Hanger Solutions, LLC v. Squarespace, Inc.

I'll research this case and its parties before drafting.

I'll research this case systematically, starting with the docket and related PTAB proceedings.

Let me dig into the PTAB proceedings and the 2022 docket.

Hanger Solutions, LLC v. Squarespace, Inc., No. 1:21-cv-00774-LPS (D. Del.) — Litigation Chronology

Bottom line up front: This case never progressed beyond the pleadings. There was no Markman, no scheduling order, no discovery of substance, no summary judgment practice adjudicated on the merits, and no trial. It was a short-lived NPE campaign case that was stayed and then dismissed with prejudice by stipulation roughly 18 months after filing. The only contested motion of substance was Squarespace's motion to stay filed in December 2021 — apparently premised on PTAB petitions — and the docket does not reflect a merits ruling on it before the case was resolved by stipulation.

Important sourcing caveat: the searches performed surfaced docket mirrors (Justia, UniCourt, Patexia, Unified Patents' litigation portal) rather than free PACER images, and no text of the complaint, answer, or stay briefs was retrievable. Everything below is labeled as sourced or inferred, and I flag where the record is thin. I hit my research step limit before I could pull PTAB P-TACTS petition numbers, so the IPR identification below is partially inferred and should be confirmed.

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1. Counsel of record (sourced)

Source: docket entries 9–13 (appearances and PHV motions, June 2021), as mirrored at Justia, UniCourt, and Patexia.

2. The patentee and the campaign context (sourced)

Hanger Solutions is a Georgia entity associated with Atlanta monetization firm IPInvestments Group, which acquired thousands of patent assets from Intellectual Ventures in late 2019. Two of the three asserted patents — US 6,430,623 and US 6,772,227 — are members of a family naming Hasan S. Alkhatib (IP Dynamics; assigned to IV in 2008) directed to communicating with an entity outside a private network via an "intermediate entity" and routing communications between "address spaces." The third, US 6,609,159 (Fast Engines; inventor Semyon Dukach), relates to web-application performance. Hanger filed this case as part of a multi-defendant assertion campaign; the same three patents were asserted against Extreme Networks in D. Del. No. 1:21-cv-00040 (filed February 2021) and later against Charter Communications in W.D. Tex. No. 6:22-cv-00070 (filed 2022-01-18).

Source: Mondaq/ROBINSON+COLE case note, "Hanger Solutions Kicks Off Networking Campaign Over Three From Thousands Of Patents Received From IV," 2021-02-12; UniCourt docket for W.D. Tex. 6:22-cv-00070.

3. Chronology

A. Filing and related-case positioning (May–June 2021)

• 2021-05-27 — Hanger files the complaint for patent infringement under 35 U.S.C. § 271, with jury demand, asserting the '623, '159, and '227 patents. Accused products are not identified in the available metadata; the complaint attached Exhibits A–E (D.I. 1, Exs. A–E). Hanger's Rule 7.1 disclosure identifies Brainbox Innovations, LLC as corporate parent (D.I. 4). Case assigned to Judge Leonard P. Stark.
• 2021-06-02 — Squarespace's counsel (Brian E. Farnan) submits a letter regarding related cases. 2021-06-04 — Hanger's counsel (Stamoulis) responds regarding "Related Case Status," expressly cross-referencing No. 1:21-cv-00164-LPS. This is the first signal that Hanger was running a coordinated multi-front campaign in Delaware.
• 2021-06-04 — Squarespace served. 2021-06-07 — Farnan LLP appearances.
• 2021-06-11 — Stipulation extending Squarespace's response deadline to 2021-07-26, so-ordered by Judge Stark.
• PHV admissions for both sides entered 2021-06-09 through 2021-06-15.

B. Answer (2021-07-20)

• 2021-07-20 — Squarespace files its Answer to the complaint (D.I. 14), with a verification attached. The docket as mirrored shows no separately docketed counterclaims — i.e., Squarespace answered and pleaded defenses rather than asserting affirmative counterclaims (no declaratory-judgment counterclaim of invalidity/non-infringement appears on the docket). That is strategically notable: Squarespace appears to have reserved its invalidity attack for the PTAB rather than duplicating it in the district court.

C. The one substantive contested motion: motion to stay (December 2021)

• 2021-11-16 — Judge Stark orders the parties to confer and submit a proposed schedule, including proposed trial length and timing, by 2021-11-30. This confirms the case had no scheduling order at all as of late November 2021 — no discovery cutoff, no Markman date, no trial date.
• 2021-11-30 / 2021-12-01 — Joint stipulation extending the scheduling proposal to 2021-12-07.
• 2021-12-07 — Squarespace files a Motion to Stay (D.I. 17) with an opening brief (D.I. 18), a Russo declaration with Exhibits 1–4 (D.I. 19), and a proposed order (D.I. 20). On the same date, Hanger filed a competing Proposed Scheduling Order (D.I. 20).
• 2021-12-21 — Hanger files its answering brief in opposition (D.I. 22; main document replaced/corrected 2021-12-27).
• 2021-12-17 / 2021-12-20 — Stipulation, so-ordered, extending Squarespace's reply deadline to 2022-01-04.

Inference, expressly flagged: The stay motion was almost certainly a stay-pending-IPR motion. The four exhibits to the Russo declaration, the timing (petitions filed shortly before the motion), and the fact that no other stay theory fits a two-month-old case all point that way. Consistent with PTAB fiscal-year numbering, Squarespace's petitions would have been docketed in the IPR2022-00xxx series (petitions filed between 2021-10-01 and 2022-09-30). I was not able to confirm the specific IPR numbers, filing dates, challenged claims, or institution decisions. These should be verified in PTAB P-TACTS / the Board's developer API by searching for petitions naming Squarespace, Inc. as petitioner and Hanger Solutions, LLC as patent owner against the '623, '159, and '227 patents. Note also that Squarespace was a co-petitioner in the separate Express Mobile web-site-generation IPR series (e.g., IPR2022-00572, IPR2022-00598), which shows it was an active PTAB challenger in this period but is unrelated to Hanger's patents.

D. The gap: January–November 2022

The public docket mirrors available to me do not reflect any order resolving D.I. 17, any scheduling order, any protective order, any discovery dispute, any claim construction briefing or Markman hearing, or any summary judgment motion. Given that the case terminated by stipulation, the most likely sequence is:

1. The Board issued institution decisions on Squarespace's petitions roughly mid-2022 (the statutory three-month-plus window after the patent owner's preliminary response, i.e., ~six months post-petition).
2. With review instituted, the parties stipulated to a stay in November 2022.
3. The case was then dismissed with prejudice by stipulation on 2022-12-13, likely as part of a global resolution (license/settlement) rather than as a litigation loss.

That is inference, not verified fact. What is verified is the existing case metadata: stayed by stipulation in November 2022; dismissed with prejudice by stipulation 2022-12-13; case terminated.

E. Claim construction, discovery, trial, post-trial, appeal

• Markman: Never reached. No claim construction order, no Markman hearing, and no proposed claim terms appear in the docket through the stay motion. The case ended before the joint claim construction statement stage that Judge Stark's form patent scheduling order would have imposed.
• Discovery: No scheduling order was ever entered, so there were no court-ordered fact or expert discovery cutoffs and no discovery rulings. No depositions, interrogatory rulings, or ESI disputes appear of record. The only "discovery-adjacent" event was the stipulated extension practice in mid-2021 and the schedule negotiation in November 2021.
• Trial / verdict: None. No trial date was ever set.
• Post-trial motions (JMOL, new trial, § 285 fees): None — procedurally impossible given the disposition.
• Appeal: None from this docket. (Any appeal of an underlying Board decision would have run separately to the Federal Circuit; I could not confirm whether any such appeal was taken.)

4. Final disposition

2022-12-13 — dismissed with prejudice by stipulation (case terminated). Because the dismissal was with prejudice and by agreement, there is no merits adjudication on infringement, invalidity, or claim scope, and no prevailing party for fee purposes. Hanger retains no ability to re-assert these patents against Squarespace, but the dismissal carries no issue-preclusive effect against other defendants or in the PTAB.

5. Effect of the parallel PTAB proceedings

Causally, the PTAB track appears to have driven this case's entire trajectory: it is the only plausible basis for the December 2021 stay motion, the only plausible reason a case with no scheduling order would sit dormant for eleven months, and the

I'll research the docket and counsel of record for Hanger Solutions, LLC v. Squarespace, Inc.

Counsel of record for plaintiff Hanger Solutions, LLC

Hanger Solutions is a Brainbox Innovations, LLC subsidiary (an Intellectual Ventures spin-out vehicle); it litigated the same three patents (US 6,430,623, 6,609,159, 6,772,227) against a long list of defendants, including Squarespace. The counsel lineup in this case was the same team used across the campaign: a two-attorney Delaware firm acting as local/registered counsel, plus three out-of-state attorneys admitted pro hac vice from an Atlanta trial firm.

Delaware counsel (local / registered counsel of record)

Pro hac vice counsel (Atlanta)

All three were admitted pro hac vice by Judge Leonard P. Stark on June 10, 2021, on Hanger's motion (D.I. 12; the corresponding PHV notices were docketed June 11 and June 15, 2021).

There was no in-house counsel for Hanger of record — the docket shows only the two Delaware lawyers and the three PHV attorneys for the plaintiff.

Case-posture note relevant to counsel

This case generated almost no merits practice from plaintiff's counsel: after the complaint (D.I. 1, filed 5/27/2021, with a Rule 7.1 disclosure at D.I. 4 identifying Brainbox Innovations as parent), the PHV admissions, and an extension of the response deadline (D.I. 13, to 7/26/2021), the case was stayed by stipulation in November 2022 and dismissed with prejudice by stipulation on December 13, 2022 — consistent with the campaign-wide pattern of resolved/settled NPE suits. No claim construction opinion, summary judgment opinion, or trial record exists for this docket.

Verification caveats

• Attorney identities and the pro hac vice admissions are grounded in the docket as mirrored by the Unified Patents litigation portal, Justia Dockets, and UniCourt for No. 1:21-cv-00774; I did not obtain the PACER images themselves, so I cannot quote the PHV motion (D.I. 12) verbatim.
• The firm attribution "Heninger Garrison Davis, LLC" is inferred from contemporaneous professional profiles (HGD firm announcements for Miller; usattorneys.com and PacerMonitor listings showing McDonough and Lynch at HGD in 2018–2021) — the PHV motion itself would state each affiant's firm and address. Their current firm (Rozier Hardt McDonough PLLC) is confirmed by State Bar of California and Law360 listings, but that is a later affiliation, not the one of record here.
• I could not independently confirm Richard C. Weinblatt's individual bar admissions or specific prior cases beyond his repeated appearance with Stamoulis; treat that line as general rather than sourced to a specific filing.
• Nothing in this docket appears sealed as to counsel identity; there is no indication of any attorney whose appearance was withheld.

I'll research the docket and counsel of record for Squarespace in this case.

Now let me identify the pro hac vice firms and roles.

Let me verify the related case, the local counsel appearances, and any developments (e.g., IPRs, motions) that shaped the defense team.