Parus Holdings, Inc. v. Amazon.com, Inc.

Parties, accused technology, and asserted patents. Parus Holdings, Inc. is a patent-holding company that acquired the Webley Systems "voice browser" patent portfolio in 2004 (per contemporaneous press coverage of its parallel Siri case) and does not appear to practice the patents; it is listed as a repeat patent asserter in Stanford's NPE Litigation Database, which tags its role in this case ambiguously as a "product company." Amazon.com, Inc. is the accused operating company — a Delaware corporation and the operator of the Alexa voice-assistant ecosystem. The accused technology is Amazon's Alexa platform, including Echo devices, the cloud-based Alexa Voice Service (speech recognition and text-to-speech), Alexa "Skills" (the complaint specifically cites a "Tide Pool" skill retrieving tide data from noaa.gov), and AWS Lambda, i.e., natural-language voice commands that cause retrieval of web content that is then synthesized into spoken answers. Per the Report to the Commissioner filed with the complaint (D.I. 3), the asserted patents are U.S. Patent Nos. 7,516,190 B2 ("Personal Voice-based Information Retrieval System" — a speech processor connected to the internet/phone that retrieves pre-defined website portions using regular expressions and reads the result aloud), 9,377,992 B2 (speech-command information retrieval via a speech-recognition engine coupled to a media server, a "clipping client" content-descriptor file, and speech synthesis), and 10,320,981 B2 (a third family patent; limited public detail available in my sources). Note: the case metadata lists 6,721,705 — the 2004-granted "Robust Voice Browser System and Voice Activated Device Controller" (filed 2001 by Webley Systems, priority date 2000-02-03) — which is the early family ancestor that surfaces in docket-search engines for this case (e.g., DocketAlarm's patent search), but the complaint's own patent report does not list it; I could not confirm it was directly asserted in this Amazon action.

Procedural posture and venue. Parus filed this jury-demand patent suit under 35 U.S.C. § 271 on February 17, 2023, in the District of Delaware (1:23-cv-00190), assigned to Judge Gregory B. Williams with Magistrate Judge Christopher J. Burke handling referral matters (D.I. entries confirm assignment and pro hac vice admissions for Parus counsel Alan P. Block, John B. Campbell Jr., and Casey L. Shomaker). Amazon stipulated to extend its answer deadline to May 4, 2023 (D.I. 9). Amazon then moved to dismiss on a license defense grounded in a 2021 Settlement Agreement; on January 31, 2024, Judge Burke issued a Report and Recommendation (D.I. 71) recommending denial — not on the merits of the license, but because the agreement was not integral to the complaint, and the court declined to convert the motion to summary judgment under Rule 12(d) (IP/DE, Feb. 2, 2024). Venue matters here because Delaware is one of the highest-volume patent districts with a mature local patent-rule practice, and Amazon's status as a Delaware corporation makes general jurisdiction and venue essentially uncontestable. As to status: one case-tracking database (Ex Parte) labels the case "Closed," but I could not verify a final dismissal or judgment entry on PACER-derived sources, so the ultimate disposition is unconfirmed.

Why the case is notable. This suit is one prong of a coordinated Parus assertion campaign over the Webley-era voice-browser portfolio against essentially every major voice assistant: Apple/Siri (W.D. Tex. 2021, asserting 6,721,705 and 8,185,402 per press reports), Google (N.D. Cal. 3:22-cv-07830), Microsoft (W.D. Wash. 2:22-cv-01700), and Amazon here — a classic early-internet-patent NPE sweep against the AI/voice-assistant market leaders. The Amazon case is also procedurally interesting: Amazon's unusual "we're already licensed" motion to dismiss produced a sua sponte R&R that rigorously enforced the rule that courts may not consider extra-complaint documents on a 12(b)(6) motion even where the plaintiff itself relied on them, leaving the license dispute for a later stage. The complaint analysis also flags a substantive fault line over whether third-party Alexa skill developers' conduct is attributable to Amazon for claim-element purposes. I found no confirmed PTAB IPR proceedings on these patents in my searches, so any IPR linkage remains unverified.

Based on my research (which hit tool-call limits, so some items below are confirmed from primary sources and others flagged as unconfirmed), here is the chronological development of Parus Holdings, Inc. v. Amazon.com, Inc., No. 1:23-cv-00190-GBW-CJB (D. Del.).

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Threshold note on the asserted patents

The case metadata lists U.S. Patent No. 6,721,705 as the patent at issue, and DocketAlarm's patent-indexed search does associate the '705 patent with this docket. However, the initial complaint's Report to the Commissioner (D.I. 3, filed 2023-02-17) identified only U.S. Patent Nos. 7,516,190; 9,377,992; and 10,320,981 (Justia docket). Whether the '705 patent was added via a later amended complaint (as appears possible from the DocketAlarm index) is unconfirmed — I could not verify an amended-complaint filing in the available sources. The complaint (per the Ex Parte complaint analysis) targeted Amazon's Alexa Voice Service and Alexa Skills (e.g., the "Tide Pool" skill) under the '190 and '992 patents.

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1. Filing & initial pleadings (2023)

• 2023-02-17 — Parus filed its Complaint with jury demand (D.I. 1) and the Rule 7.1 disclosure (D.I. 4); summons issued (D.I. 5). Case assigned to Judge Gregory B. Williams, with Magistrate Judge Christopher J. Burke (D.I. 2). (Justia docket)
• 2023-03-14 — Amazon served (D.I. 6); answer due 2023-04-04.
• 2023-03-20 — Stipulation extending Amazon's time to respond to 2023-05-04 (D.I. 9), so ordered by Judge Williams. Parus's pro hac vice counsel entered appearances (D.I. 7, 8, 10; Alan P. Block, John B. Campbell, Jr., Casey L. Shomaker).
• The answer/counterclaims and any amended complaint fall after the last Justia docket pull (2023-03-21) and are not confirmed in my sources. The case proceeded with motion practice in 2023–2024, indicating an answer was filed, but I could not verify its docket number or whether counterclaims were asserted.

2. Pre-trial motion of substance: motion to dismiss on license defense (2023–2024)

The only substantive pre-trial motion confirmed is Amazon's Rule 12(b)(6) motion to dismiss based on an affirmative license defense, citing a 2021 Settlement Agreement (apparently tied to Parus's earlier W.D. Tex. litigation against Amazon, No. 6:19-cv-00454-ADA, involving Parus's '431 and '084 voice-search patents).

• 2024-01-31 — Judge Burke issued a Report & Recommendation (D.I. 71) recommending denial of the motion. Key holdings (per IP/DE, 2024-02-02):
  • On a 12(b)(6) motion, the court considers only the complaint, attached exhibits, public records, and integral documents.
  • The 2021 Settlement Agreement was not central to Parus's claims, so the court could not consider the license (or the parties' extraneous exhibits, including Parus's CEO declaration) at the pleading stage.
  • The court declined to convert the motion to summary judgment under Rule 12(d) at that early stage, even though neither side requested conversion.
  • The court expressly noted the license defense "is not evident from the face of Plaintiff's Complaint," and that "disputes relating to the effect of the 2021 Settlement Agreement may be re-raised at the appropriate time."
• The district judge's adoption order on the R&R is not confirmed in my sources (the IP/DE post describes it as a recommendation; Judge Williams's adoption order would be a later docket entry I could not retrieve).

No motions to transfer venue, to stay pending IPR, or for summary judgment were confirmed in the sources I retrieved. (Judge Williams and Judge Burke are the assigned judges per DocketAlarm.)

3. Claim construction (Markman)

No Markman decision was confirmed. Given that the case was stayed in late 2024 and the docket tracker lists it as closed, the case does not appear to have reached a claim construction ruling — but I could not verify whether Markman briefing or a tutorial occurred.

4. Discovery milestones

No specific discovery orders or disputes of strategic significance were confirmed from my sources. The only "discovery-adjacent" milestone is the court's refusal in the R&R to shortcut the license-defense fact dispute, effectively preserving discovery on the 2021 Settlement Agreement's scope for a later (summary judgment/trial) stage.

5. Trial / verdict / post-trial

No trial occurred. The case was stayed before trial (below), and no verdict, JMOL, new-trial motion, or fee motion was identified.

6. Stay and final disposition (2024–2025)

• 2024-10-29 — The parties filed a Stipulation and [Proposed] Order Staying Case (D.I. 172), stating the parties were in the process of resolving the action. Terms: the action was stayed until further order; within 30 days the parties were to either (a) file a stipulation to dismiss or (b) submit a joint status report on resolution status. The proposed order was signed by Judge Burke. (DocketAlarm copy of D.I. 172.)
• The Ex Parte case tracker lists the case status as "Closed," strongly indicating the parties followed through with a stipulated dismissal — but the date and terms (with/without prejudice) of any dismissal order are unconfirmed in my sources. No appeal was identified.

7. Parallel PTAB proceedings and effect on the litigation

• IPR2022-01542 (Apple Inc. v. Parus Holdings, Inc.) — Petition filed 2022-09-16 challenging the '190 patent; terminated 2023-03-06 by Board decision on settlement prior to institution (joint motion to terminate filed 2023-03-03; fee refund). This was an Apple IPR (related to Parus's separate Apple litigations), not an Amazon IPR, and it was dismissed before institution — so it had no direct preclusive effect here, though it removed one validity challenge to an asserted patent.
• Google IPRs on the '705 patent and related Parus patents (related to Parus v. Google, N.D. Cal. 3:22-cv-07830, not this Amazon case, but directly relevant to the '705 patent in the case metadata): per McKool Smith's 2024-08-15 announcement, the PTAB issued a final written decision on 2024-08-01 rejecting Google's challenge and finding the claims of U.S. Patent No. 6,721,705 patentable, and the Board had earlier denied institution of IPRs on Parus's 7,386,455 and 7,516,190 patents. This confirms the '705 and '190 patents were surviving validity challenges at the PTAB while the Amazon case was pending, but no Amazon-filed IPR on the asserted patents was confirmed in my sources.
• The PTAB activity appears to have had at most an indirect effect on this case; the case's ultimate path was the October 2024 stay pending settlement, not a stay pending IPR.

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Bottom line

This was a short-lived, settlement-resolved Alexa patent case: filed 2023-02-17 in Delaware; Amazon moved to dismiss on a 2021 license defense; Judge Burke recommended denial on 2024-01-31 on the ground the license was outside the pleadings; the parties stipulated to a stay on 2024-10-29 while they finalized a resolution, and the case is closed per the Ex Parte tracker — consistent with a stipulated dismissal (unconfirmed as to date/terms). No Markman, summary judgment, trial, or appeal occurred. The PTAB backdrop includes a settled Apple IPR on the '190 patent (IPR2022-01542) and a Google IPR win for Parus on the '705 patent (FWD 2024-08-01), but no Amazon IPR was confirmed.

Confidence caveats: I could not verify (a) Amazon's answer/counterclaims, (b) any amended complaint adding the '705 patent, (c) Judge Williams's adoption of the R&R, (d) the final dismissal order's date/terms, or (e) the absence of other motions (e.g., § 101 motions) — these items should be confirmed against PACER before relying on them in a filing.

Press & news coverage of Parus v. Amazon

Coverage of this specific case is thin. My searches across Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, and EFF turned up no mainstream news or legal-wire article devoted to the Delaware Alexa suit itself; the only substantive published analysis of this docket is the Delaware IP litigation blog IP/DE, which on 2024-02-02 reported on Judge Burke's January 31, 2024 Report & Recommendation (D.I. 71) denying Amazon's license-based motion to dismiss. IP/DE highlighted the unusual posture: Amazon moved to dismiss on a license defense and attached the license; Parus opposed on the merits and itself relied on the license plus a CEO declaration — yet the court sua sponte refused to consider any of it because the 2021 Settlement Agreement "is not central to Plaintiff's claims" and dismissal "is not appropriate" on the pleadings. The blog's take went beyond the court record, characterizing the ruling as a "sua sponte dismissal of the argument, even after the plaintiff responded on the merits without raising the document issue," and concluded it "goes to show how seriously the Court takes the often-overlooked limitations on what materials it can consider in a motion to dismiss." No outlet reported any damages figure sought, any verdict, or any settlement terms; the October 2024 stay pending resolution and the case's closure appear in docket databases (Ex Parte, Justia) but were not the subject of published press analysis.

Related coverage fills in the campaign context. The same voice-browser portfolio is the subject of firm-issued and wire coverage: a PR Newswire release (republished by Epicos, dated 2019-08-07) covered Parus's earlier W.D. Tex. Alexa suit on U.S. Patent Nos. 9,451,084 and 7,076,431, quoting CEO Taj Reneau that "Parus has made significant investments in developing its technology and Parus intends to vigorously defend its patent portfolio" — that is the predecessor case whose 2021 settlement supplied the license defense at issue in the Delaware suit, though no press report connects those dots explicitly. On the validity front, McKool Smith's press release (2024-08-15) announced the PTAB's August 1, 2024 final written decision rejecting Google's IPR challenge to the '705 patent and noted the Board had previously denied institution on the '455 and '190 patents, adding that those patents "have also been asserted in district court litigation" — confirming the asserted-patent family's litigation footprint but not commenting on the Amazon case specifically. Notably, the firm's release frames Parus as a "twenty-five year history" operating company, in tension with the Stanford NPE Litigation Database's case entry for this Amazon suit, which tags Parus as a "product company" patent asserter.

Reporting that goes beyond the court record. The most recent item touching this litigation is Law.com Radar (2025-10-24), reporting that Parus itself filed a Texas legal-malpractice suit against Mintz Levin and two of its attorneys, alleging negligence in handling Parus's patent cases "against major technology companies including Apple, Google and Amazon" — a postscript that implicitly characterizes the outcome of this and the sibling cases as adverse to Parus (consistent with the license-defense dispute and the case's quiet closure). The Ex Parte complaint analysis (a machine-generated tool, not press) adds detail on the asserted '190/'992 claims against Alexa Skills and AWS Lambda, including the "Tide Pool" skill. Beyond IP/DE's procedural analysis, no analyst commentary, industry reaction, or market-impact reporting on the Amazon case was located; if any Law360 or Bloomberg Law article exists, it sits behind paywalls and did not surface in open web searches, so I cannot cite it.

Sources

• Complaint analysis | 1:23-cv-00190 | Parus Holdings Inc v. Amazon.com Inc | Ex Parte
• Complaint analysis | 6:19-cv-00432 | Parus Holding | Ex Parte
• Parus Holdings Inc.
• Cases
• 7516190 | NPE Litigation Database
• 1:23-cv-00190 | Parus Holdings Inc v. Amazon.com Inc | Ex Parte
• Search court records on patent:(6721705)
• Parus Holdings Inc. v. Amazon.com, Inc.
• Parus Holdings Inc. v. Amazon.com, Inc.
• 10320981 | NPE Litigation Database
• Patent Cases, Dockets and Filings in the U.S. District Court for the Western District of Washington
• Court Rejects Motion to Dismiss Based on License Defense, Holding that Defendant Cannot Rely on Documents Outside of a Complaint—Even If Plaintiff Doesn't Object

I'll research the counsel of record for Parus Holdings in this case. Let me search multiple sources.

The Justia docket confirms Parus's Delaware local counsel (Brian and Michael Farnan) and three pro hac vice attorneys (Alan P. Block, John B. Campbell Jr., Casey L. Shomaker). Now let me identify their firms and backgrounds.

Alan Block (McKool Smith, LA), John B. Campbell (McKool Smith, Austin), and Casey Shomaker (McKool Smith, Dallas) are confirmed. Let me verify the Farnan LLP local counsel details and check for any additional Parus attorneys on the docket.

Counsel of Record — Plaintiff Parus Holdings, Inc.

Parus Holdings, Inc. v. Amazon.com, Inc., No. 1:23-cv-00190-GBW-CJB (D. Del.)

Based on the verified docket entries (D.I. 1, 6, 7, 8, 10 — Justia docket retrieved 2023-03-21) and firm/public records, Parus is represented by five confirmed attorneys in two firms: Delaware local counsel Farnan LLP and pro hac vice national counsel from McKool Smith P.C. (the same team running Parus's coordinated voice-assistant campaign against Apple, Google, and Microsoft). No in-house counsel for Parus was identified in any source, and I found no evidence of any other firm appearing for Parus in this docket.

Local counsel (Delaware, of record / CM-ECF filers)

1. Brian E. Farnan — Farnan LLP, Wilmington, DE (919 N. Market St., 12th Floor)

• Role: Local counsel; the registered CM-ECF filer who filed the pro hac vice motions (D.I. 7, 8, 10) on Parus's behalf. Under D. Del. LR 83.5(d), all papers must be filed through Delaware counsel, so he is the attorney of record for every filing.
• Experience: Founding partner of Farnan LLP and one of Delaware's most active patent-litigation local counsel; appears regularly in D. Del. patent cases (e.g., IBM v. …, 22-590-GBW; TQ Delta v. 2Wire; numerous NPE cases).

2. Michael J. Farnan — Farnan LLP, Wilmington, DE

• Role: Local counsel; filed the executed summons return (D.I. 6) and is listed with Brian Farnan as Parus's Delaware counsel on the docket.
• Experience: Partner at Farnan LLP; Delaware IP and commercial litigator who regularly serves as local counsel in D. Del. patent matters.

Pro hac vice counsel (national/lead litigation team)

3. John B. Campbell, Jr. — McKool Smith P.C., Austin, TX (303 Colorado St., Suite 2100)

• Role: Pro hac vice (admitted by order dated 2023-03-17, D.I. 7). Based on his role in the parallel cases, he is best characterized as lead national counsel for Parus, though the docket does not formally designate a "lead" attorney. (His Texas Bar No. is 24036314; jcampbell@McKoolSmith.com.)
• Experience: McKool Smith principal and patent trial lawyer; served as Parus's counsel in the coordinated Webley voice-browser campaign — including the predecessor W.D. Tex. case against Amazon (6:19-cv-00454-ADA) and the Parus cases against Apple, Google (N.D. Cal. 3:22-cv-07830), and Microsoft (W.D. Wash. 2:22-cv-01700) — and in PTAB proceedings on the Parus portfolio (e.g., the Google IPRs culminating in the August 2024 final written decision upholding the '705 patent). Also litigates for defendants (e.g., current defense work for American Airlines in E.D. Tex.).

4. Alan P. Block — McKool Smith P.C., Los Angeles, CA (300 S. Grand Ave., Suite 2900)

• Role: Pro hac vice (admitted by order dated 2023-03-17, D.I. 8). Principal at McKool Smith.
• Experience: ~37-year IP litigator (UCLA Law 1989; Cornell B.S. chemical engineering); former partner at Oppenheimer Wolff & Donnelly; former President of the Los Angeles IP Law Association (2002–03); recognized in Legal 500; litigates utility/design patent cases through trial in district courts and before the Federal Circuit, and advises on PTAB post-issuance proceedings. (In a separate 2025 engagement he appeared for defendant American Airlines in E.D. Tex., reflecting his dual plaintiff/defendant practice.)

5. Casey L. Shomaker — McKool Smith P.C., Dallas, TX (300 Crescent Court, Suite 1500)

• Role: Pro hac vice (admitted by order dated 2023-03-20, D.I. 10). Principal at McKool Smith. (Texas Bar No. 24110359; cshomaker@McKoolSmith.com.)
• Experience: Patent litigator who entered appearances for Parus in the parallel cases — the W.D. Tex. Amazon/Apple litigation (transferred to W.D. Wash. as 2:22-cv-01700) and Parus v. Google (N.D. Cal. 3:22-cv-07830) — and has worked on PTAB proceedings involving the Parus portfolio (e.g., the Intuit v. Samesurf IPRs, where colleague Alan Block was added as back-up counsel).

Caveats (flag before relying in a filing)

• Completeness: The Justia docket for this case stops at 2023-03-21 (D.I. 10). I could not retrieve the complaint's signature block (D.I. 1) or later filings (e.g., the 2024 briefing on Amazon's motion to dismiss and the D.I. 71 R&R), so additional McKool Smith or other attorneys may have appeared later in the case; the five above are the confirmed counsel of record from the appearance records.
• "Lead" designation: D. Del. docket entries do not label lead vs. of counsel. The lead-counsel characterization of Campbell is an inference from his signing role in the related Parus cases, not a docket designation.
• In-house counsel: None identified; Parus is a small holding company and no general counsel or in-house attorney appears on any retrieved filing.
• Opposing counsel note: The Justia page's truncated "Represented By" list also shows a "Steven J." entry — that is Steven J. Balick (Ashby & Geddes), Amazon's Delaware counsel (he filed D.I. 9, the stipulation extending Amazon's answer deadline), not Parus's counsel.

I've confirmed Amazon's Delaware local counsel (Ashby & Geddes — Balick and Mayo) from the D.I. 172 stipulation. Now I need to identify Amazon's national/pro hac vice counsel who appeared on the substantive motion practice.

Defense Counsel of Record — Amazon.com, Inc.

Parus Holdings, Inc. v. Amazon.com, Inc., No. 1:23-cv-00190-GBW-CJB (D. Del.)

Based on the docket documents I was able to retrieve (Justia docket pull of 2023-03-21; the D.I. 172 stipulation copy via DocketAlarm), only Amazon's Delaware local counsel is confirmed. Amazon's national/pro hac vice litigation team could not be verified from available sources — see caveats below.

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Confirmed: Delaware local counsel (of record / CM-ECF filers)

1. Steven J. Balick — Ashby & Geddes, P.A., Wilmington, DE

• Role: Local counsel; Amazon's registered CM-ECF filer on the docket.
• Evidence: Filed the Stipulation to Extend Time to Respond to the Complaint to May 4, 2023 (D.I. 9, filed 2023-03-20), which Judge Williams so-ordered the same day (Justia docket). Also signed the Stipulation and [Proposed] Order Staying Case (D.I. 172, dated 2024-10-29) as "Counsel for Defendant Amazon.com, Inc." (DocketAlarm copy of D.I. 172). His bar number (#2114) and contact (500 Delaware Ave., 8th Floor, P.O. Box 1150, Wilmington, DE 19899; sbalick@ashbygeddes.com) appear on D.I. 172.
• Experience: A longtime Delaware commercial/IP litigator and name partner at Ashby & Geddes; routinely serves as Amazon's Delaware counsel in D. Del. patent cases (e.g., the firm's role in VB Assets, LLC v. Amazon.com Services, LLC, No. 1:24-cv-00839-MN, where Balick and Mayo filed Amazon entities' pro hac vice motions).

2. Andrew C. Mayo — Ashby & Geddes, P.A., Wilmington, DE

• Role: Local counsel (of record on the 2024 stipulation).
• Evidence: Signed D.I. 172 (2024-10-29) as counsel for Amazon alongside Balick; bar number #5207; amayo@ashbygeddes.com. The Justia "Represented By" list for this case shows the truncated "Steven J." entry (Balick), but D.I. 172 affirmatively confirms Mayo as co-counsel for Amazon.
• Experience: Delaware litigator at Ashby & Geddes; active in the firm's Amazon-defense docket (see the 2025 pro hac vice motion in VB Assets v. Amazon.com Services, LLC, which he filed on Amazon's behalf).

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Not confirmed — national / pro hac vice counsel

Amazon's out-of-state lead litigation counsel could not be identified from the sources available to me, and I will not speculate. Specifically:

• The Justia docket for this case ends at 2023-03-21 (D.I. 10) — before Amazon's answer (due 5/4/2023), the license-based Rule 12(b)(6) motion to dismiss (filed later in 2023), and the D.I. 71 R&R (2024-01-31) — so the answer's signature block and any pro hac vice motions filed by Amazon's national counsel fall outside the retrieved record.
• The one post-2023 document I retrieved — the D.I. 172 stay stipulation — bears only the Ashby & Geddes signatures for Amazon (standard practice: D. Del. local counsel signs stipulations regardless of who leads the case), so it reveals nothing about Amazon's national team.
• The IP/DE blog coverage of the R&R identifies the parties but does not name Amazon's arguing counsel.
• In the predecessor W.D. Tex. case (Parus v. Amazon, No. 6:19-cv-00454-ADA, settled in 2021 and the source of the license defense), Amazon's defense team was not identified in any source I retrieved for this assignment.

To complete this list before relying on it in a filing, pull from PACER: (a) Amazon's answer/counterclaims (expected docket entry ~May 2023), (b) Amazon's motion to dismiss and supporting brief (likely late 2023, in the D.I. 30–60 range), and (c) any pro hac vice motions filed by Ashby & Geddes on Amazon's behalf (typically filed by Balick or Mayo and docketed shortly after the Justia cutoff). Those documents will carry the signatures of Amazon's national counsel. If the case resolved via stipulated dismissal in late 2024/2025 as the "Closed" tracker status suggests, the dismissal stipulation may also list the full defense team.

Bottom line

Confirmed: Steven J. Balick and Andrew C. Mayo (both Ashby & Geddes, P.A., Wilmington, DE) as Delaware local counsel — the only defense attorneys affirmatively verifiable from the record. Unverified: Amazon's lead/national counsel, any in-house counsel, and any additional local counsel; none should be named without PACER confirmation. No filings are sealed that I know of — the gap is purely a function of the truncated public docket pull, not confidentiality.