Flexiworld Technologies, Inc. v. Brother Industries (U.S.A.), Inc. et al.

I'll research this case thoroughly. Let me start with several searches.

Let me dig into the specifics of the patents and the litigation campaign.

Let me pin down the specific patents in the '2250 case and the '798 patent details.

Flexiworld Technologies v. Brother Industries (U.S.A.), Inc. — Case Overview

Note on sourcing: The docket metadata in this prompt (parties, court, case number, '798 patent) is treated as authoritative. Everything below is grounded in the sources cited; where a fact could not be confirmed, I say so.

The parties

Flexiworld Technologies, Inc. (plaintiff) is a wireless-technology company founded around 2001 by inventor William Ho Chang (with co-inventor Christina Ying Liu), first in Portland, Oregon and later Vancouver, Washington. It describes itself as "a pioneer and leading innovator in the field of pervasive wireless technologies," developing short-range wireless (Wi-Fi, Bluetooth) applications and embedded solutions for mobile devices, printers, and other output devices; the company says its founders have amassed 150+ U.S. patents (complaint text via the RPX document viewer, https://insight.rpxcorp.com/litigation_documents/14870285; RTM World, https://www.rtmworld.com/news/hp-sued-for-infringement-of-flexiworld-patents/). Flexiworld is now characterized as an NPE/patent-licensing company: RPX tags the case "NPE DC" (https://insight.rpxcorp.com/litigation/tnwdce-95143-flexiworld-technologies-v-brother-industries), and the Stanford NPE Litigation Database classifies it as a "failed startup"-type asserter (https://npe.law.stanford.edu/party/flexiworld-technologies-inc-0). Importantly, Flexiworld is not a classic shell NPE — it was a genuine early-2000s startup that was voted the best early-stage company in the Pacific Northwest in 2002 and tried (and failed) to commercialize its technology before pivoting to licensing/enforcement. Defendants are Brother Industries (U.S.A.), Inc. (originally named — Brother says it was the "incorrect defendant") and Brother International Corporation, the U.S. arm of Japan's Brother Industries, Ltd., a major printer/MFP manufacturer. Brother International maintains a large manufacturing/distribution facility at 7777 North Brother Boulevard, Bartlett, Tennessee, and its U.S. HQ is in New Jersey (Brother MTD memorandum, https://www.action-intell.com/wp-content/uploads/2022/09/Brother-supporting-memorandum.pdf). Brother's Tennessee lawyers were Wyatt, Tarrant & Combs LLP (Mark Vorder-Bruegge, Jr.; Matthew M. Lubozynski), with Cadwalader, Wickersham & Taft LLP (John T. Moehringer, Danielle V. Tully, Michael B. Powell, John T. Augelli) admitted pro hac vice; Flexiworld was represented by Timothy Grochocinski, Charles Austin Ginnings, and William E. Routt III (Nelson Bumgardner Conroy PC / Watson Burns PLLC) (PatSnap summary, https://www.patsnap.com/resources/blog/litigation/flexiworld-technologies-v-brothers-industries-consent-judgment-patsnap/).

The accused technology and the asserted patents

The case targets Brother's wireless printing functionality, not its core printing hardware: Brother's wireless printers and mobile-printing apps/services, including Apple AirPrint, Mopria Print Service, Google Cloud Print, Brother iPrint&Scan, Brother Web Connect, and Brother Cloud Apps (Brother MTD memo; complaint). Flexiworld's core theory is the driverless/mobile-print paradigm — a phone or tablet wirelessly discovers a nearby output device, negotiates capabilities, and sends output data without installing a device-specific printer driver. RPX reports 11 accused products and 4 patents-in-suit in this '2250 action (https://insight.rpxcorp.com/litigation/tnwdce-95143-flexiworld-technologies-v-brother-industries). The one patent confirmed by the case metadata is U.S. Patent No. 10,841,798 (the "'798 patent"), which relates to an information apparatus or client software that wirelessly discovers, within short range, one or more output devices for establishing a wireless connection (Google Patents listing, https://patents.google.com/patent/[US7929950](/patent/US7929950); the '798 is also asserted against Lexmark in E.D. Ky., where Flexiworld charted claim 1 — see https://www.action-intell.com/wp-content/uploads/2022/09/Flexiworld-v-Lexmark-FAC-00108.pdf). I could not confirm from the sources reviewed which three other patents were specifically asserted in the '2250 docket. For context, Flexiworld's overlapping Brother/Lexmark/other campaigns collectively asserted a pool of fifteen patents — the '181, '071, '856, '402, '073, '846, '791, '178, '871, '798, '056, '233, '576, '031, and RE42,725 patents — all tracing to 2000–2002 priority dates (E.D. Ky. consolidated order, https://cases.justia.com/federal/district-courts/kentucky/kyedce/5:2022cv00097/98438/44/0.pdf). So the '798 is best understood as one member of a large, long-lived continuation family covering wireless/driverless output.

Procedural posture, venue, and why it matters

Filed April 21, 2022 in the U.S. District Court for the Western District of Tennessee, Memphis Division, before Judge Jon Phipps McCalla (referring magistrate: Chief Magistrate Judge Tu M. Pham). Flexiworld filed four parallel Brother suits (2:22-cv-02236, -02237, -02250, -02251). The original complaints named Brother Industries (U.S.A.), Inc.; after a joint stipulation and leave to amend, Flexiworld filed a first amended complaint (June 21, 2022) substituting Brother International Corporation as sole defendant, then a second amended complaint (Aug. 5, 2022). Brother moved to dismiss the SAC on September 2, 2022, arguing that (1) method claims can only be directly infringed by "use" (targeting the '402, '233, and '798 patents), (2) Flexiworld failed to plead joint infringement for theories depending on third-party software/hardware (Apple, Google, Mopria, iPhones), and (3) contributory-infringement counts were inadequately pled (Brother motion, https://www.action-intell.com/wp-content/uploads/2022/09/Brother-motion-to-dismiss-amended-Fleixworld-complaints.pdf). Before any ruling, the parties settled; on March 13, 2023, the court entered a consent judgment / dismissal with prejudice across all four coordinated Brother actions via a joint Rule 41(a)(1)(A)(ii) motion (PatSnap; Actionable Intelligence, https://www.action-intell.com/tag/flexiworld-technologies-v-brother-industries-i-2022/). Total: 327 days in litigation (RPX), closed March 13, 2023.

Venue is the headline procedural issue. This is a post-TC Heartland case: a domestic corporation "resides" for venue purposes only where incorporated or where it has a regular and established place of business. Flexiworld deliberately pleaded venue around Brother's Bartlett, Tennessee distribution center, citing order confirmations, tracking data, photographs of shipments, and Tennessee-based support personnel (complaint, https://tonernews.com/wp-content/uploads/2022/04/Flexiworld-Technologies-Inc.-Sues-Brother-2-04-18-2022.pdf). Tennessee is not a traditional patent venue, so the choice reflects targeting where the accused products are warehoused, sold, and supported. Notably, the parallel Lexmark case in E.D. Ky. took a different path: Judge Karen K. Caldwell denied Lexmark's motion to dismiss (including its § 287 marking challenge and request to phase discovery) on March 20, 2023 — one week after Brother settled — leaving the merits untested in either case (E.D. Ky. DE 44).

Why the case is notable

• Part of a broad, systematic enforcement campaign. Flexiworld has asserted its wireless-printing portfolio against essentially the entire printer industry — Canon (W.D. Tex., Waco, Feb. 2021), Epson (C.D. Cal. 2021), Lexmark (E.D. Ky. 2022), Brother (W.D. Tenn. 2022), Hisense (E.D. Tex. 2022), Amazon (over Echo devices, 2020), Sony, Xerox, and HP (S.D. Tex., July 2024) (RTM World; The Recycler, https://therecycler.com/posts/tech-innovator-sues-hp-inc/; PTAB petition records). It is a textbook example of a failed operating company monetizing a broad continuation family.
• Early-priority "pioneer" narrative vs. modern standards. The patents claim priority to late-2000/early-2001 provisionals — years before AirPrint (2010) and Mopria — which supports Flexiworld's "ahead of its time" framing (Lexmark even called the concept "ahead of its time" in 2002, per the complaint) but also invites § 101 eligibility and prior-art/enablement defenses given that the accused functionality is really the smartphone OS and printer's standard protocols.
• Joint-infringement and pleading battleground. Brother's motion highlights a recurring NPE-software problem: the asserted method claims are practiced partly by Brother and partly by end users using third-party software/hardware (Apple, Google, Mopria), forcing Flexiworld to plead a joint-enterprise/direction-and-control theory — the same vulnerability that drives § 101 and § 271 motion practice across wireless-printing NPE suits.
• IPR/PTAB linkage (partial). USPTO PTAB records show at least one petition (Petition No. 1553925 at ptacts.uspto.gov) addressing Flexiworld's '402 patent and citing the Brother litigation among Flexiworld's assertions; I could not fully verify the petitioner or outcome from the sources reviewed, so treat this as an unconfirmed IPR linkage and not a ruling in the '798 patent.
• Market context. Driverless/cloud and mobile printing is now ubiquitous (AirPrint, Mopria, cloud print), making any Flexiworld win a potential royalty exposure across printer OEMs and platform vendors — which likely explains why OEMs settle (Brother, Canon, Epson) rather than litigate to judgment, and why the terms here (any license/payment) were kept confidential.

Caveats: The exact three additional patents-in-suit in the '2250 docket, the identity of counsel on the specific '2250 pleadings vs. the consolidated Brother filings, and the PTAB petition details are not fully confirmed in the publicly available sources I reviewed; the settlement's financial terms are undisclosed in the public record.

I'll research the chronological legal developments in this case. Let me start with several targeted searches.

Let me dig deeper into the specific docket events, the patents in the '2250 case, and any PTAB proceedings on the '798 patent.

I've reached my tool-call limit but gathered substantial material. Here's the chronological legal-development and outcome analysis, building on the prior sections.

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Key Legal Developments & Outcome — Flexiworld v. Brother, No. 2:22-cv-02250 (W.D. Tenn.)

Bottom line: This was a short, motion-driven case that never reached claim construction, discovery-on-the-merits, or trial. It resolved by a joint stipulated dismissal with prejudice on 2023-03-10, entered/terminated 2023-03-13, after Brother's two rounds of Rule 12 motion practice but before any court ruling on the dispositive motion. There is no merits adjudication, no Markman order, no damages ruling, and no appeal. All four Brother actions resolved simultaneously; terms are confidential.

A clarifying development: the earlier sections flagged uncertainty over the three other patents in the '2250 docket. The complaint's own docket entry resolves it.

The four patents-in-suit in the '2250 case (now confirmed)

Dkt. 3 (Report to the Commissioner of Patents, filed 2022-04-21) identifies the patents asserted in this case as:

• U.S. 10,841,798 (the '798) — the metadata patent
• U.S. 10,768,871 (the '871)
• U.S. 10,037,178 (the '178)
• U.S. 11,096,056 (the '056)

Source: Justia docket for 2:22-cv-02250, https://dockets.justia.com/docket/tennessee/tnwdce/2:2022cv02250/95143 (Dkt. 3, 2022-04-21).

⚠️ Contradiction to flag: The PatSnap case summary states the four asserted patents were US10481846 ('846), US10761791 ('791), US7609402 ('402), and US10140073 ('073) (https://www.patsnap.com/de/resources/blog/litigation/flexiworld-technologies-v-brothers-industries-consent-judgment-patsnap/). That set does not match the '2250 Report to the Commissioner. The most likely explanation is that PatSnap conflated the four coordinated Brother actions (Nos. 2:22-cv-02236 / -02237 / -02250 / -02251), which asserted different patent subsets — consistent with the Lexmark IPR record showing the '402 was asserted in Brother 2:22-cv-02237, not '2250 (Lexmark IPR petition, Petition No. 1553925, ptacts.uspto.gov). For the '2250 case specifically, the docket's Dkt. 3 controls: '798, '871, '178, '056.

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1. Filing & initial pleadings

Answer / counterclaims: In this docket I found no answer and no counterclaims filed by Brother in the '2250 case before dismissal — Brother defaulted to Rule 12 motion practice. The 2023-03-10 joint dismissal nonetheless recites dismissal of "all pending claims and counterclaims… all claims by Brother against Flexiworld," which reads as boilerplate drafted to cover the consolidated family (and to moot any counterclaims in companion cases); I could not confirm any actually-filed Brother counterclaim in '2250. Treat the "counterclaims" language as unverified for this specific case.

2. Coordination & venue posture

• Flexiworld filed four parallel Brother actions (2:22-cv-02236, -02237, -02250, -02251), which were tracked together on a single joint schedule (Dkt. 20, Joint Planning Report, 2022-06-16, captioned across all four associated cases). Source: Justia docket.
• Venue was pleaded around Brother's Bartlett, Tennessee distribution/support facility; no separate motion to transfer or venue challenge appears in the retrieved record (venue allegations: complaint ¶¶ 10–12, https://insight.rpxcorp.com/litigation_documents/14870285).

3. Pre-trial motions of substance — two rounds of Rule 12 practice (no ruling)

This is the substantive heart of the case, and it played out in two waves:

Wave 1 — First Amended Complaint (filed 2022-06-21). On 2022-07-21, Brother moved to dismiss multiple claims from the FAC (Dkt. 35 in the lead member case). Rather than oppose it, Flexiworld amended as of right, mooting the motion.

Wave 2 — Second Amended Complaint (filed 2022-08-05). On 2022-09-02, Brother filed a second motion to dismiss the SAC plus a supporting memorandum. Three grounds:

1. Method-claim direct infringement limited to "use." Flexiworld again pleaded "making, using, selling, offering for sale, and/or importing" for method claims; Brother argued only "use" can constitute direct infringement of a method claim, specifically targeting the '402, '233, and '798 patents — including that Flexiworld charted only method claims for the '798 ('2250 SAC ¶¶ 87–89, Ex. 8).
2. Third-party / joint-infringement defect. All infringement theories tying Brother to third-party software (Apple AirPrint, Google Cloud Print, Mopria) and third-party hardware (iPhones, tablets) amount to joint infringement requiring a joint-enterprise theory, which Flexiworld failed to plead as to end-user customers.
3. Contributory infringement inadequately pleaded for the '181, '071, '856, '178, '871, '056, '073, and '791 patents.

Sources: Brother supporting memorandum, https://www.action-intell.com/wp-content/uploads/2022/09/Brother-supporting-memorandum.pdf; motion, https://www.action-intell.com/wp-content/uploads/2022/09/Brother-motion-to-dismiss-amended-Fleixworld-complaints.pdf.

• Flexiworld opposed ("Flexiworld Fights Brother's and Lexmark's Motions to Dismiss"), and Brother filed a reply brief ("Brother and Lexmark File Briefs Arguing for Dismissal…"). Sources: Actionable Intelligence tags, https://www.action-intell.com/tag/flexiworld-technologies-v-brother-industries-iv-2022/.
• No ruling issued. The court never decided either motion; the case settled first. So the method-claim, joint-enterprise, and contributory-infringement issues were left unresolved in this district.

No other pre-trial motions of substance (no motion to transfer, no motion to stay pending IPR, no summary-judgment motion) appear in the record I retrieved.

4. Claim construction (Markman)

None. The case never reached claim construction — no Markman briefing, no hearing, no construction order. The case terminated ~10.5 months after filing, before the Joint Planning Report's schedule would have produced a Markman order.

5. Discovery milestones

No merits discovery milestone with strategic significance appears. The case was in early case-management posture: the Joint Planning Report and Proposed Schedule (Dkt. 20, 2022-06-16) was the only scheduling filing. The record retrieved shows no Rule 26(f) completion, no contention interrogatories, no claim-chart exchange order, and no fact/expert discovery cutoff reached. Notably, Flexiworld itself moved to dismiss only ~3 months after the Joint Planning Report — i.e., the parties settled while Rule 12 motions (which stay/precede real discovery) were pending.

6. Trial events, verdict, post-trial motions

None. No trial, no verdict, no JMOL/new-trial/fees motion. Fees were addressed by contract in the settlement: "Each party is to bear its own costs and fees" (Joint Motion to Dismiss), so no § 285 fee motion was filed.

7. Settlement, dismissal, final disposition

• 2023-03-10 — Parties filed a Joint Motion to Dismiss with Prejudice under Rule 41(a)(1)(A)(ii), captioned across all four Brother actions (Nos. 2:22-cv-02236 / -02237 / -02250 / -02251): "Flexiworld and Brother… have settled their claims… and thus move this Court to dismiss with prejudice all pending claims and counterclaims… Each party is to bear its own costs and fees." Source: https://www.action-intell.com/wp-content/uploads/2023/03/Flexiworld-motion-to-dismiss-Brother-lawsuits.pdf.
• 2023-03-13 — Case terminated; docket records the basis of termination as Consent Judgment, effecting a dismissal with prejudice, which bars Flexiworld from re-asserting the same claims against Brother in these matters. Sources: Justia docket (Terminated March 13, 2023); RPX, https://insight.rpxcorp.com/litigation/tnwdce-95143-flexiworld-technologies-v-brother-industries; PatSnap.
• No appeal was taken (terminated case, dismissal with prejudice). Settlement amount/license terms are confidential and not in the public record.
• Docket statistics: 327 days per RPX; PatSnap computes 332 days (it uses an April 15, 2022 filing date — the date some companion Brother complaints were filed). Note this small discrepancy; the '2250 complaint itself was filed 2022-04-21.

8. Parallel PTAB proceedings and their effect

No PTAB proceeding was instituted on the '798 patent in this window, and none stayed or affected the '2250 case (consistent with the absence of any motion to stay). The relevant PTAB activity involves sibling Flexiworld patents and other defendants, and is useful as landscape rather than direct effect on this case:

• IPR2021-00713 & IPR2021-00714 — Roku, Inc. v. Flexiworld Technologies. Roku's petitions, arising from the Flexiworld v. Roku W.D. Tex. litigation; PTAB depositions (Dr. Todor Cooklev) taken 2022-03-30. Illustrates the PTAB parallel to the district-court campaign. Source: Docket Alarm PTAB dockets, https://www.docketalarm.com/cases/PTAB/IPR2021-00714/Roku_Inc._v._Flexiworld_Technologies_Inc/.
• IPR2022-00775 — Unified Patents, LLC v. Flexiworld, U.S. 9,836,257 ('257). Final Written Decision 2023-11-01: the Board held no challenged claims unpatentable, i.e., Flexiworld prevailed; Flexiworld's revised motion to amend dismissed as moot. Source: Docket Alarm FWD, https://www.docketalarm.com/cases/PTAB/IPR2022-00775/Unified_Patents_LLC_v._Flexiworld_Technologies_Inc/.
• Lexmark's petition on the '402 patent (Petition No. 1553925, ptacts.uspto.gov). Real party-in-interest Lexmark International, Inc.; it expressly lists the Brother actions among Flexiworld's assertions — "Flexiworld Technologies, Inc. v. Brother Industries (USA), Inc., No. 2-22-cv-02237 (W.D. Tenn.) (… settled/voluntarily dismissed March 13, 2023)."
• Petition No. 1548112 — a written-description/§ 112 challenge to Flexiworld's '903 patent (a portfolio patent not asserted in '2250).
• IPR2023-00845 — Flexiworld power-of-attorney naming Ginnings, Grochocinski, Bumgardner (patent and outcome unverified here).

Effect: None of these touched the '2250 patents-in-suit ('798, '871, '178, '056) in a way that altered this litigation, and no stay was sought or granted. The '798 itself does not appear to have been the subject of an instituted IPR in this period (unverified — a full PTAB docket pull would be needed).

9. Parallel district-court context (why this matters)

The Lexmark tracks (E.D. Ky., Nos. 5:22-cv-00097 et al.) moved further and faster than Brother and give the clearest read on how the merits would likely have been contested:

• Lexmark moved to dismiss (2022-08-12, DE 32); Flexiworld amended (2022-08-31); Lexmark filed a "renewed" partial motion to dismiss attacking the § 287(a) marking/pre-suit-damages allegations.
• Lexmark's motion to stay was denied 2022-09-01 (E.D. Ky.).
• Judge Karen K. Caldwell denied Lexmark's partial motion to dismiss on 2023-03-20 — including the § 287(a) marking challenge and phasing request — one week after Brother settled (DE 44). This is the only substantive merits-adjacent ruling in the campaign around this time.
• Lexmark answered and counterclaimed (March 2023), then settled; its four cases were dismissed 2023-06-06.

Sources: E.D. Ky. consolidated order, DE 44, https://cases.justia.com/federal/district-courts/kentucky/kyedce/5:2022cv00097/98438/44/0.pdf; Actionable Intelligence, https://www.action-intell.com/tag/flexiworld-technologies-v-lexmark-international-iii-2022/.

Takeaway: Brother did not need to win its Rule 12 motion — it settled before the court could rule, mirroring the same early-settlement pattern seen across the Flexiworld campaign (Canon, Epson, Lexmark, Brother all settled rather than risk a merits holding on the broad, 2001-priority continuation family). The unresolved issues Brother raised — method-claim "use"-only infringement, joint-enterprise pleading for third-party driverless-print features, and contributory-infringement sufficiency — remain open questions that would recur in any future assertion of the '798.

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Caveats / verification limits

1. Free docket was last refreshed 2022-06-16. Docket entries after mid-June 2022 (the FAC, both motions to dismiss, opposition/reply briefs, and the dismissal) are drawn from the filed PDFs and Actionable Intelligence, not from a live PACER pull; specific docket-entry numbers for Wave 1 (2022-07-21) and Wave 2 (2022-09-02) motions in '2250 are not confirmed (Dkt. 35 is confirmed only for the lead member case).
2. No answer/counterclaims in '2250 were confirmed; the joint dismissal's "counterclaims" reference is treated as boilerplate.
3. Patent-series discrepancy between PatSnap (846/791/402/073) and the '2250 docket (798/871/178/056) — I treat the docket's Dkt. 3 as authoritative for '2250 and attribute the difference to case conflation across the four coordinated Brother suits.
4. PTAB: no instituted IPR on the '798 was located; the identified IPRs concern sibling patents ('257, '402, '903, and the Roku patents). Treat "no '798 IPR" as unconfirmed pending a full PTAB docket search.
5. Settlement terms, any license, and any payment are not disclosed.

Primary sources: Justia docket 2:22-cv-02250 (https://dockets.justia.com/docket/tennessee/tnwdce/2:2022cv02250/95143); RPX (https://insight.rpxcorp.com/litigation/tnwdce-95143-flexiworld-technologies-v-brother-industries); Brother MTD memo & motion and Joint Motion to Dismiss (action-intell.com, URLs above); E.D. Ky. DE 44; PatSnap summary; Docket Alarm PTAB records; ptacts.uspto.gov petitions 1553925 / 1548112.

I'll research the counsel of record for plaintiff Flexiworld Technologies in this case.

I have good leads. Let me dig deeper into the specific counsel and the local Tennessee counsel.

Let me verify the plaintiff's counsel roster through the docket and firm sources.

Counsel of Record for Plaintiff Flexiworld Technologies, Inc.

Case: Flexiworld Technologies, Inc. v. Brother Industries (U.S.A.), Inc. et al., No. 2:22-cv-02250-JPM-tmp (W.D. Tenn., Memphis Div.), terminated 3/13/2023.

Flexiworld's representation in this case followed its standard two-tier structure: a national patent-litigation boutique handling substantive work (appearing pro hac vice) plus a Memphis firm as local counsel. All of the attorneys below are drawn from the docket and from signed filings in the case — none are inferred.

National / lead counsel — Nelson Bumgardner Conroy PC (Orland Park, Illinois)

Firm note: the firm has appeared under several names in Flexiworld matters — Nelson Bumgardner Albritton PC (Fort Worth, TX), Nelson Bumgardner PC, and now Nelson Bumgardner Conroy PC (Orland Park, IL). The "Nelson Bumgardner" entity is the same shop; the name change is documented in a notice filed in Flexiworld v. Epson America (C.D. Cal. 8:21-cv-00807).

Local counsel — Watson Burns, PLLC (Memphis, Tennessee)

Important caveats

1. Counsel did not change because of sealing — the case simply resolved quickly. After Brother's motion to dismiss the amended complaints (Dkt. 35 in the lead member case, 7/21/2022) and a second motion directed at the Second Amended Complaints (filed 9/2/2022), Flexiworld moved to dismiss the Brother lawsuits on March 10, 2023, and the case was terminated March 13, 2023. No sealed-attorney or sealed-appearance issue has been identified; the appearance records are simply thin in the public excerpts available after mid-2022.
2. Signature-block ambiguity in the dismissal papers. The March 10, 2023 pleading PDF aggregating the Brother dismissals mixes plaintiff and defense signature blocks (Wyatt, Tarrant & Combs / Cadwalader, Wickersham & Taft for Brother International Corporation appear alongside the Watson Burns block). I am relying on the plaintiff-side block (Watson/Burns/Routt) only, and flagging that the extraction is imprecise.
3. One name I could not place in this case. Steven G. Hill (Hill, Kertscher & Wharton LLP, Atlanta) appears on a Flexiworld plaintiff signature block in a March 7, 2023 filing (with Grochocinski and Ginnings). That filing is contemporaneous with the Brother dismissals but may belong to a parallel Flexiworld action (e.g., the Lexmark or another printer-defendant matter). I could not confirm Hill entered an appearance in 2:22-cv-02250, so I do not list him as counsel of record here.
4. Party-name correction context. Flexiworld originally sued "Brother Industries (U.S.A.), Inc." but was granted leave to substitute Brother International Corporation as sole defendant (Dkt. 19, 6/14/2022), which is why the caption names both entities while only one was actively litigated.

Key sources

• Docket listing (free excerpt through 6/16/2022): dockets.justia.com/docket/tennessee/tnwdce/2:2022cv02250/95143 — shows Dkt. 11 (Routt service), Dkt. 12/13 (Grochocinski pro hac vice), Dkt. 18 (Ginnings stipulation), Dkt. 20 (Grochocinski joint planning report).
• UniCourt party/attorney page for No. 2:22-cv-02250: plaintiff attorneys listed as Charles Austin Ginnings, Timothy Grochocinski, William E. Routt, III.
• RPX Insight case page: insight.rpxcorp.com/litigation/tnwdce-95143 — closed 3/13/2023, 4 patents-in-suit, 11 accused products.
• Flexiworld's March 10, 2023 dismissal papers (plaintiff signature block: Watson Burns, PLLC — Watson, Burns, Routt): action-intell.com/wp-content/uploads/2023/03/Flexiworld-motion-to-dismiss-Brother-lawsuits.pdf.
• Grochocinski pro hac vice declaration (background/experience), IPR2021-00714, Ex. 2001.
• Flexiworld IPR power of attorney naming Ginnings, Grochocinski, and Brent Bumgardner (IPR2023-00845).

If you need verified appearance dates for Ginnings or confirmation of any additional plaintiff-side appearances after June 2022, that would require a fresh PACER pull of the full docket for 2:22-cv-02250, which I could not retrieve here.

I'll research counsel of record for the Brother defendants in this case.

Let me pull the actual filings to verify the signature blocks and search the docket directly.

Let me verify the docket entries, the firms' rosters, and the full signature blocks.

Bottom line

Two firms appeared for the Brother side in No. 2:22-cv-02250 (and its three companion W.D. Tenn. cases, Nos. 2:22-cv-02236, -02237 and -02251): Cadwalader, Wickersham & Taft LLP (New York) as lead/principal counsel, and Wyatt, Tarrant & Combs, LLP (Memphis) as Tennessee local counsel. All of the identified attorneys appeared by signature block (the Cadwalader group pro hac vice). No in‑house Brother attorney appears in the materials I could retrieve.

Counsel of record

What the record shows

• Docket/appearances. The Justia docket for No. 2:22-cv-02250 (last retrieved June 16, 2022) records "NOTICE of Appearance by Matthew Mahoney Lubozynski on behalf of Brother Industries (U.S.A.) Inc.," Dkt. 16 (May 23, 2022), and the parallel UniCourt docket entries record "NOTICE of Appearance by Mark Vorder-Bruegge, Jr on behalf of Brother Industries (U.S.A.), Inc.," Dkt. 14. Both are listed as defendant attorneys, with the plaintiff side shown as Timothy E. Grochocinski, Charles Austin Ginnings and William E. Routt III (Nelson Bumgardner Conroy, later Watson Burns PLLC locally). — https://dockets.justia.com/docket/tennessee/tnwdce/2:2022cv02250/95143 ; https://unicourt.com/case/pc-db5-flexiworld-technologies-inc-v-brother-industries-usa-inc-[1183494](/patent/1183494)
• Substitution of defendant. Brother's Sept. 2, 2022 supporting memorandum states that Flexiworld was granted leave to amend and "dropped Brother Industries (U.S.A.), Inc. and named Brother International Corporation as the sole defendant" — so the Cadwalader/Wyatt Tarrant team thereafter appeared for Brother International Corporation. — https://www.action-intell.com/wp-content/uploads/2022/09/Brother-supporting-memorandum.pdf
• Joint signature block (Sept. 2, 2022). Brother's motion to dismiss and supporting memorandum close with two blocks — Cadwalader (Moehringer, Tully, Powell, Augelli, all "admitted pro hac vice") and Wyatt, Tarrant & Combs (Vorder-Bruegge and Lubozynski) — both designated "COUNSEL FOR DEFENDANT Brother International Corporation." — https://www.action-intell.com/wp-content/uploads/2022/09/Brother-motion-to-dismiss-amended-Fleixworld-complaints.pdf and the memorandum above.
• Termination. The cases ended by a Joint Motion to Dismiss with Prejudice captioned in all four cases (Nos. 2:22-02236 / -02237 / -02250 / -02251), dated March 10, 2023, resolving "all pending claims and counterclaims." The Cadwalader block again appears as "COUNSEL FOR DEFENDANT BROTHER INTERNATIONAL CORPORATION," consistent with Dkt. entries terminating the case on March 13, 2023. — https://www.action-intell.com/wp-content/uploads/2023/03/Flexiworld-motion-to-dismiss-Brother-lawsuits.pdf

Caveats / limits on verification

1. OCR ambiguity in the March 2023 joint motion. The text extraction of that filing places a "Counsel for Plaintiff Flexiworld Technologies, Inc." line immediately above the "/s/ Mark Vorder-Bruegge, Jr. (with consent)" block, with the Cadwalader block appearing under the "Counsel for Defendant Brother International Corporation" line. The OCR page ordering appears jumbled, and I could not retrieve a clean page image. The weight of the evidence (Dkt. 14/16 notices of appearance for the defendant, the Sept. 2, 2022 defense signature block, and Patsnap's counsel table listing Wyatt, Tarrant & Combs as defendant counsel) supports Vorder-Bruegge and Lubozynski as Brother's Tennessee counsel, not plaintiff's.
2. Firm titles/roles. The Caption paragraphs (pro hac vice designations, bar numbers, addresses) are taken verbatim from the filed signature blocks. The "lead vs. of counsel" labels are my characterization based on who signed and who was first-named; the filings do not formally designate lead counsel.
3. Experience notes. The one-line experience descriptions for Moehringer (Cadwalader IP litigation partner), Vorder-Bruegge (Memphis commercial/IP litigator) and Lubozynski (Memphis IP litigator) reflect general professional background, not verified case-specific findings from this docket; the individual Cadwalader attorneys' precise titles (partner vs. associate) were not confirmed from a firm bio page in this session.
4. Possible additional counsel. The publicly retrieved docket sheet was last refreshed in June 2022; if additional appearances (including any in-house counsel or a successor firm) were docketed between mid‑2022 and the March 2023 dismissal, they would not appear in the sources above. I found no evidence of any, and I have not invented any.