Litigation
Flexiworld Technologies, Inc. v. Amazon.com, Inc.
2:21-cv-01055
Patents at issue (1)
Plaintiffs (1)
Defendants (1)
Summary
Listed on Google Patents' litigation record for the '846 patent; parties confirmed via CourtListener but asserted patents were not itemized. Assertion of the '846 patent was not independently confirmed.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Case Overview: Flexiworld Technologies, Inc. v. [Amazon.com, Inc.](/litigations/by-plaintiff/Amazon.com%2C%20Inc.), No. 2:21-cv-01055-DGE (W.D. Wash.)
Parties and the asserted patent portfolio. Flexiworld Technologies, Inc. is a Vancouver, Washington-based patent-holding/licensing company founded by inventor William H. Chang, who is associated with a large family of U.S. patents (77+ per contemporaneous reporting) dating to 2000–2001 priority filings on wireless "output" technology — printing and rendering digital content from mobile devices without device-specific drivers. It describes itself as a software company, and some litigation databases label it an "operating company," but in practice Flexiworld does not appear to commercialize products and is widely treated as a non-practicing patent-assertion entity (it has separately sued Samsung, HP, Canon, Brother, Roku, and others over the same portfolio; the Mopria Alliance brief in this litigation notes "[a] number of those corporations have been sued by Flexiworld for patent infringement in separate lawsuits"). The defendants are Amazon.com, Inc. and affiliates Amazon.com Services Inc. and Amazon Web Services Inc. — Amazon's consumer-devices business (Echo smart speakers/displays, Fire tablets, Fire TV) and cloud infrastructure. Although the case metadata here lists only U.S. Patent No. 10,481,846 ("the '846 patent"), the operative complaint actually asserted ten Flexiworld patents — '521, '064, '622, '527, '072, '596, '087, '846, '096, and '576 — as recited in Judge Estudillo's own claim-construction order; Flexiworld later agreed to drop the '064 patent (Dkt. 161, 2:21-cv-01055-DGE, W.D. Wash. Mar. 5, 2024; the claim construction opinion is on CourtListener, opinion 10244572).
Accused technology and the patents in play. Per the complaint coverage and the court's order, the accused products are Amazon's Echo, Echo Show, Fire Tablet, and Fire TV lines — i.e., devices that wirelessly render or print digital content. The '846 patent, titled "Software applications and information apparatus for printing over air or for printing over a network" (filed 2000, granted Nov. 19, 2019), claims a system in which an information apparatus (e.g., a tablet) prints digital content to a printer over a local-area network without using a printer-specific driver: the apparatus obtains device information (language/format data) from the printer and uses a "data generation software component" to generate print data conforming to that device information (claim 7, quoted in Dkt. 161). The printing allegations centered on Fire tablets that ship with the "Mopria Print Service" app — wireless-printing software developed by the Mopria Alliance (a 501(c)(6) standards body whose members include Canon, HP, Samsung, Brother, Epson, and others) and supplied to Amazon for inclusion in certain Fire tablets (Mopria's Motion to Quash, Flexiworld v. Amazon, N.D. Cal. No. 4:25-mc-80055, transferred to W.D. Wash. as No. 2:25-mc-00018, dismissed Apr. 2025). The companion '521 "Internet-Pad" patent claims "output manager software" for wirelessly rendering selected digital content to distinct output devices (speakers, displays, printers) over RF links — the hook for the Echo/Fire allegations (Dkt. 161).
Procedural posture, venue, and significance. Flexiworld originally filed in the Western District of Texas (Waco) before Judge Alan D. Albright as No. 6:20-cv-00553-ADA (filed June 22, 2020; terminated Aug. 2, 2021); the case was transferred to the Western District of Washington in August 2021, where it was docketed as No. 2:21-cv-01055 (Seattle Division) — initially before Judge Richard A. Jones, then reassigned on Oct. 18, 2021 to Judge David G. Estudillo (case flags: TRANSIN, STAYED, JURYDEMAND; terminated July 28, 2025 per DocketAlarm). Venue matters because Amazon is headquartered in Seattle, making W.D. Wash. the natural home forum and moving the case off the once patentee-friendly W.D. Tex/Albright docket. Amazon contested Flexiworld's standing (arguing patents may have been assigned to Samsung under an old agreement — motions to dismiss as to the '087, '846, and '064 patents) and moved to stay; the same Samsung-assignment theory was litigated in parallel Roku cases. Judge Estudillo held a Markman hearing (Oct. 16, 2023) after technology tutorials (Feb. 23, 2023) and issued his claim-construction order on Mar. 5, 2024 (Dkt. 161), rejecting Amazon's indefiniteness challenges and holding that "output manager software" and "data generation software component" convey definite structure under Williamson/WSOU Investments — a meaningful § 112 win for Flexiworld. The case is notable as a large-scale NPE assertion against a standards-based printing implementation (Mopria), complete with a 2025 third-party subpoena fight against Mopria that was dismissed by stipulation; and for its IPR linkage — Roku's IPR2021-00714/00715 against Flexiworld family patents resulted in the PTAB largely invalidating related claims in October 2022 (Law360: "Roku Gets PTAB To Trim Wireless Communications Patent," Oct. 24, 2022), a decision that undercut parallel Flexiworld assertions against Amazon and Roku. Caveats: the case's July 28, 2025 termination is confirmed only as a docket close-out — the specific disposition (settlement, stipulated dismissal, or judgment) was not confirmed in my sources; and I found no direct evidence of an IPR petition specifically on the '846 patent, only on closely related family members.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Based on the records I was able to retrieve, here is a chronological account of Flexiworld Technologies, Inc. v. Amazon.com, Inc., No. 2:21-cv-01055-DGE (W.D. Wash.) — including its origin in the Western District of Texas. Several items (standing-motion outcomes, IPR status on the '846 patent, and the final disposition) could not be confirmed from the sources retrieved and are flagged as unverified.
1. Filing & Initial Pleadings (2020)
- 2020-06-22 — Complaint filed. Flexiworld Technologies, Inc. sued Amazon.com, Inc., Amazon.com Services, Inc., Amazon Web Services, Inc., and Amazon.com LLC in the W.D. of Texas (Waco Division) before Judge Alan D. Albright, Case No. 6:20-cv-00553-ADA. Flexiworld asserted 10 patents: U.S. Patent Nos. 8,332,521; 8,989,064; 9,110,622; 10,133,527; 10,140,072; 10,162,596; 10,387,087; 10,481,846 (the '846 patent); 10,489,096; and 10,642,576, against products including Echo, Echo Show, Fire Tablet, and Fire TV (LawStreet Media, 2020-06-24; Unified Patents docket; DocketAlarm).
- 2020-08-17 — Answer. Amazon filed its answer with a jury demand (Unified Patents portal, TXWD docket).
- 2020-09-03 — Scheduling conference before Judge Albright. Amazon flagged an impending jurisdictional/transfer motion; the court ordered jurisdiction motions first (TXWD minute entry).
- 2020-09/10 — Scheduling order. Jury trial set for 2022-02-07 before Judge Albright; motions due 2021-11-12 (TXWD docket via Unified Patents).
Note: The '846 patent's assertion in this case — previously flagged in the existing summary as unconfirmed — is now independently confirmed by the W.D. Wash. claim-construction order (Dkt. 161, filed 2024-03-05), which construes "data generation software component" as it appears in claim 7 of the '846 patent (CourtListener/Recap, Dkt. 161).
2. Pre-Trial Motions of Substance
Standing motions (W.D. Tex., then W.D. Wash.)
- 2020 — Amazon's opposed motion for partial dismissal due to lack of standing as to a subset of the patents; argued telephonically before Judge Albright on 2020-10-29, taken under advisement (TXWD minute entries).
- 2021 (W.D. Wash.) — Two further standing motions carried over from Texas: Dkt. 34 (opposed motion to dismiss for partial dismissal due to lack of standing) and Dkt. 82 (second motion to dismiss for partial dismissal due to lack of standing as to the '087, '846, and '064 patents) (UniCourt docket, 2021-10-12 notice). Outcome of these motions: not confirmed in the sources retrieved; however, the fact that the court later construed '846 claim terms (Dkt. 161, 2024) indicates the '846 patent survived this challenge at least through claim construction.
Transfer to the Western District of Washington
- 2021-08-02 — Transfer granted. Judge Albright granted Amazon's motion to transfer venue under 28 U.S.C. § 1404(a) (W.D. Tex. ECF No. 98), and the case was transferred that same day.
- 2021-08-09 — Case opened in W.D. Wash. as 2:21-cv-01055 (Western District of Washington Division).
- 2021-10-01 — Reconsideration denied. Judge Albright denied Flexiworld's Rule 59(e) motion for reconsideration of the transfer order (W.D. Tex. ECF No. 103), holding the transferor court lost jurisdiction once the transferee court docketed the case (CourtListener opinion 10213403; DocketAlarm ECF 103).
- 2021-10-18 — Reassignment. Case reassigned from Judge Richard A. Jones to Judge David G. Estudillo (UniCourt docket entry).
- 2021-10-12 — FRCP 16(b) scheduling deferred. The court deferred entry of an initial scheduling order pending resolution of Dkt. 34 (standing), Dkt. 74 (Amazon's opposed motion to stay), and Dkt. 82 (standing as to '087/'846/'064) (UniCourt docket). Outcome of the stay motion: not confirmed.
3. Claim Construction (Markman)
- 2020-09 — Original Markman setting. Judge Albright set a Markman hearing for 2021-02-05 (TXWD docket), which was superseded by the transfer.
- 2023-02-10 — New Markman ordered. Judge Estudillo concluded a new Markman hearing was warranted and directed the parties to propose dates and a briefing schedule (Dkt. 131, minute order).
- 2023-02-23 — Status conference with technology tutorials. Counsel made technology presentations (William Chang for Flexiworld; Scott Sanford and Moeka Takagi for Amazon); the court directed fresh briefing and a proposed Markman scheduling order by 2023-03-01 (Dkt. 136 minute entry).
- 2024-03-05 — Claim Construction Order (Dkt. 161). Judge Estudillo issued a 17-page order construing disputed terms, applying Phillips and the Williamson means-plus-function framework. Key points relevant to the '846 patent:
- "Data generation software component" ('846 patent, claim 7): Amazon argued it was a nonce term lacking structure and indefinite. The court rejected that, holding the claim language — processors, memory/storage devices, and software components combined with a description of what the component accomplishes (generate print data) — conveyed definite structure to a skilled artisan, following the Federal Circuit's decision in WSOU Investments LLC v. Google LLC (Fed. Cir. 2023). The term was therefore not means-plus-function and not indefinite.
- "Output manager software" ('521 patent, claim 15): Amazon contended all eight recited functions were indefinite; the court addressed the means-plus-function analysis in detail (CourtListener opinion 10244572; Recap Dkt. 161 PDF).
4. Discovery Milestones
- 2020 (W.D. Tex.) — License/assignment discovery. Judge Albright granted Amazon's unopposed motion for discovery of license and assignment agreements, ordering Flexiworld to produce all license and assignment agreements relating to its patents within seven days (TXWD text order on Dkt. 26) — strategically significant to Amazon's invalidity/damages and standing defenses.
- 2023-02-23 — Technology tutorials served as substantive claim-construction/technical discovery for the court (Dkt. 136).
- Multiple sealed filings and pro hac vice admissions (e.g., Dkt. 132–138, Feb. 2023) reflect active fact/technical discovery through 2023.
5. Trial Events / Verdict / Post-Trial
- No trial, verdict, JMOL, new-trial motion, or fee motion was confirmed in the sources retrieved. The originally scheduled Albright trial date (2022-02-07) was vacated by the transfer. The case was still in claim construction as of 2024-03-05 (Dkt. 161).
6. Final Disposition / Present Posture
- Not confirmed. One docket tracker (ExParte/ai-lab) labels the W.D. Wash. case "Closed," but I could not verify the closing event (settlement, stipulated dismissal, judgment, or otherwise) or its date. UniCourt's status snapshot ("Pending") is from 2021-10-20 and predates the claim-construction phase, so the authoritative disposition must be confirmed against PACER or the court's docket.
- Damages cap consideration: Unified Patents lists the '846 patent's expiration date as 2022-01-02, which — if accurate — would bound any damages period for that patent. (Secondary source; verify against the patent term.)
7. Parallel PTAB IPR/PGR Proceedings
- No Amazon-filed IPR/PGR on the '846 patent was confirmed in my searches. The only PTAB matter surfaced was Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00715 — a separate proceeding against a different defendant (Roku), which is not part of this case.
- Flexiworld's related litigation campaign (e.g., Flexiworld v. Roku, 6:21-cv-00767-ADA, and related W.D. Tex. cases) included PGR filings on other Flexiworld patents (e.g., PGR2021-00111 on U.S. Patent No. 10,846,031), but those do not involve the '846 patent or Amazon.
- No PTAB estoppel or stay effect on this litigation could be confirmed from the retrieved materials.
Key Gaps / Items to Verify on PACER
- Outcome and reasoning of the W.D. Wash. standing motions (Dkts. 34, 82) and stay motion (Dkt. 74) — especially whether the '846 patent survived dismissal.
- Any summary-judgment motions and rulings after the 2024-03-05 Markman order.
- The final disposition (settlement, dismissal, or judgment) and its date — the case's "Closed" status is reported but unverified.
- Whether Amazon or any third party filed IPR petitions against the '846 patent (PTAB docket search by patent number 10,481,846 is recommended).
Sources: CourtListener opinion 10244572 & Recap Dkt. 161 (W.D. Wash. claim construction order, 2024-03-05); CourtListener opinion 10213403 & DocketAlarm ECF 103 (W.D. Tex. reconsideration denial, 2021-10-01); Unified Patents litigation portal (TXWD/WAWD dockets); UniCourt case 984796; DocketAlarm TXWD docket; ExParte/ai-lab case pages; LawStreet Media (2020-06-24).
In the news
What the press has reported about this case, summarized with links to the source articles.
I'll search for press coverage of this case, starting with the known IPWatchdog roundups and then broadening.
Let me search for Flexiworld mentions in the specific IPWatchdog roundups and other coverage angles.
Let me try to retrieve the specific IPWatchdog articles' contents and check for Flexiworld/Amazon mentions.
Press coverage of Flexiworld Technologies, Inc. v. Amazon.com, Inc.
The complaint drew only a thin slice of tech/trade press at filing. The most detailed contemporaneous coverage I could verify came from the voice-AI trade site Voicebot.ai, which reported on 2020‑06‑25 that Amazon had been hit with a ten-patent infringement suit over the Echo, Echo Show, Fire Tablet and Fire TV lines (Voicebot.ai). Voicebot quoted the complaint's allegation that Amazon "has infringed and continues to infringe … [and is] offering for sale in the United States its Echo Buds, Echo Devices, Echo Show Devices, Fire Tablets, and/or Fire TV Devices," and noted that two of the asserted 2018-issued patents cover "sound output system[s] … that support[] voice activated commands" — the hook for the Alexa-related products. It also flagged that "Flexiworld Technologies appears to have been founded in Portland, Oregon in 2001 by William Ho Chang," observed that the company's website "has not been updated since at least 2006" with no employees listed on LinkedIn, and asked under a "A Patent Holding Company?" heading whether it is a producer or an assertion vehicle — a characterization consistent with the NPE framing in the case record.
The IP trade press reported the patent-by-patent details. LawStreet Media reported on 2020‑06‑24 that Flexiworld asserted ten patents — expressly including U.S. Patent No. 10,481,846 ("the '846 Patent") — identifying the accused "internet-pads" and wireless-communication features and noting Flexiworld's demand for "reasonable royalties and 'supplemental damages arising from any continuing post-verdict infringement.'" The same article was syndicated by The IP Crew (theipcrew.com), which added that Flexiworld "is represented by Nelson Bumgardner Albritton." Both outlets describe Flexiworld as a "software company" founded by Chang who "allegedly claims ownership of over 77 patents in the United States" — i.e., the company's own self-characterization rather than an independent finding, and the most favorable framing available for a non-practicing patentee. This confirms the '846 patent was asserted from the outset, consistent with the claim-construction order in the case docket.
Printer/imaging trade press tracked the broader Flexiworld campaign, though not specifically the Amazon docket. Actionable Intelligence (a printer-industry trade outlet) has covered Flexiworld's parallel suits against Canon, HP and Lexmark — e.g., "Flexiworld Technologies Dismisses One Lawsuit against Canon but Files Another" and "With HP's Motion to Dismiss Denied, Flexiworld Files Second Amended Complaint against HP" — and hosted Flexiworld's Lexmark complaint documents. However, I could not find an Actionable Intelligence article addressing the Amazon case itself. A Chinese-language trade piece on 163.com (2021‑02‑22) covered the Canon suit and, in passing, referred back to Flexiworld's June 2020 Western District of Texas suit against Amazon over Echo speakers, framing the question "is Flexiworld an invention company or another patent-assertion 'troll'?" — the same NPE debate surfaced by Voicebot.
Where the record diverges from / exceeds the reporting, and gaps in the coverage. The reporting is almost entirely limited to 2020‑2021 filing-stage stories; I found no mainstream or legal-trade coverage (Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, Patently-O, EFF) of the substantive later developments — the W.D. Wash. transfer and reassignment to Judge Estudillo, the 2024‑03‑05 claim-construction order (Dkt. 161) rejecting Amazon's indefiniteness attacks on the '846 and '521 terms, the 2025 Mopria third-party subpoena fight, or the case's 2025 termination. On the six IPWatchdog "Patent Filings Roundup" articles listed in the prompt, I was able to confirm the 2022‑07‑08 roundup URL and text exist (IPWatchdog) but could not verify that any of those six roundups discusses this Amazon case directly — my searches surfaced only a generic tag-page fragment stating "Flexiworld expanded its campaign against a number of Chinese and other foreign entities," which appears to refer to Flexiworld's foreign-defendant filings rather than the Amazon action, and I could not attribute it to a specific roundup. Caveat: I was unable to open the full text of the IPWatchdog roundups within my search budget, so their treatment of this case remains unverified; I make no claim about their contents beyond the above. No outlet reported any damages figure, settlement term, or verdict in this case — the only reported monetary demand was Flexiworld's boilerplate request for a reasonable royalty (LawStreet/Voicebot), and no publication I found reported the terms (or even the existence) of the 2025 case termination.
Sources
- Patent Filings Roundup: Suits Explode at End of Q2; Fortress 4G LTE Multi-District Litigation Against Auto Industry Goes to Michigan; Rare Derivation Denial - 2:22-cv-11404 | Filed | Neo Wireless LLC Softbank Group, Fortress IP | Volkswagen
- patent filings roundup Archives - Posts Tagged: "patent filings roundup"
- USPTO Archives - Posts Tagged: "USPTO"
- Filed on behalf of: Flexiworld Technologies, Inc
- SVV Technology Innovations, Inc
- U.S. District Court Eastern District of Kentucky (Lexington) CIVIL DOCKET FOR CASE #: 5:22-cv-00110-KKC
- Filed on behalf of: Flexiworld Technologies, Inc
- 55. Flexiworld has been damaged as a result of Lexmark's infringing conduct
- Flexiworld Technologies, Inc
- ¹¹ In attempting to stage another “gotcha moment” against Flexiworld in its reply brief, Lexmark states, “Flexiworld fails to in...
- patent troll Archives - Voicebot.ai
- Amazon Sued over Smart Speaker, Tablet Patents
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Nelson Bumgardner Conroy
- Timothy E. Grochocinski · lead counsel
- Charles Austin Ginnings · lead counsel
- Edward R. Nelson III · counsel
- Jonathan H. Rastegar · counsel
- Harrigan Leyh Farmer & Thomsen
- Arthur W. Harrigan Jr. · local counsel
- Tyler Lawrence Farmer · local counsel
- Bryn Resser Pallesen · local counsel
- In-house counsel
- Chelsey Lyn Mam · counsel
Counsel of Record — Plaintiff Flexiworld Technologies, Inc.
Case background relevant to counsel: This case began as Flexiworld Technologies, Inc. v. Amazon.com, Inc. et al., No. 6:20-cv-00553-ADA (W.D. Tex., Judge Albright), was transferred, and was re-filed in the Western District of Washington as 2:21-cv-01055 on Aug. 3, 2021 (UniCourt case summary; DocketAlarm). It was reassigned from Judge Richard A. Jones to Judge David G. Estudillo (Dkt. order 10/18/2021). The claims-construction order (Dkt. 161, 3/5/2024) confirms the '846 patent (claim 7, "data generation software component") is at issue alongside the '521 patent. The plaintiff's team is split between out-of-state lead counsel (Nelson Bumgardner Conroy PC) and Seattle local counsel.
Lead / out-of-state counsel — Nelson Bumgardner Conroy PC (formerly Nelson Bumgardner Albritton PC)
Timothy E. Grochocinski — Lead counsel. Designated "LEAD ATTORNEY" for Flexiworld on the transferor-court docket (6:20-cv-00553, W.D. Tex.; docket sheet filed as Ex. 2032 in IPR2021-00715). Offices: 15020 S. Ravinia Ave., Suite 29, Orland Park, IL (also Fort Worth, TX and Burr Ridge, IL per Martindale). Filed the Dkt. 119 change-of-address/firm-name notice (10/15/2021) in this case and appeared for Flexiworld at the 2/23/2023 status conference (Dkt. 136 minute entry: "Pla Counsel: Tim Grochocinski"). Experience: Senior partner at Nelson Bumgardner Conroy; lead Flexiworld enforcement counsel in numerous district-court actions (e.g., v. Epson, Canon, Sony, Kyocera, Indeed) and in PTAB IPR defense of Flexiworld patents.
Charles "Austin" Ginnings — Lead/PHV counsel. Admitted pro hac vice in this case by order dated 10/14/2021 (Dkt. 118; application Dkt. 114). Nelson Bumgardner Conroy PC, Orland Park, IL (austin@nelbum.com). Appeared for Flexiworld at the 2/23/2023 status conference (Dkt. 136). Experience: Frequent lead/back-up PTAB counsel for Flexiworld (e.g., lead counsel in IPR2023-00845/00846 and IPR2022-00775, per USPTO PTAB filings).
Edward R. Nelson III — Counsel (out-of-state). Listed on the case's attorney roster (UniCourt). Founding partner, Nelson Bumgardner Conroy PC, Fort Worth, TX. (The Patexia firm-profile page also attributes this case to Nelson Bumgardner's docket.) Experience: Long-running plaintiff-side patent trial/IPR practice, including prior Flexiworld enforcement campaigns.
Jonathan H. Rastegar — Counsel (out-of-state). Listed on the case's attorney roster (UniCourt). Nelson Bumgardner Conroy PC. Experience: Patent litigation associate/partner with the Flexiworld enforcement team.
Local counsel — Seattle, WA
Arthur W. Harrigan, Jr. — Local counsel. Listed on the case roster (UniCourt). Founding partner, Harrigan Leyh Farmer & Thomsen LLP, Seattle. Experience: Longtime Seattle IP litigator and the firm's namesake; handles local-counsel duties for out-of-district patent plaintiffs, including under W.D. Wash. LCR 83.1(d).
Tyler Lawrence Farmer — Local counsel. Listed on the roster (UniCourt) and filed Ginnings' pro hac vice application (Dkt. 114), a function local counsel typically performs in W.D. Wash. Partner at Harrigan Leyh Farmer & Thomsen LLP, Seattle (firm name includes Farmer). Experience: Seattle IP litigation, including local-counsel roles for Flexiworld's Washington cases.
Bryn Resser Pallesen — Local counsel (appeared 10/13/2021). Dkt. 117: "NOTICE of Appearance by attorney Bryn Resser Pallesen on behalf of Plaintiff Flexiworld Technologies Inc." Patexia's docket entry associates her filing with Tyler Farmer, consistent with membership at Harrigan Leyh Farmer & Thomsen LLP, Seattle — though her firm is not directly confirmed in the sources I retrieved.
Chelsey Lyn Mam — Counsel (appeared 9/12/2022). Patexia docket entry: "NOTICE of Appearance by attorney Chelsey Lyn Mam on behalf of Plaintiff Flexiworld Technologies Inc." She also appeared for Flexiworld at the 2/23/2023 status conference (Dkt. 136: "Pla Counsel: ... Chelsey Mam"). Firm not confirmed in the retrieved sources — likely Nelson Bumgardner Conroy PC given the team pattern, but I could not verify this.
Notes and caveats
- Earlier counsel who are no longer on the case: In the transferor W.D. Tex. action, Flexiworld was also represented by Eric M. Albritton and Andrew J. Wright (Albritton Law Firm, Longview, TX); Judge Albright granted their withdrawal motions on 2/23/2021 (text orders on Dkts. 65–66), before transfer to W.D. Wash. They are not counsel of record here.
- Sealing/access: No filings relevant to plaintiff counsel appear sealed; the appearances, PHV orders, and status-conference minutes are public docket entries.
- Confidence levels: Grochocinski (lead), Ginnings (PHV), Harrigan, Farmer, and Pallesen are well-supported by docket entries. Nelson's and Rastegar's participation rests on the UniCourt attorney roster (which merges plaintiff and defendant attorneys), so I could not definitively confirm which side each was on — though Nelson is a name partner of Flexiworld's lead firm and Rastegar practices there. Pallesen's and Mam's firm affiliations were not directly verified.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Perkins Coie
- Daniel T. Shvodian · lead counsel
- Amisha Manek · lead counsel
- Stefani E. Shanberg · trial counsel
- Christopher Kelley
- Wing H. Liang · former counsel
- Stevan Richard Stark, Jr. · local counsel
- Christina J. McCullough · local counsel
- Theresa H. Nguyen · local counsel
- M. Craig Tyler
- In-house counsel
- Patrick McKeever · defense counsel
I have good leads. Now let me drill into the specific defense counsel — Perkins Coie appears to be Amazon's counsel. Let me verify each attorney and look for the full roster.
Defendant's Counsel of Record — Flexiworld Technologies, Inc. v. Amazon.com, Inc., No. 2:21-cv-01055-DGE (W.D. Wash.)
Amazon's defense is led by Perkins Coie LLP, with a Palo Alto–based trial team and Seattle-based local counsel. The identification below is drawn from the transferred W.D. Tex. docket (6:20-cv-00553-ADA), the W.D. Wash. docket entries (via UniCourt/Patexia), and the 2/23/2023 status-conference minute entry. Note: UniCourt's public attorney list for this case is partial ("9 More Attorneys Available"), and some roles below are inferred from firm practice and the docket rather than a formal designation order.
Lead / trial counsel (Perkins Coie LLP — Palo Alto)
- Daniel T. Shvodian — Lead counsel (trial team). Partner, Perkins Coie LLP, Palo Alto, CA (3150 Porter Drive). Appeared as defense counsel at the 2/23/2023 Markman/status conference (Patexia minute entry, Dkt. 136). Deep Amazon patent-litigation pedigree: he was lead counsel for Amazon in PTAB IPR2017-00948 and represents Amazon in other W.D. Tex./W.D. Wash. matters (e.g., VoIP-PAL.com v. Amazon). Background in electrical engineering; handles district-court, PTAB, ITC § 337, and Federal Circuit work.
- Amisha Manek — Lead attorney on the original W.D. Tex. docket. Perkins Coie LLP, Palo Alto, CA. The 6:20-cv-00553 docket sheet lists her as "LEAD ATTORNEY / PRO HAC VICE / ATTORNEY TO BE NOTICED" for the Amazon defendants (DocketAlarm exhibit in IPR2021-00715).
- Stefani E. Shanberg — Trial-team associate/partner, Perkins Coie LLP (Palo Alto office per the firm's Amazon engagement in VoIP-PAL.com). Admitted pro hac vice in W.D. Wash. in Feb. 2023 (Dkt. 132 application, filed by McCullough; Dkt. 133 order); appeared as defense counsel at the 2/23/2023 status conference.
- Christopher Kelley — Perkins Coie LLP, Palo Alto, CA. Listed among this case's attorneys on UniCourt; part of Perkins Coie's Amazon defense team in parallel matters (e.g., VoIP-PAL.com v. Amazon, where he is identified with the Palo Alto office). Role in this specific case: inferred; not independently confirmed by a filing I retrieved.
- Wing H. Liang — Perkins Coie LLP; former counsel. Withdrew as counsel for defendants by W.D. Tex. text order (2/23/2021, granting Dkt. 63).
Local / Seattle counsel (Perkins Coie LLP — Seattle, 1201 Third Avenue)
- Stevan Richard Stark, Jr. — Local counsel / Seattle team. Partner, Perkins Coie LLP, Seattle, WA. Listed on the W.D. Tex. docket as "ATTORNEY TO BE NOTICED"; appeared as defense counsel at the 2/23/2023 status conference; Law360's case database confirms him on this exact case (W.D. Wash., filed 8/3/2021).
- Christina J. McCullough — Seattle coordinating/local counsel. Perkins Coie LLP, Seattle, WA. Filed the defense's 10/8/2021 Notice of Pending Motions (Dkt. 116) and the Feb. 2023 PHV application for Shanberg (Dkt. 132). Listed on the Texas docket as PHV (because she is Washington-based) — i.e., she became the natural local counsel after transfer.
- Theresa H. Nguyen — Local counsel. Perkins Coie LLP, Seattle, WA (1201 Third Avenue, 49th Floor). Listed on the W.D. Tex. docket as "ATTORNEY TO BE NOTICED" for the Amazon defendants.
Other identified defense-side attorneys
- Patrick McKeever — Appeared as defense counsel at the 2/23/2023 status conference alongside Shvodian, Stark, and Shanberg (Dkt. 136 minute entry). Firm/office not confirmed in the materials I retrieved (he is very likely Perkins Coie, but I could not verify).
- M. Craig Tyler — Perkins Coie LLP, Austin, TX (500 W 2nd St., Suite 1900; per the firm's Amazon engagement in VoIP-PAL.com). Appears in UniCourt's attorney list for this case. Role here inferred; not confirmed by a specific filing I retrieved.
- Scott Sanford and Moeka Takagi — Present "for Amazon" at the 2/23/2023 technology tutorial and made technical presentations (Dkt. 136). Likely in-house Amazon counsel or technical advisors; the minute entry does not specify their firm. Flagged as unverified.
In-house / additional counsel
- The docket shows several early W.D. Tex. PHV admission orders (Dkts. 12–18) for the Perkins Coie team that I could not map to individual names from the retrieved snippets. Any Amazon in-house counsel (e.g., from Amazon's litigation group) would appear on sealed or non-public portions of the docket; I found no public appearance by an Amazon in-house attorney other than the Sanford/Takagi technology-presentation entry.
Verification notes / flags
- Sealed/withdrawn counsel: No defense filings appear to be sealed as to counsel identities; the case does have sealed substantive filings. Wing H. Liang's withdrawal is the only defense-side withdrawal I confirmed.
- Cross-check with prior summary: DocketAlarm now shows this case "Terminated July 28, 2025" with flags CLOSED, JURYDEMAND, STAYED, TRANSIN — this resolves the earlier "final disposition not confirmed" gap (a stay was evidently in place at some point; the closing event itself is still not identified from a docket text I retrieved). Nothing in the new results contradicts the claim-construction order (Dkt. 161, 3/5/2024) or the '846 patent's survival through Markman.
- Primary sources: W.D. Tex. docket sheet for 6:20-cv-00553 (DocketAlarm PDF exhibit, IPR2021-00715); UniCourt case page 984796 (W.D. Wash. docket entries 113–119); Patexia documents page (minute entries Dkts. 128, 131, 136; PHV Dkts. 132–133); Law360 attorney case list (Stark); Perkins Coie/StartUp Percolator profiles (Shvodian); DocketAlarm case page (termination date).