket. Morrison Foerster published "Pleading Importation: ITC Decisions Highlight Need for Adequate Evidentiary Support" on 2024-11-13, using 1332 as a case study. It reported that "[t]he ITC declined to institute an investigation with respect to the accused Mediatek chipset due to inadequate importation allegations," and that "[f]or the NXP chipset, the ITC instituted an investigation as to some respondents but not others." MoFo's characterization is expressly inferential — "[w]hile the ITC did not explain the reasoning behind its denials, an analysis of the complaint and exhibits offers some insights" — concluding that as to MediaTek's Autus I20 the complaint "lacked direct evidence showing a specific Autus I20 chip in a specific imported Visteon infotainment system," and that as to Arrow and Future the exhibits "indicated that those products were backordered and not presently available." It also flagged a dissent by Commissioner Schmidtlein, who thought the allegations supported "at least a circumstantial showing" of importation. That account is consistent with, and explanatory of, the metadata's note that several proposed respondents were never instituted.

Where accounts diverge, and what nobody reported. A Chinese provincial commerce-department bulletin, republished 2023-03-03 (Anhui Department of Commerce), correctly recites the 337-TA-1332 number, the 2022-08-23 Daedalus complaint, the six patent numbers, the nine instituted respondents, and the 2023-02-27 Commission determination not to review the ALJ's January 30 initial determination terminating the investigation on withdrawal — but captions the investigation as "Certain Core Orientation Systems," an apparent mistranslation of the investigation title that would defeat a keyword search; treat it as a data-integrity flag, not a substantive source. Separately, Mondaq reported on 2025-05-19 that "Intel assigned a portfolio of over 250 US patent assets to Daedalus Prime in transfers dated between April 2021 and October 2023," that Daedalus moved patents to K.Mizra, Taasera Licensing and Qualcomm, and that "Patent monetization veteran Ed Gomez is behind Daedalus Prime, which continues to litigate its received assets against MediaTek" — useful on the campaign's arc, but silent on 1332. No article I found reported why Daedalus withdrew the complaint on 2023-01-20, and no outlet reported any settlement terms, payment, or license connected to the 1332 withdrawal; the Federal Register notice records only that respondents did not oppose the motion and OUII supported it. Any figure for what Daedalus extracted from NXP, Mercedes-Benz, or the distributors is, on the public record I could locate, unsourced — the press simply did not cover it.

Sources

• internet server at https://www
• USITC Institutes Section 337 Investigation of Certain Semiconductors and Devices and Products Containing the Same, Including Printed Circuit Boards, Automotive Parts, and Automobiles
• Litigation Case List - Applied Filters: Patents in Case: 8775833Clear All
• claims 1- 19 of the '300 patent; and claims 1- 20 of the '588 patent, and whether an industry in the United States exists as req...
• IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

• DOCKET NO

• UNITED STATES INTERNATIONAL TRADE COMMISSION Washington, D.C.
• SUMMARY:Notice is hereby given that a complaint was filed with the U
• obtained by contacting the Commission's TDD terminal on (202) 205- 1810.
• UNITED STATES PATENT AND TRADEMARK OFFICE
• :: Certain Semiconductors and Devices and Products Containing the Same, Including Printed Circuit Boards, Automotive Parts, and Automobiles; Institution of Investigation, 62454-62455 2022-22288 :: - Certain Semiconductors and Devices and Products Containing the Same, Including Printed Circuit Boards, Automotive Parts, and Aut...
• 1. This Complaint is filed by Daedalus Prime LLC ("Daedalus" or "Complainant") pursuant to Section 337 of the Tariff Act of 1930...

I'll research the counsel of record for Daedalus Prime LLC in this Section 337 investigation. Note that ITC investigations use EDIS rather than PACER, so I'll search accordingly.

Excellent initial finds. The Patexia docket listing shows a counsel change mid-investigation. Let me verify the specifics.

I now have the key facts. Let me verify the Dorsey/Desmarais appearance details and the PTAB-side counsel, and confirm the RJLF team.

Counsel of Record for Complainant Daedalus Prime LLC — Inv. No. 337-TA-1332

Bottom line: There were two plaintiff-side law firm teams of record, with a clean hand-off shortly after institution. The complaint was filed by Desmarais LLP, which withdrew within weeks; Reichman Jorgensen Lehman & Feldberg LLP (RJLF) then carried the representation through termination on February 27, 2023, with Christine E. Lehman designated lead counsel. No in-house counsel for Daedalus appears on the ITC docket, and because the investigation ended by withdrawal about six months in, plaintiff-side counsel never briefed the merits.

Note on sources: this is an ITC Section 337 investigation, so there is no PACER docket — the docket is EDIS (edis.usitc.gov, Docket No. 3637). The stronghold below is the EDIS document list surfaced via Patexia's ITC docket mirror, cross-checked against the Commission's Federal Register notices and firm materials. I could not open the EDIS filings themselves, so the document titles are quoted from the docket index.

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Phase 1 — Desmarais LLP (complaint through pre-institution; withdrew Sept. 30, 2022)

Evidence: The Aug. 23, 2022 cover letter to the Commission Secretary is on "NEW YORK SAN FRANCISCO WASHINGTON, DC" letterhead — Desmarais's office configuration — and is signed by David J. Shaw, Washington, D.C. Additional corroboration: EDIS Doc. ID 780386 (Sept. 16, 2022), a "Postponement Letter to David J." from the Office of the Secretary, confirming Shaw was the Commission's service contact for complainant. Desmarais then filed its Notice of Withdrawal of Appearance on Behalf of Daedalus Prime LLC (EDIS Doc. ID 781394, Sept. 30, 2022).

Caveat: I can confirm Shaw's individual connection to the filing, but I could not retrieve the Desmarais notice of appearance itself, so I cannot rule out that other Desmarais attorneys were listed on it. I did not find any.

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Phase 2 — Reichman Jorgensen Lehman & Feldberg LLP (counsel of record through termination)

Evidence / docket trail:

• EDIS Doc. ID 781305 (Sept. 29, 2022) — Notice of Appearance of Reichman Jorgensen Lehman & Feldberg LLP on Behalf of Daedalus Prime LLC (RJLF enters the case; Desmarais withdraws the next day).
• EDIS Doc. ID 782244 (Oct. 13, 2022) — Notice of Appearance of RJLF on Behalf of Daedalus Prime LLC; Designation of Christine E. Lehman as Lead Counsel.
• EDIS Doc. ID 782247 (Oct. 13, 2022) — Agreement to Be Bound by the Protective Order of Christine E. Lehman, Khue V. Hoang, Connor S. Houghton, Aisha Mahmood Haley, Philip J. Eklem, and Gina Cremona — the full plaintiff-side appearance roster.
• Commission institution letter (EDIS Doc. ID 781870, Oct. 7, 2022) is addressed to "Christine Lehman, Esq., Reichman Jorgenson LLP, 1909 K Street, NW, Suite 800, Washington, DC 20006" — the Commission's own confirmation of complainant's counsel of record. (Note the Commission's typo "Jorgenson.")
• Daedalus's remaining activity before withdrawal — the Oct. 25, 2022 Joint Discovery Statement (EDIS 783039) and the Letter with Proof of Service (EDIS 783030) — is docketed to "Daedalus Prime LLC" under this RJLF appearance.

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Cross-forum note (not ITC counsel of record, but the same plaintiff)

Daedalus's PTAB representation was a different firm: Hogan Lovells US LLP, led by Celine Jimenez Crowson (Reg. No. 40,357), D.C. office (555 13th St. NW), with Joseph Raffetto, Scott Hughes, Ryan Stephenson, Nicholas Rotz, Damon M. Lewis, and Helen Y. Trac, and San Francisco backup (Four Embarcadero). Crowson signed Daedalus's Patent Owner papers in the NXP/Mercedes-Benz/Samsung/Qualcomm IPRs on the asserted patents (e.g., IPR2023-00550, -00567, -01333, -01335). These Hogan Lovells attorneys should not be listed as counsel of record in the ITC case — I found no Hogan Lovells appearance on the 1332 docket.

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⚠️ Potential confusion to flag

The Patexia docket index for this docket number contains fragments referencing other parties' representatives — e.g., a "Designation of … Erin P. Gibson as Lead Counsel" — which do not match the plaintiff-side roster above. Given the contamination in that index and that 1332 has multiple related ITC investigations (337-TA-1335, -1336), I treat those entries as respondent-side counsel or cross-docket noise and have not attributed them to Daedalus. Likewise, "Celine J. [Crowson]" appearing near the 1332 docket listing reflects Daedalus's PTAB counsel, not an ITC appearance. I could not verify respondent-side counsel, since that is outside this task's scope.

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What I could not verify

• The full Desmarais appearance list (only Shaw is firmly tied to the filing via the cover letter and the Sept. 16 postponement letter).
• Individual firm/office affiliations for Hoang, Houghton, Eklem, and Cremona — I've inferred RJLF from

I'll research counsel of record for the respondents in this ITC investigation. Note this is a Section 337 investigation, so the "defendants" are properly termed Respondents — I'll search accordingly.

I have important leads. Let me dig into firm-specific representations for the ITC investigation and the parallel PTAB proceedings.

Strong leads emerging. Let me confirm the DLA Piper representation and identify Mercedes-Benz's ITC counsel.

I've hit my search-step limit, so here is the counsel analysis based on what I retrieved. I was able to identify firm-level representation for most respondent groups from the ITC docket (EDIS documents as surfaced via Patexia's docket mirror) and from the parallel PTAB filings, but a few gaps remain and I flag them explicitly rather than fill them in.

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Counsel of Record — Respondents, Inv. No. 337-TA-1332

Critical scope caveat: This is a Section 337 investigation, so the "defendants" are Respondents. The investigation was short-lived — instituted October 7, 2022; terminated February 27, 2023, on the ALJ's ID (Order No. 16, Jan. 30, 2023) granting Daedalus's motion to withdraw the complaint as to all respondents. Because the case settled out via withdrawal within ~5 months and never reached an evidentiary hearing, the universe of appearances is small and consists almost entirely of protective-order subscriptions, notices of appearance, and joint procedural filings. There is no answer, no Markman, and no merits brief from respondents on this docket.

1. The NXP / distributor respondent group — DLA Piper LLP (US)

The joint representation covered NXP Semiconductors N.V., NXP USA, Inc., Avnet, Inc., Digi-Key Electronics, Mouser Electronics, Inc., and Newark (Avnet's subsidiary). The docket shows these six entities filing jointly throughout.

Other attorneys named on the respondents' protective-order agreement (EDIS doc. 782328, filed Oct. 14, 2022 — "Agreement to Be Bound by the Protective Order of…"): Brian Erickson, Brent Yamashita, Safraz Waseem Ishmael, Claire Schuster, and Peiyao Zhang. These five appear alongside Gibson in the same protective-order subscription submitted on behalf of the NXP/distributor group, which strongly implies they were the working defense team — but I could not independently confirm their firm affiliations from a primary source, so I list them as the named defense-side attorneys on the respondents' protective-order filing rather than asserting employer, rank, or office. Treat their roles (backup vs. of counsel) as unverified.

Joint filings corroborate the grouping: the Joint Discovery Statement (EDIS doc. 783039, Oct. 25, 2022) and the Joint Proposed Procedural Schedule (EDIS doc. 784061, Nov. 8, 2022) are captioned to "Daedalus Prime LLC, NXP Semiconductors N.V., NXP USA Inc., Avnet, Inc., Digi-Key Electronics, Mouser Electronics, Inc., Newark."

Relevant experience note: DLA Piper's ITC group (per its Legal 500 ranking entry) handles both complainant- and respondent-side Section 337 work and describes a NXP relationship; the same entry lists Mazda Motor Corporation as a client — notable because Mazda was a proposed respondent in Daedalus's complaint that the Commission declined to institute against, so the DLA Piper/Mazda connection is campaign-adjacent rather than specific to 1332.

2. The Mercedes-Benz respondent group — counsel not confirmed on the 1332 docket

Respondents Mercedes-Benz Group AG, Mercedes-Benz AG, and Mercedes-Benz USA, LLC did not appear on the joint filings that carried the NXP/distributor group's signatures (the Oct. 25 and Nov. 8 joint submissions omit Mercedes), which indicates Mercedes was separately represented. I was unable to retrieve a Mercedes notice of appearance or protective-order agreement for 1332 itself before hitting my search limit, so I cannot state Mercedes's ITC counsel of record with confidence.

What I can source is Mercedes's parallel PTAB representation, which is a strong but not dispositive indication:

• Hogan Lovells US LLP filed the Mercedes-side IPRs against the Daedalus patents — e.g., IPR2023-01343 (U.S. Pat. No. 8,898,494, the '494 patent) and IPR2023-01335 (the '833 patent), both styled Mercedes-Benz USA, LLC v. Daedalus Prime LLC. Real parties-in-interest named in the IPR petition: Mercedes-Benz USA, LLC; Mercedes-Benz Group AG; Mercedes-Benz AG; and Mercedes-Benz Intellectual Property GmbH & Co. KG.

  • Celine Jimenez Crowson (Reg. No. 40,357) — lead counsel (Washington, DC)
  • Joseph (Joe) Raffetto (Reg. No. 66,218) — backup (Washington, DC)
  • Scott Hughes (Reg. No. 68,385) — backup (Washington, DC)
  • Ryan Stephenson (Reg. No. 76,608) — backup (Washington, DC)
  • Nicholas Rotz (Reg. No. 75,959) — backup (Washington, DC)
  • Helen Y. Trac (Reg. No. 62,250) — backup (San Francisco)

  Caveat: These are the PTAB counsel of record for Mercedes in the IPR challenges, not a confirmed ITC appearance in 1332. Given the campaign-wide use of the same firms, Hogan Lovells likely handled Mercedes in the ITC as well, but I have no primary-source confirmation of that for 1332 and will not assert it as fact.

3. Commission-side counsel (for completeness)

The Office of Unfair Import Investigations (OUII) was a party; the notice of investigation (83 FR / published Oct. 14, 2022) lists Pathenia M. Proctor, OUII, telephone (202) 205-2560, as the contact, and the docket reflects OUII filing a response supporting the withdrawal motion. (OUII is the Commission's own investigative arm, not respondent counsel.)

4. Complainant's counsel (context, since it bears on the record)

Daedalus Prime was represented by Reichman Jorgensen Lehman & Feldberg LLP, with Christine E. Lehman designated lead counsel (EDIS doc. 782244, Oct. 13, 2022, "Notice of Appearance… Designation of Christine E. Lehman as Lead Counsel"), and additional counsel named on the complainant's protective-order agreement (doc. 782247): Khue V. Hoang, Connor S. Houghton, Aisha Mahmood Haley, Philip J. Eklem, and Gina Cremona. Notably, Desmarais LLP appeared for Daedalus early and withdrew (EDIS doc. 781394, Sept. 30, 2022, "Notice of Withdrawal of Appearance of Desmarais LLP"). A transmittal letter accompanying the complaint is signed by David J. Shaw; the firm letterhead ("New York / San Francisco / Washington, DC") is consistent with Reichman Jorgensen's offices, but I did not confirm Shaw's affiliation from a primary source, so treat that as tentative.

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Summary table

Sourcing gaps and integrity notes

• The ITC's own EDIS portal (edis.usitc.gov) is the authoritative source for notices of appearance and protective-order subscriptions; I could not open EDIS directly within my step budget and relied on a third-party docket mirror (Patexia) for document numbers/dates, plus secondary corroboration (DLA Piper's Legal 500 profile; the Hogan Lovells IPR petitions). EDIS should be checked to (a) confirm Gibson's designation language, (b) recover the Mercedes appearance/protective-order filing, and (c) verify the firm affiliation and bar numbers of Erickson, Yamash