Litigation

Flexiworld Technologies, Inc. v. Amazon.com Inc. et al.

terminated

2:21-cv-01055

Filed
2021-08-03
Terminated
2025-07-28

Patents at issue (1)

Summary

Flexiworld Technologies sued Amazon entities for patent infringement in W.D. Wash. The case had standing motions, a motion to stay, and a claim-construction order addressing an authentication procedure term; it terminated July 28, 2025. The narrative states that US 9,110,622 was not confirmed as asserted; docket text referenced other Flexiworld patents by short forms.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

I'll research this case thoroughly using web searches.

Let me dig deeper into the parties, patents, and procedural history.

Let me get the docket details, asserted patents, and the termination.

Case Overview & Background — Flexiworld Technologies, Inc. v. Amazon.com, Inc. et al., No. 2:21-cv-01055-DGE (W.D. Wash.)

The parties. Flexiworld Technologies, Inc. is a small, Vancouver, Washington–based patent owner founded around 2000 by inventor William Ho Chang (with co-inventor Christina Ying Liu), whose portfolio claims priority to provisional applications filed in 2000–2001 covering wireless/"over-the-air" printing and digital-content output. It is best characterized as a hybrid: an original operating startup turned patent-monetization entity. Flexiworld has asserted the same family of patents in a broad campaign against printer OEMs (Brother, Lexmark, Epson, Canon, Samsung), consumer-electronics makers (Hisense, Sony, Roku), and now Amazon — a pattern typical of a PAE/NPE, though the patents trace to genuine in-house R&D rather than acquisition. The defendants are the Amazon corporate family: Amazon.com Inc., Amazon.com Services Inc., Amazon Web Services Inc., and Amazon.com LLC. (DocketAlarm docket; Lexmark IPR petition listing the Flexiworld campaign, PTAB)

The accused technology and patents. As Flexiworld's non-party discovery against the Mopria Alliance makes explicit, the core infringement theory concerns Amazon Fire tablets that ship with the "Mopria Print Service" app preinstalled — a mobile-printing client developed by the Mopria Alliance (the printer-industry standards consortium whose members include Canon, HP, Xerox, Epson, Brother, Samsung, etc.) and supplied to Amazon for inclusion in certain Fire devices. Flexiworld's theory is that wireless discovery of a LAN printer and generation/transmission of printer-ready output data from the Fire tablet practicess its claims; the joinder of Amazon Web Services and Amazon.com LLC suggests the accused conduct may extend beyond tablets to Amazon-hosted services, though I could not verify specific AWS-hosted functionality in the public record. (Mopria motion to quash, N.D. Cal. 4:25-mc-80055) The case metadata lists U.S. Patent No. 9,110,622 as the patent at issue, but the assertion record actually litigated is murkier: the court's March 5, 2024 claim-construction order (Dkt. 161) construed terms from the '521 patent, claim 15 (an "Internet-Pad" — a wireless mobile apparatus with touchscreen, camera, e-mail app, and "output manager software" that conforms selected digital content into output data and sends it wirelessly to a selected output device) and the '846 patent, claim 7 (U.S. 10,481,846, "Software Applications and Information Apparatus for Printing Over Air or for Printing Over a Network" — generating print data at a mobile device based on device information received from a discovered LAN printer, without a printer-specific driver). I could not independently confirm that the '622 patent was ever actually asserted on the docket, consistent with the prior narrative flagging that "US 9,110,622 was not confirmed as asserted." (Claim Construction Order, Dkt. 161)

Procedural posture and why it matters. The case was docketed in the Seattle Division of the Western District of Washington before U.S. District Judge David G. Estudillo, filed August 3, 2021 and terminated July 28, 2025, with case flags reflecting a stay and a transfer-in (TRANSIN). Venue was materially contested — the dispute arrived in Seattle notwithstanding Flexiworld's Texas filing history, and Amazon's home forum is significant because Amazon is headquartered in Seattle and the accused Fire-tablet conduct is centered there. Early procedural skirmishes included a challenge to Flexiworld's standing and Amazon's successful motion to compel production of Flexiworld's license and assignment agreements (unopposed discovery order), a motion to stay (the docket stayed discovery for a period, reopening around May 2024), and the March 2024 Markman ruling, which rejected Amazon's § 112 ¶ 6 indefiniteness attack on the '846 "data generation software component" term (following WSOU Investments v. Google) but construed "output manager software" in the '521 patent. The case's notability is threefold: (1) it is a leading test of Flexiworld's wireless-printing family against a major platform rather than a printer OEM; (2) it produced an unusual non-party discovery fight with a standards body — Flexiworld subpoenaed Mopria for documents and Rule 30(b)(6) testimony, including inspection of Mopria's confidential source code, and Mopria's motion to quash was transferred from N.D. Cal. to W.D. Wash. (2:25-mc-00018, Judge John H. Chun) and then dismissed by joint stipulation on April 22, 2025 — raising standard-setting-organisation and third-party-burden issues; and (3) the same patent family has generated PTAB activity (e.g., Roku's IPR2021-00714 on U.S. 8,989,064 and Lexmark's IPRs against the '402 patent), so the Amazon case sits within an active IPR/monetization ecosystem and the parties' parallel-patent outcomes were likely a driver of settlement or dismissal.

Sourcing caveats: the specific termination document for the main case (e.g., a stipulated dismissal or settlement) is not confirmed in the public records I could retrieve; the exact scope of accused products beyond Fire tablets and the identity/number of the '521 patent are not confirmed; and the role of U.S. 9,110,622 (the metadata-listed patent) is unverified against the docket. Where the case metadata and web sources diverge, I have followed the metadata for party names, court, case number, and the '622 patent.

Key legal developments & outcome

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

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

Let me dig into the docket details, transfer, and the specific motions.

Now let me pull the docket timeline and key orders.

I hit my research budget before I could pull every docket entry, so below I've separated well-sourced facts from items I could not confirm. I'd rather flag gaps than invent entries.

Flexiworld Technologies, Inc. v. Amazon.com, Inc., No. 2:21-cv-01055-DGE (W.D. Wash.)

Important framing: 2:21-cv-01055 is a transferred-in case (docket flag TRANSIN). Its real origin is Flexiworld Technologies, Inc. v. Amazon.com, Inc., No. 6:20-cv-00553-ADA (W.D. Tex., Waco Div.), filed June 2020 before Judge Alan D. Albright, and it landed in the Western District of Washington in August 2021. Any chronology that starts at the 2021-08-03 "filing date" misses the first 14 months of the case. (Mopria's motion to quash recites "Flexiworld filed this lawsuit in June 2020"; DocketAlarm docket sheet shows Transferred from txwd on 8/9/2021 entries and the TRANSIN flag.)


1. Filing and initial pleadings (W.D. Tex. phase)

  • 2020-06-25 (approx.): Complaint filed in W.D. Tex. (6:20-cv-00553-ADA). Scope was large: 10 asserted patents / 91 asserted claims — Amazon's own motion states "Flexiworld has asserted 91 claims across 10 patents against Amazon," covering printing, audio/video retrieval and transmission, content manipulation, voice commands, touch controls, speakers, wireless data transmission, and "authenticating users and/or devices." (Amazon's Opposed Motion to Exceed Presumptive Limit of Claim Terms, Dkt. 50 in the W.D. Tex. case, dated 2020-12-02.) This breadth matters because the case summary's single-patent framing (US 9,110,622) understates what was actually pleaded.
  • 2020-07-17: Defendant's unopposed extension granted — response due 2020-08-17.
  • 2020-08-17: Amazon's Answer (with jury demand) filed in W.D. Tex., later transferred. Counterclaims: I could not locate the counterclaim text; it is likely the answer included declaratory-judgment counterclaims of non-infringement/invalidity, but I have no sourced confirmation and will not assert it.
  • 2020-09-03: Scheduling conference. The minute entry records that Amazon told Judge Albright it would file (i) a motion to transfer to W.D. Wash. and (ii) a motion as to jurisdiction (standing), and that the court directed the jurisdiction motion be heard first.
  • 2020-09-04 – 2020-10-26: Amazon's unopposed motion for discovery of all license and assignment agreements (Dkt. 26) was granted — an early, deliberate shot at Flexiworld's chain of title.
  • 2020-12-02: Amazon's motion to construe 16 claim terms (above the presumptive 12-term limit), previewing § 112 ¶ 6 indefiniteness attacks on output manager software ('521) and software component stored at the memory unit of the wireless controller ('064).
  • Schedule originally set: Markman 2021-02-05; jury trial 2022-02-07; motions deadline 2021-11-12. None of these held once the transfer landed.

2. Venue transfer → W.D. Wash.

  • 2021-08-03 / 2021-08-09: Case transferred to W.D. Wash., Seattle Division, opened as 2:21-cv-01055. The case carried in the pending motions and the STAYED flag.
  • 2021-10-18: Reassigned from Judge Richard A. Jones to Judge David G. Estudillo.

3. Pre-trial motions of substance

Docket Motion Notes
Dkt. 34 Amazon's first opposed motion for partial dismissal for lack of standing Carried over from Texas; noted 2021-10-15
Dkt. 74 Amazon's opposed motion to stay (paired with the IPR campaign) Noted 2021-10-15
Dkt. 82 Amazon's second motion for partial dismissal for lack of standing — expressly directed at the '087, '846 and '064 patents Per the court's 2021-10-12 notice
  • 2021-10-12: The court deferred entry of a Rule 16 scheduling order pending rulings on Dkts. 34, 74 and 82 — i.e., the case went into procedural limbo on standing and stay grounds almost immediately after transfer.
  • Standing theory: Amazon's challenge was chain-of-title based, tied to a Flexiworld–Samsung agreement. In a parallel W.D. Tex. Flexiworld case, the court on 2022-06-06 rejected the same theory, holding the Samsung Agreement § 1.1.1 assigned only four specific items (the '541 patent, the '958 application, and two continuations) and did not assign the '064/'066 patents, relying on Washington's "context rule" and extrinsic evidence (letter of intent, Samsung's silence during 10 years of Flexiworld prosecution). See Doc. 198, No. 6:20-cv-00819-ADA (W.D. Tex. June 6, 2022). (Case-number caveat: I could not fully reconcile this number against Lexmark's IPR petition, which lists a Flexiworld v. Roku case as 6:21-cv-00680-ADA. The substance of the June 6, 2022 standing ruling is sourced; treat the case number as approximate.) That decision specifically notes the Amazon case "was stayed pending resolution of a motion to dismiss and remains pending in the Western District of Washington."
  • Motion to stay / stay mechanics: The STAYED flag never cleared. Flexiworld's subpoena history with Mopria states that discovery was stayed and then "reopened" in May 2024. Combined with a Jan. 2023 Markman status conference, the most likely sequence is a stay of the case pending IPR, lifted in stages (claim construction allowed to proceed in 2023, fact discovery reopened ~May 2024). I could not source the precise stay/lift dates or the order granting Dkt. 74 — flagging that as unverified.

4. Claim construction (Markman)

  • 2023-01-12: Flexiworld files Notice of Prior Claim Construction Rulings (Dkt. 127), attaching preliminary constructions and the CC hearing transcript.
  • 2023-01-17: Status conference re: Markman before Judge Estudillo (Dkt. 126).
  • 2024-03-05: Order Regarding Claim Construction (Dkt. 161) — the substantive pretrial ruling of the case. Two disputed terms:
    • output manager software (claim 15, the '521 patent) — this is the limitation that recites "obtaining, authentication or security information provided by the user," i.e., the authentication-procedure term referenced in the case summary.
    • data generation software component (claim 7, the '846 patent).
    • The court applied Williamson v. Citrix and WSOU Investments LLC v. Google LLC, 2023 WL 6889033 (Fed. Cir. Oct. 19, 2023), held Amazon bore the § 112 ¶ 6 burden, and rejected the indefiniteness attack on the '846 term — finding the claim combined the nonce-ish term with a description of what it must accomplish, conveying definite structure to a POSITA. This was a plaintiff-favorable outcome on the means-plus-function/indefiniteness fight that Amazon had been setting up since December 2020.

5. Discovery milestones with strategic significance

  • 2021-06: Flexiworld serves subpoenas on Mopria Alliance (documents + Rule 30(b)(6) deposition), targeting the Mopria Print Service app shipped on Amazon Fire tablets — a third-party liability theory, since Mopria (a standards body with no employees, run by contractor Inventures) developed the app Amazon used.
  • 2024-05: Discovery reopens; subpoenas re-served on Mopria.
  • 2024-06-07: Mopria serves objections; disputes burden given it has no employees and code maintained by a contractor in Bangalore.
  • 2024-07-01 to 2024-10-31: Mopria produces ~1,200+ pages.
  • 2024-10-22/23: Flexiworld's expert inspects Mopria Print Service source code; 2024-10-30: 64 pages produced under the protective order.
  • 2025-03-28 – 2025-04-23: The subpoena fight spills into an ancillary proceeding — Mopria's motion to quash removed from N.D. Cal. (4:25-mc-80055) to W.D. Wash. as 2:25-mc-00018 (Judge John H. Chun), Mopria moved to quash (Dkt. 9), and the parties stipulated to dismiss the ancillary action without prejudice (Dkt. 17, filed 2025-04-22; terminated 2025-04-23). Note the timing: the third-party discovery dispute was still being litigated three months before the main case terminated.

6. Trial, verdict, post-trial motions

None. No trial, verdict, JMOL, new-trial, or fee motion is reflected. Claim construction (2024-03-05) was the last substantive merits ruling; discovery was the last active phase.

7. Final disposition

  • 2025-07-28: Case terminated (docket sheet, DocketAlarm: "Terminated July 28, 2025"; flags CLOSED / JURYDEMAND / STAYED / TRANSIN). Judge Estudillo presiding throughout.
  • Caveat: I could not retrieve the terminating document itself. It is consistent with a stipulated dismissal/settlement (Flexiworld has a portfolio-wide pattern of settling — Roku dismissed Oct. 28, 2022; Epson Feb. 1, 2022; Brother Mar. 13, 2023; Hisense Apr. 7, 2023), but I have no sourced confirmation, and there is no reported judgment, consent judgment, or injunction. No appeal is docketed; given termination in July 2025, any notice of appeal deadline (Fed. R. App. P. 4(a)(1)(A)) would have run in late September 2025 — worth checking the Federal Circuit docket directly.

8. Parallel PTAB proceedings

  • Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00714 — petition filed 2021-04-09 on U.S. Patent No. 8,989,064 (Ikonen/Beck and Yamaguchi/Gu obviousness grounds). The '064 patent was asserted against Amazon (it is one of the three patents in Amazon's second standing motion, Dkt. 82), so this IPR is squarely parallel to this case and is the most plausible driver of the stay.
  • Additional Roku petitions: IPR2022-01112 and IPR2022-01269 (per an expert declaration in the PTAB record); IPR2022-01114 on U.S. 9,965,233, which was terminated/settled before institution on 2022-11-28. Roku's W.D. Tex. case settled 2022-10-28.
  • Lexmark v. Flexiworld, IPR2023-00845 (U.S. 7,609,402) and a companion petition on U.S. 9,965,233 — same portfolio, different defendants.
  • A petition invoking both the W.D. Wash. Amazon case and an E.D. Tex. case appears in the PTAB record, arguing that "the WDWA case is still in its infancy and has yet to receive a scheduling order," that "the WDWA court adopts a 'liberal policy' in favor of granting such stays" (New World Medical v. MicroSurgical Technology, 2021 WL 952456 (W.D. Wash. Feb. 18, 2021); Supercell Oy v. Rothschild, 2016 WL 9226493 (W.D. Wash. July 28, 2016)), and estimating a WDWA trial date around July 2025 — about five months after its expected final written decision. I could not confirm whether the petitioner was Amazon, so I am not attributing an Amazon IPR to this case. If Amazon did file, it would explain the STAYED flag and why fact discovery idled.

Bottom line

This was a broad, 10-patent/91-claim campaign that Amazon venue-transferred out of Judge Albright's court and then effectively neutralized without a merits trial. Amazon's two standing/chain-of-title motions (Dkts. 34, 82) and its stay motion (Dkt. 74) arrested the case immediately post-transfer; a parallel Texas ruling (June 6, 2022) went against Amazon on the same Samsung-assignment theory; Flexiworld won the one real merits ruling (the 2024-03-05 claim construction rejecting § 112 ¶ 6 indefiniteness on the '521 authentication term and the '846 term); discovery on the Mopria Print Service app was still being fought over in ancillary proceedings in April 2025; and the case closed on 2025-07-28 without trial or judgment.

Two corrections to the existing case summary, subject to confirmation: (1) US 9,110,622 does not appear in any ruling or docket text I found — the patents actually construed were the '521 and '846, and the patents at issue in the standing motions were the '087, '846, '064, consistent with the narrative's note that the '622 was never confirmed as asserted. (2) The case summary's "motion to stay" was one of three dispositive-threshold motions (two standing motions plus the stay), which is the real strategic core of this case.

Plaintiff representatives

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

I'll research the plaintiff's counsel of record for this case.

I hit my search-step limit before I could pull the full PACER docket sheet line-by-line, so below I've flagged precisely what is sourced and what remains unverified. Everything named below comes from docket text I actually retrieved (W.D. Tex. 6:20-cv-00553-ADA docket sheet, the W.D. Wash. ancillary docket 2:25-mc-00018, CourtListener/UniCourt docket extracts, and the Dkt. 161 claim-construction order caption), not from inference.

Plaintiff's Counsel of Record — Flexiworld Technologies, Inc. v. Amazon.com, Inc., No. 2:21-cv-01055-DGE (W.D. Wash.)

Threshold point: the plaintiff's team came with the case from Texas

Because this case is a transfer-in (TRANSIN) from 6:20-cv-00553-ADA (W.D. Tex., Waco) — as the prior section established — the plaintiff's substantive/lead counsel are the Texas-based Nelson Bumgardner Albritton PC ("NBA") team, and the Western District of Washington attorneys function as local counsel under LCR 83.1(d). Docket text from the ancillary Mopria matter confirms the court's local-counsel requirement being applied to this plaintiff: "NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present…" (2:25-mc-00018, Dkt. 14, admitting C. Austin Ginnings pro hac vice).


1. Lead / trial counsel (Nelson Bumgardner Albritton PC)

Attorney Role Firm & office Notes
Timothy E. Grochocinski Lead attorney (so designated on the W.D. Tex. docket, carried into W.D. Wash.); PTAB-side counsel Nelson Bumgardner Albritton PC, 15020 S. Ravinia Ave., Suite 29, Orland Park, IL 60462 Admitted pro hac vice in W.D. Wash. via Dkt. 113 (application filed by Tyler Farmer; admitted by Clerk Ravi Subramanian, Oct. 2021). Also listed as Flexiworld's service counsel in Roku's IPR2021-00714 mandatory notice (tim@nbafirm.com). Filed a notice of change of address in this case (Dkt. 119).
C. Austin Ginnings (Charles Austin Ginnings) Lead attorney (designated LEAD on the W.D. Tex. docket); Flexiworld's active pro hac vice attorney through the end of the case Nelson Bumgardner Albritton PC, Orland Park, IL Admitted pro hac vice in W.D. Wash. via Dkt. 114 (Oct. 2021). Still appearing for Flexiworld in April 2025 in the Mopria ancillary matter, signing the Dkt. 16 declaration in 2:25-mc-00018 in support of Flexiworld's opposition to Mopria's motion to quash.
Edward R. Nelson, III Attorney of record (W.D. Tex. phase and carried on the W.D. Wash. docket listing) Nelson Bumgardner Albritton P.C., 3131 W. 7th Street, Suite 300, Fort Worth, TX 76107 Named-firm partner; part of the original Flexiworld team in 6:20-cv-00553-ADA.
Jonathan H. Rastegar Attorney of record Nelson Bumgardner Albritton P.C., Fort Worth, TX Appears on the W.D. Tex. docket for Flexiworld; carried onto the W.D. Wash. docket listing.
Ryan Griffin Attorney of record Nelson Bumgardner Albritton PC, Fort Worth, TX Same — plaintiff-side NBA attorney on both docket listings.

Withdrawn / departed NBA counsel (Texas phase, before transfer):

  • Eric M. Albritton — NBA (Longview, TX) — withdrew by unopposed motion, granted by Judge Albright (Dkt. 65/66 text order, noted Feb. 23, 2021).
  • Andrew J. Wright — NBA (Fort Worth, TX) — withdrew on the same order.
  • Joseph Paul Oldaker — NBA (Orland Park, IL) — terminated as counsel 06/02/2021 per the W.D. Tex. docket sheet.

Caveat: I also saw, in PTAB filings, NBA attorneys Brent Bumgardner and Robert A. Delafield II listed as Flexiworld's attorneys of record for the Roku IPRs (brent@nbafirm.com, bobby@nbafirm.com). I did not find them on the Amazon district-court docket and am therefore not listing them as counsel of record in this case.


2. Local counsel (W.D. Wash.) — Harrigan Leyh Farmer & Thomsen LLP, Seattle

Attorney Role Firm & office Notes
Tyler Lawrence Farmer Local counsel — the attorney who actually signed and filed the plaintiff's papers in W.D. Wash. (e.g., the July 29, 2022 Joint Status Report, Dkt. 123; the pro hac vice applications at Dkts. 113–114) Harrigan Leyh Farmer & Thomsen LLP, Seattle, WA, during the case; since 2025, Martinez & Farmer LLP, 4020 East Madison St., Suite 300, Seattle, WA 98112 (he co-founded the firm in 2025) Seattle trial lawyer; Best Lawyers (Appellate, Commercial Litigation, Litigation–IP) since 2018, Chambers USA–ranked, Super Lawyers Top 100 WA (2020–2024). Litigation–IP practice, though his practice is broader commercial/bet-the-company litigation rather than a pure patent practice. He also appeared as local counsel in the Mopria ancillary case (2:25-mc-00018, Dkt. 12, Apr. 9, 2025).
Arthur W. Harrigan, Jr. Local counsel — named on the W.D. Wash. docket attorney listing for Flexiworld Harrigan Leyh Farmer & Thomsen LLP, Seattle, WA Founding partner of the Seattle litigation boutique. Caveat: he appears on the Unicourt attorney list for this case but I could not retrieve a specific docket entry showing him signing a filing; treat his level of involvement as unconfirmed.
Bryn Resser Pallesen Local counsel (short tenure) Harrigan Leyh Farmer & Thomsen LLP at the time (notice of appearance Dkt. 117, Oct. 13, 2021); withdrew Sept. 12, 2022 (via Dkt. 124, filed by Tyler Farmer). Washington-licensed (WSBA #57714), Michigan Law J.D. 2011; later at Bryan Cave and now Orrick, Herrington & Sutcliffe LLP, Seattle (Senior Associate; antitrust/complex commercial litigation). Her practice is not patent-focused.
Chelsey Lyn Mam Local counsel Firm not verified — most likely Harrigan Leyh Farmer & Thomsen given the pattern of Seattle local counsel, but I could not source it, and I will not assert it. Appeared by Notice of Appearance, Dkt. 125, Sept. 15, 2022 — one business day after Pallesen's withdrawal, which suggests a direct replacement as the Seattle-side support attorney.

3. What I could not confirm

  • A complete roster of appearances. I worked from third-party docket aggregators (Unicourt's party-attorney list, Patexia's document feed, CourtListener's RECAP docket) plus the W.D. Tex. docket sheet. The Unicourt listing for this case shows a mixed plaintiff/defendant attorney list and notes "9 More Attorneys Available." I could not open every appearance entry on the W.D. Wash. docket directly, so a late-appearing or short-tenure plaintiff attorney could be missing.
  • Whether the plaintiff changed lead counsel or firms at any point in 2023–2025. I found no withdrawal or substitution notice for Grochocinski or Ginnings, but I did not exhaustively search docket entries after Dkt. 161 (Mar. 5, 2024).
  • Sealed filings. The case had multiple motions for leave to file under seal in the Texas phase (Dkts. 32, 36, 39, 48). If any sealing order covered an appearance-related filing, it would not be reflected in public docket text.
  • Whether Flexiworld had any in-house counsel of record. Flexiworld is a small Vancouver, WA–based patent owner; I found no in-house attorney appearing on the docket. William Ho Chang (founder/inventor) is a party-affiliated individual but not counsel of record.

4. One cross-check for the prior sections

Consistent with the earlier-generated narrative, the docket-text attorney attribution confirms that the Perkins Coie attorneys on the Unicourt list (Daniel T. Shvodian, M. Craig Tyler, Amisha Manek, Christina J. McCullough, Stevan R. Stark, Jr., Theresa H. Nguyen, Ruchika Verma, Christopher Kelley, Wing H. Liang) are Amazon's (defendant's) counsel — e.g., the Dec. 2, 2020 signature block (/s/ Daniel T. Shvodian, M. Craig Tyler, Bar No. 794762, PERKINS COIE LLP), and Judge Albright's text order granting Wing H. Liang's withdrawal as Defendants' counsel. So the plaintiff's side is the Nelson Bumgardner + Harrigan Leyh pairing described above. Note also that Perkins Coie appears on both sides of the Flexiworld ecosystem — Perkins Coie represents Roku and Lexmark as IPR petitioners against Flexiworld while representing Amazon in this case.


Bottom line: Flexiworld's counsel of record in this case was Timothy E. Grochocinski and C. Austin Ginnings of Nelson Bumgardner Albritton PC (Orland Park, IL) as lead/pro hac vice counsel, supported by NBA colleagues Edward R. Nelson III, Jonathan H. Rastegar and Ryan Griffin (Fort Worth, TX), with Tyler Lawrence Farmer, Arthur W. Harrigan, Jr. (and briefly Bryn Resser Pallesen and Chelsey Lyn Mam) of Harrigan Leyh Farmer & Thomsen LLP, Seattle as the LCR 83.1(d) local counsel.

Defendant representatives

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

I'll research defendant counsel using docket records, firm announcements, and court filings.

Good progress. Let me pin down the specific appearances, substitutions, and local counsel on the W.D. Wash. docket.

Let me pin down the Fenwick appearance dates, local counsel, and whether Perkins Coie withdrew.

I hit my research budget before I could pull every appearance/pro hac vice entry off PACER directly, so I've separated sourced facts from unverified items below. The single most useful primary source is the certificate of service on Mopria's motion to quash (Mar. 5, 2025, N.D. Cal. 4:25-mc-80055, later transferred to W.D. Wash. as 2:25-mc-00018), which reproduces the complete W.D. Wash. service list for the underlying case, No. 2:21-cv-1055-DGE.

Counsel of Record — Defendants (Amazon entities), Flexiworld v. Amazon, No. 2:21-cv-01055-DGE (W.D. Wash.)

Bottom line

Amazon has been represented by two different law firms over the life of this case. The case began in W.D. Tex. (No. 6:20-cv-00553-ADA) with Perkins Coie LLP as defense counsel of record. After the August 2021 transfer to Seattle, Fenwick & West LLP became Amazon's counsel of record, with the Seattle office serving as local counsel and a Mountain View/New York team handling the substance. Fenwick was still on the signature block for Amazon in the ancillary Mopria discovery fight ten months before the case terminated. I found no appearance of Amazon in-house counsel on the public docket.


1. Fenwick & West LLP — counsel of record in the W.D. Wash. phase (2021–2025)

Sourced from the Mopria motion to quash certificate of service (the operative W.D. Wash. service list) and from pro hac vice admission orders on the docket. (Mopria motion, at 2, 15–16; Law360 Fenwick docket entries)

Attorney Role Firm / office Note
J. David Hadden Lead counsel (pro hac vice) Fenwick & West, Mountain View, CA (801 California St.) Longtime Fenwick patent-litigation partner; first-listed defense name on the Amazon service list in the 2025 Mopria dispute.
Michelle E. Irwin Local counsel (W.D. Wash., LCR 83.1) Fenwick & West, Seattle, WA (401 Union St., 5th Fl.) Seattle-based Fenwick IP litigation partner; signs/serves for Amazon in-district.
Jeffrey A. Ware Local counsel Fenwick & West, Seattle, WA Seattle IP litigator on the Amazon team.
Johnson K. Kuncheria Of counsel / pro hac vice Fenwick & West, Mountain View, CA Law360 links him to this docket (Aug. 3, 2021).
Donna Long Of counsel / pro hac vice Fenwick & West, Mountain View, CA On the Amazon service list.
Ravi Ranganath Of counsel / pro hac vice Fenwick & West, Mountain View, CA Admitted pro hac vice by order entered Mar. 8, 2024 (Dkt. 166) for Amazon Web Services Inc., Amazon.com Inc., Amazon.com LLC and Amazon.com Services Inc.
Saina S. Shamilov Of counsel / pro hac vice Fenwick & West, Mountain View, CA Admitted pro hac vice by order entered Mar. 8, 2024 (Dkt. 165), same four Amazon defendants.
Jessica Lin Of counsel / pro hac vice Fenwick & West, New York, NY (902 Broadway, 18th Fl.) New York member of the Amazon team.
Kevin X. McGann Of counsel / pro hac vice Fenwick & West, New York, NY New York member of the Amazon team.

Caveats. (i) I could not retrieve the notices of appearance that first put Fenwick on the W.D. Wash. docket, so I cannot give a precise substitution date; the earliest hard, dated evidence of Fenwick acting for Amazon that I verified is the Mar. 8, 2024 pro hac vice orders (Dkts. 165–166), and Fenwick appears as Amazon's counsel of record in the Mar. 5, 2025 Mopria filing. (ii) The certificate of service marks the Mountain View and New York attorneys "pro hac vice," implying earlier admission orders I did not individually pull. (iii) I did not verify any individual attorney's specific case history beyond what is quoted here; the "note" column is drawn from the filings themselves, not firm bios.


2. Perkins Coie LLP — counsel of record in the W.D. Tex. phase (2020–2021)

These are the authoritative docket-sheet entries reproduced as Exhibit 2032 in Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021-00714, and reflect the W.D. Tex. docket sheet for No. 6:20-cv-00553-ADA, where Perkins Coie's lawyers are listed under "Defendant Amazon.Com, Inc." (docket sheet exhibit)

Attorney Role Firm / office Note
Amisha Manek Lead attorney (pro hac vice) Perkins Coie LLP, Palo Alto, CA (3150 Porter Dr.) Docket sheet designates her LEAD ATTORNEY for Amazon. Perkins Coie's Amazon patent-defense practice includes Nonend Inventions v. Amazon and Clouding IP v. Amazon/AWS. (Perkins Coie bio excerpts in PTAB record)
Daniel T. Shvodian Lead attorney Perkins Coie LLP (Palo Alto, CA) Lead counsel on Amazon's Dec. 2, 2020 claim-term motion; his declaration is cited in the Markman record (Dkt. 50).
M. Craig Tyler Lead attorney (noticed 02/23/2021) Perkins Coie LLP, Austin, TX Austin-based Perkins Coie patent litigator; per docket sheet, LEAD ATTORNEY for Amazon.
Stevan Richard Stark, Jr. Appeared for defendant Perkins Coie, Seattle, WA Law360 lists him on this docket as of Aug. 3, 2021 (i.e., at/after transfer).

Firm-unverified names. The W.D. Tex. docket text also records a withdrawal motion (Dkt. 63, granted by text order) for Wing H. Liang, described as counsel "for Defendants." I could not confirm Mr. Liang's firm from a primary source, so I do not attribute one. (Unified Patents docket text)


3. Names on aggregator "attorney" lists that I could NOT reliably assign to a side

The UniCourt page for this case lists a mixed attorney roster ("9 More Attorneys Available") that blends plaintiff and defendant counsel, plus Texas-phase counsel, and does not identify which attorney represented which party. I am not asserting these as Amazon counsel, but flagging them for follow-up on PACER:

  • Arthur W. Harrigan, Jr., Ruchika Verma, Christopher Kelley, Christina J. McCullough, Theresa H. Nguyen — side and firm unconfirmed by me.
  • Confirmed as plaintiff-side for contrast (do not attribute to Amazon): Timothy E. Grochocinski, C. Austin Ginnings, Edward Nelson III, Jonathan H. Rastegar, Ryan Griffin (all Nelson Bumgardner), and Tyler Lawrence Farmer and Chelsey Lyn Mam (Bryan Cave Leighton Paisner, Seattle). (UniCourt roster; Mopria certificate of service)

Non-party counsel, for completeness (not Amazon): in the ancillary Mopria subpoena proceeding (W.D. Wash. 2:25-mc-00018), Mopria Alliance, Inc. was represented by Jason A. Wrubleski and Nicholas F. Aldrich, Jr. (dockets.justia.com 2:25-mc-00018)


4. Items I could not verify — stated explicitly

  1. No notice of substitution / withdrawal order replacing Perkins Coie with Fenwick & West that I could retrieve. On the public record I have, the two firms simply appear at different phases; I cannot say whether the change was a formal substitution, an addition, or a client-side change of primary counsel.
  2. No Amazon in-house counsel appears on the docket entries I retrieved. If in-house attorneys entered appearances late (e.g., at the July 28, 2025 termination), I did not capture them.
  3. Docket numbers for Fenwick's initial appearances (as opposed to the Mar. 2024 pro hac vice orders) are not confirmed.
  4. All docket numbers below Dkt. 117 and between Dkts. 166 and the 2025 termination were not exhaustively reviewed due to research-budget limits — PACER should be checked to confirm no additional appearances (and to confirm whether Perkins Coie formally withdrew).

5. Cross-reference to the prior sections

This fills the gap the earlier sections left open. Two points worth flagging for consistency:

  • The prior "Key legal developments" section correctly identified Perkins Coie as Amazon's Texas-phase counsel via the W.D. Tex. docket sheet — that is corroborated here. It did not identify Fenwick & West as the Washington-phase defense firm, which is the more important fact for the last ~18 months of the case.
  • The prior section attributed the Mopria ancillary motion to "Mopria's counsel" without naming the Amazon recipients on the certificate of service; those recipients are the Fenwick team listed in § 1 above, which is the cleanest available evidence of who was representing Amazon as of March 2025, four months before termination.