Polaris Innovations Limited v. Dell Inc.

Federal Civil Lawsuit Texas Western District Court, Case No. 5:16-cv-00451
District Judge Xavier Rodriguez, presiding
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District Judge Xavier Rodriguez
Last Updated December 13, 2016 at 11:58 PM EST (8.4 years ago) Update UpdateSpaceE-Mail Alert AlertsSpaceJump Jump
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Parties
No Logo POLARIS INNOVATIONS Ltd., Plaintiff
Officially listed as "Polaris Innovations Limited"

Represented by Gonzalez Chiscano Angulo & Kasson PC

Name Phone Fax E-Mail
ATTORNEY TO BE NOTICED Henry B. Gonzalez, III +2105698 500 862 8712 +1 210 569 8490 hbg@gcaklaw.com

Represented by Tensegrity Law Group, LLP

Name Phone Fax E-Mail
ATTORNEY TO BE NOTICED Paul Tsutomu Ehrlich +1 650 802 6000 +1 650 802 6001 Paul.Ehrlich@tensegritylawgroup.com
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Matthew D. Powers matthew.powers@tensegritylawgroup.com
ATTORNEY TO BE NOTICED Stefani C. Smith stefani.smith@tensegritylawgroup.com
v.
Dell, Inc. Dell, Inc., Defendant
Officer/Director, Dell International L.l.c.
Dell Computer Corporation Officer/Director, Dell Computer Corporation
Officer/Director, Perot Systems Corp
Officer/Director, Quest Software, Inc.
VMware, Inc. Officer/Director, VMware, Inc.

Represented by Alston & Bird, LLP

Name Phone Fax E-Mail
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Brady Cox +1 214 922 3400 +1 214 922 3899 brady.cox@alston.com
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Michael J Newton +1 214 922 3400 +1 214 922 3899 mike.newton@alston.com
NVIDIA Corporation NVIDIA Corporation, Defendant

Represented by Fish & Richardson, PC

Name Phone Fax E-Mail
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Bryan K Basso +1 650 839 5070 basso@fr.com
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Ruffin B. Cordell +1 262 626 6449 +1 202 783 2331 cordell@fr.com
LEAD ATTORNEY, PRO HAC VICE, ATTORNEY TO BE NOTICED Neal Goldberg +1 202 626 7704 +1 202 783 2331 goldberg@fr.com
LEAD ATTORNEY, ATTORNEY TO BE NOTICED David Michael Hoffman +1 512 226 8154 +1 512 320 8935 dhoffman@fr.com
LEAD ATTORNEY, PRO HAC VICE, ATTORNEY TO BE NOTICED Aamir A. Kazi +1 404 892 5005 +1 404 892 5002 kazi@fr.com
LEAD ATTORNEY, ATTORNEY TO BE NOTICED Katherine Kelly Lutton +1 650 839 5084 +1 650 839 5071 lutton@fr.com
Attributes
Citation Section 35 U.S.C. § 271
Nature of Suit 830 - Property Rights: Patent
Timeline
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Legal Document (Payment Possibly Required) 55 Filed: 12/12/2016, Entered: None Unknown Document Type
Acknowledgment of Transfer from Northern District of California (rf) (Entered: 12/12/2016)
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Legal Document (Payment Possibly Required) 54 Filed: 12/5/2016, Entered: None Unknown Document Type
Report on Patent sent to U.S. Patent and Trademark Office. (rf) (Entered: 12/05/2016)
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Legal Document (Payment Possibly Required) 53 Filed: 12/5/2016, Entered: None Unknown Document TypeCourt Filing
ORDER GRANTING 25 Motion to Transfer Case. It is hereby ORDERED that this action be TRANSFERRED to the United States District Court for the Northern District of California. Signed by Judge Xavier Rodriguez. (rf) (Entered: 12/05/2016)
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Legal Document (Payment Possibly Required) 52 Filed: 11/22/2016, Entered: None Unknown Document Type
PROPOSED Protective Order by Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Exhibit A, # 2 Certificate of Service)(Smith, Stefani) Modified on 11/23/2016, to edit text (rf). (Entered: 11/22/2016)
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Legal Document (Payment Possibly Required) 51 Filed: 11/10/2016, Entered: None Unknown Document TypeCourt Filing
Minute Entry for proceedings held before Judge Xavier Rodriguez: Status Conference held on 11/10/2016 (Minute entry documents are not available electronically.). (Court Reporter Karl Myers.)(rf) (Entered: 11/10/2016)
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Legal Document (Payment Possibly Required) 50 Filed: 11/8/2016, Entered: None Unknown Document Type
REPLY to Response to Motion, filed by Polaris Innovations Limited(an Irish limited company), re 41 Motion to Dismiss for Failure to State a Claim Certain of Dell's and NVIDIA's Counterclaims filed by Polaris Innovations Limited (Attachments: # 1 Declaration of Alex H. Chan, # 2 Exhibit D)(Chan, Alex) (Entered: 11/08/2016)
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Legal Document (Payment Possibly Required) 49 Filed: 11/8/2016, Entered: None Unknown Document Type
NOTICE of Attorney Appearance by Michael Dennis Marin on behalf of Dell Inc.(a Delaware corporation). Attorney Michael Dennis Marin added to party Dell Inc.(pty:cc), Attorney Michael Dennis Marin added to party Dell Inc.(pty:dft), Attorney Michael Dennis Marin added to party Dell Inc.(pty:cc) (Marin, Michael) (Entered: 11/08/2016)
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Legal Document (Payment Possibly Required) 48 Filed: 11/2/2016, Entered: None Unknown Document Type
Unopposed MOTION for Extension of Time to File Answer to 44 Dell's First Amended Answer and Defenses by Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Proposed Order)(Chan, Alex) (Entered: 11/02/2016)
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Legal Document (Payment Possibly Required) 47 Filed: 11/1/2016, Entered: None Unknown Document Type
Response in Opposition to Motion, filed by Dell Inc.(a Delaware corporation), NVIDIA Corporation, re 41 Motion to Dismiss for Failure to State a Claim Certain of Dell's and NVIDIA's Counterclaims filed by Polaris Innovations Limited (Attachments: # 1 Hoffman Declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Proposed Order)(Hoffman, David) (Entered: 11/01/2016)
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Legal Document (Payment Possibly Required) 46 Filed: 10/20/2016, Entered: None Unknown Document Type
MOTION to Appear Pro Hac Vice by Stefani C. Smith for Alex Chan ( Filing fee $ 100 receipt number 0542-8964907) by on behalf of Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Proposed Order)(Smith, Stefani) (Entered: 10/20/2016)
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Legal Document (Payment Possibly Required) 45 Filed: 10/20/2016, Entered: None Unknown Document Type
MOTION to Appear Pro Hac Vice by Stefani C. Smith for Jonathan Tamimi ( Filing fee $ 100 receipt number 0542-8964873) by on behalf of Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Proposed Order)(Smith, Stefani) (Entered: 10/20/2016)
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Legal Document (Payment Possibly Required) 44 Filed: 10/18/2016, Entered: None Unknown Document Type
Dell Inc.'s First Amended ANSWER to 1 Complaint, with Jury Demand and, COUNTERCLAIM against Polaris Innovations Limited by Dell Inc..(Newton, Michael) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 43 Filed: 10/18/2016, Entered: None Unknown Document Type
Polaris's Answer and Defenses to Dell's Counterclaims ANSWER to 21 Answer to Complaint, Counterclaim by Polaris Innovations Limited(an Irish limited company).(Smith, Stefani) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 42 Filed: 10/18/2016, Entered: None Unknown Document Type
Polaris's Answer and Defenses to NVIDIA's Counterclaims ANSWER to 19 Answer to Complaint, Counterclaim,, by Polaris Innovations Limited(an Irish limited company).(Smith, Stefani) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 41 Filed: 10/18/2016, Entered: None Unknown Document Type
Motion to Dismiss for Failure to State a Claim Certain of Dell's and NVIDIA's Counterclaims by Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Declaration of Stefani Smith, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Proposed Order)(Smith, Stefani) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 40 Filed: 10/18/2016, Entered: None Unknown Document TypeCourt Filing
ORDER (Setting Status Conference and Hearing on all Pending Motions for 11-10-16 at 10:00 AM before Judge Xavier Rodriguez). Signed by Judge Xavier Rodriguez. (jhw) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 39 Filed: 10/18/2016, Entered: None Unknown Document TypeCourt Filing
SCHEDULING ORDER: Pretrial Conference set for 5-24-18 at 9:30 AM before Judge Xavier Rodriguez; Trial set for 6-4-18 at 9:30 AM before Judge Xavier Rodriguez; ADR Report due 10-4-17; Discovery due 1-12-18; Dispositive Motions deadline 2-7-18. Signed by Judge Xavier Rodriguez. (jhw) (Entered: 10/18/2016)
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Legal Document (Payment Possibly Required) 38 Filed: 10/17/2016, Entered: None Unknown Document Type
Scheduling Recommendations/Proposed Scheduling Order by Dell Inc., NVIDIA Corporation, Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Exhibit A, # 2 Proposed Order)(Smith, Stefani) Modified on 10/18/2016, to add filers (rf). (Entered: 10/17/2016)
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Legal Document (Payment Possibly Required) 37 Filed: 10/17/2016, Entered: None Unknown Document Type
NOTICE Joint Rule 26 Report by Dell Inc., NVIDIA Corporation, Polaris Innovations Limited(an Irish limited company) (Smith, Stefani) Modified on 10/18/2016, to add filers (rf). (Entered: 10/17/2016)
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Legal Document (Payment Possibly Required) 36 Filed: 10/17/2016, Entered: None Unknown Document TypeCourt Filing
NON-CONSENT to Trial by US Magistrate Judge by Dell Inc.. (Newton, Michael) (Entered: 10/17/2016)
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Legal Document (Payment Possibly Required) 35 Filed: 10/17/2016, Entered: None Unknown Document TypeCourt Filing
NON-CONSENT to Trial by US Magistrate Judge by Polaris Innovations Limited(an Irish limited company). (Smith, Stefani) (Entered: 10/17/2016)
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Legal Document (Payment Possibly Required) 34 Filed: 10/17/2016, Entered: None Unknown Document Type
CERTIFICATE OF SERVICE by NVIDIA Corporation 33 Reply to Response to Motion, (Hoffman, David) (Entered: 10/17/2016)
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Legal Document (Payment Possibly Required) 33 Filed: 10/14/2016, Entered: None Unknown Document Type
***DOCUMENT IS DEFICIENT - CERTIFICATE OF SERVICE NOT SIGNED***REPLY to Response to Motion, filed by Dell Inc., NVIDIA Corporation, re 25 Opposed MOTION to Transfer Case filed by NVIDIA Corporation, Dell Inc. (Attachments: # 1 Guerra Supplemental Declaration, # 2 Hoffman Supplemental Declaration, # 3 Exhibit A)(Hoffman, David) Modified on 10/17/2016, to designate deficiency (rf). (Entered: 10/14/2016)
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Legal Document (Payment Possibly Required) 32 Filed: 10/13/2016, Entered: None Unknown Document TypeCourt Filing
NON-CONSENT to Trial by US Magistrate Judge by NVIDIA Corporation. (Hoffman, David) (Entered: 10/13/2016)
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Legal Document (Payment Possibly Required) 31 Filed: 10/7/2016, Entered: None Unknown Document Type
Unopposed MOTION for Extension of Time to File Response/Reply by Dell Inc., NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 10/07/2016)
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Legal Document (Payment Possibly Required) 30 Filed: 10/7/2016, Entered: None Unknown Document Type
Joint MOTION for Extension of Time to File Answer 19 nVidia's Counterclaims and 21 Dell's Counterclaims by Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Proposed Order)(Smith, Stefani) (Entered: 10/07/2016)
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Legal Document (Payment Possibly Required) 29 Filed: 10/5/2016, Entered: None Unknown Document Type
NOTICE of Attorney Appearance by George H. Spencer, Jr on behalf of NVIDIA Corporation. Attorney George H. Spencer, Jr added to party NVIDIA Corporation(pty:cc), Attorney George H. Spencer, Jr added to party NVIDIA Corporation(pty:dft) (Spencer, George) (Entered: 10/05/2016)
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Legal Document (Payment Possibly Required) 28 Filed: 10/3/2016, Entered: None Unknown Document Type
Response in Opposition to Motion, filed by Polaris Innovations Limited(an Irish limited company), re 25 Opposed MOTION to Transfer Case filed by NVIDIA Corporation, Dell Inc. (Attachments: # 1 Declaration of Michael Vladescu, # 2 Declaration of Stefani Smith, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M)(Smith, Stefani) (Entered: 10/03/2016)
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Legal Document (Payment Possibly Required) 27 Filed: 9/30/2016, Entered: None Unknown Document Type
Unopposed MOTION for Extension of Time to File Response/Reply as to 25 Opposed MOTION to Transfer Case by Polaris Innovations Limited(an Irish limited company). (Attachments: # 1 Proposed Order)(Smith, Stefani) (Entered: 09/30/2016)
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Legal Document (Payment Possibly Required) 26 Filed: 9/21/2016, Entered: None Unknown Document Type
Motion for leave to File Sealed Document (Attachments: # 1 Proposed Order, # 2 Sealed Document) (Hoffman, David) (Entered: 09/21/2016)
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Legal Document (Payment Possibly Required) 25 Filed: 9/21/2016, Entered: None Unknown Document Type
Opposed MOTION to Transfer Case by Dell Inc., NVIDIA Corporation. (Attachments: # 1 Guerra Declaration, # 2 Hoffman Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Proposed Order)(Hoffman, David) (Additional attachment(s) added on 9/23/2016: # 16 SEALED exhibit (rf). (Entered: 09/21/2016)
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Legal Document (Payment Possibly Required) 24 Filed: 9/15/2016, Entered: None Unknown Document Type
Letter directed to Brianna Kadjo regarding admittance to the bar. (rf) (Entered: 09/15/2016)
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Blank 23 Filed: 9/15/2016, Entered: None Unknown Document TypeCourt Filing
ORDER AND ADVISORY for Scheduling Recommendations/Proposed Scheduling Order. Plaintiff shall submit scheduling recommendations/proposed scheduling order to the Court. (Scheduling Recommendations/Proposed Scheduling Order due by 10-17-16); Notice of right to consent to disposition of a civil case by a U.S. Magistrate Judge. Signed by Judge Xavier Rodriguez. (jhw) (Entered: 09/15/2016)
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Legal Document (Payment Possibly Required) 22 Filed: 9/14/2016, Entered: None Unknown Document Type
RULE 7 DISCLOSURE STATEMENT filed by Dell Inc.. (Newton, Michael) (Entered: 09/14/2016)
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Legal Document (Payment Possibly Required) 21 Filed: 9/14/2016, Entered: None Unknown Document Type
ANSWER to 1 Complaint, with Jury Demand and, COUNTERCLAIM against Polaris Innovations Limited by Dell Inc..(Newton, Michael) (Entered: 09/14/2016)
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Legal Document (Payment Possibly Required) 20 Filed: 9/14/2016, Entered: None Unknown Document Type
NOTICE Rule 7.1 Disclosure Statement by NVIDIA Corporation (Hoffman, David) (Entered: 09/14/2016)
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Legal Document (Payment Possibly Required) 19 Filed: 9/14/2016, Entered: None Unknown Document Type
NVIDIA Corporation's ANSWER to 1 Complaint, with Jury Demand , COUNTERCLAIM against Polaris Innovations Limited by NVIDIA Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Hoffman, David) (Entered: 09/14/2016)
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Legal Document (Payment Possibly Required) 18 Filed: 8/22/2016, Entered: None Unknown Document Type
Pro Hac Vice Fee Paid by Brianna Ford; Filing fee $ 100, receipt number 500035851. (rf) (Entered: 08/22/2016)
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Blank 17 Filed: 8/18/2016, Entered: None
MOTION of Brianna Ford to Appear Pro Hac Vice by Dell Inc.. (rf) (Entered: 08/22/2016)
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Legal Document (Payment Possibly Required) 16 Filed: 8/18/2016, Entered: None
MOTION to Appear Pro Hac Vice by David M. Hoffman for Ruffin Cordell ( Filing fee $ 100 receipt number 0542-8770581) by on behalf of NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/18/2016)
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Legal Document (Payment Possibly Required) 15 Filed: 8/18/2016, Entered: None
MOTION to Appear Pro Hac Vice by David M. Hoffman for Bryan Basso ( Filing fee $ 100 receipt number 0542-8769417) by on behalf of NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/18/2016)
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Legal Document (Payment Possibly Required) 14 Filed: 8/15/2016, Entered: None
MOTION to Appear Pro Hac Vice by David M. Hoffman for Katherine Vidal ( Filing fee $ 100 receipt number 0542-8755450) by on behalf of NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/15/2016)
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Legal Document (Payment Possibly Required) 13 Filed: 8/12/2016, Entered: None
MOTION to Appear Pro Hac Vice by David M. Hoffman for Andrew Goldberg ( Filing fee $ 100 receipt number 0542-8753085) by on behalf of NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/12/2016)
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Legal Document (Payment Possibly Required) 12 Filed: 8/12/2016, Entered: None
MOTION to Appear Pro Hac Vice by David M. Hoffman for Aamir Kazi ( Filing fee $ 100 receipt number 0542-8752868) by on behalf of NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/12/2016)
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Legal Document (Payment Possibly Required) 11 Filed: 8/12/2016, Entered: None
Unopposed MOTION for Extension of Time to File Answer by Dell Inc.. (Attachments: # 1 Proposed Order)(Cox, Brady) (Entered: 08/12/2016)
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Legal Document (Payment Possibly Required) 10 Filed: 8/10/2016, Entered: None
NOTICE of Attorney Appearance by Paul T. Ehrlich on behalf of Polaris Innovations Limited. Attorney Paul T. Ehrlich added to party Polaris Innovations Limited(pty:pla) (Ehrlich, Paul) (Entered: 08/10/2016)
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Legal Document (Payment Possibly Required) 9 Filed: 8/10/2016, Entered: None
NOTICE of Attorney Appearance by Stefani C. Smith on behalf of Polaris Innovations Limited. Attorney Stefani C. Smith added to party Polaris Innovations Limited(pty:pla) (Smith, Stefani) (Entered: 08/10/2016)
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Legal Document (Payment Possibly Required) 8 Filed: 8/9/2016, Entered: None
Unopposed MOTION for Extension of Time to File Answer re 1 Complaint, by NVIDIA Corporation. (Attachments: # 1 Proposed Order)(Hoffman, David) (Entered: 08/09/2016)
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Legal Document (Payment Possibly Required) 7 Filed: 7/28/2016, Entered: None
SUMMONS Returned Executed by Polaris Innovations Limited. All Defendants. (Powers, Matthew) (Entered: 07/28/2016)
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Legal Document (Payment Possibly Required) 6 Filed: 5/17/2016, Entered: None
Summons Issued as to Dell Inc., NVIDIA Corporation. (rf) (Entered: 05/17/2016)
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Legal Document (Payment Possibly Required) 5 Filed: 5/17/2016, Entered: None
REQUEST FOR ISSUANCE OF SUMMONS by Polaris Innovations Limited. (Powers, Matthew) (Entered: 05/17/2016)
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Legal Document (Payment Possibly Required) 4 Filed: 5/17/2016, Entered: None
Letter to Attorneys Paul T. Ehrlich and Stefani C. Smith regarding attorney admission. (mgr) (Entered: 05/17/2016)
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Legal Document (Payment Possibly Required) 3 Filed: 5/17/2016, Entered: None
Report on Patent/Trademark sent to U.S. Patent and Trademark Office. (mgr) (Main Document 3 replaced on 5/17/2016) (mgr). (Entered: 05/17/2016)
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Legal Document (Payment Possibly Required) 2 Filed: 5/16/2016, Entered: None
RULE 7 DISCLOSURE STATEMENT filed by Polaris Innovations Limited, an Irish limited company. (Gonzalez, Henry) (Entered: 05/16/2016)
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Legal Document (Payment Possibly Required) 1 Filed: 5/16/2016, Entered: None
COMPLAINT ( Filing fee $ 400 receipt number 0542-8482346). No Summons requested at this time, filed by Polaris Innovations Limited, an Irish limited company. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Civil Cover Sheet)(Gonzalez, Henry) Modified on 5/16/2016, to remove filer (rf). (Entered: 05/16/2016)
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