Relink US LLC v. Tesla Inc.

Background

Relink US LLC’s patent-infringement action against Tesla Inc. concerns the ’755 Patent, which the opinion identifies as the only patent at issue. The Patent Trial and Appeal Board had previously denied institution of Tesla’s inter partes review petition. About a year later, Tesla asked the United States Patent and Trademark Office to conduct an ex parte reexamination of the patent. Tesla then moved to stay, or pause, this case until the reexamination proceedings—including any appeals—are resolved.

Legal standard

The court considered three factors used when deciding whether to stay a patent case during reexamination: whether discovery is complete and a trial date has been set; whether the reexamination will simplify the case; and whether the stay would cause undue prejudice or a clear tactical disadvantage to the party opposing it.

Discovery and trial

The court found that the parties had conducted almost no substantive discovery. Each side had served one set of document requests and interrogatories, but there had apparently been no significant exchange of documents or information. The case had no current schedule or trial date because of earlier proceedings, a transfer of the case, and Relink’s motion to transfer it back to Texas. This factor favored a stay.

Simplification of the issues

Tesla requested reexamination of 17 of the 20 patent claims at issue. The three claims not included in the request—Claims 15, 16, and 17—were related to Claim 1, which was included in the reexamination request. The court therefore concluded that the reexamination could affect all claims in the case.

The court also found that reexamination could simplify the litigation even if it did not cancel claims. It could provide the court with the Patent and Trademark Office’s expert analysis, clarify the scope of the claims, and potentially amend the claims in ways that would affect Relink’s arguments. This factor favored a stay.

Prejudice

The court rejected Relink’s argument that additional delay would cause undue prejudice. Relink did not make a specific showing of harm beyond the delay inherent in a stay, and it did not provide specific evidence that important evidence might become stale. The court also rejected the assertion that Tesla had delayed its reexamination request to gain an improper tactical advantage. Tesla stated that it had retained new counsel, conducted new prior-art searches, and consulted an expert during the intervening year.

The court noted that Relink and Tesla do not compete with each other, which weighed against finding prejudice. Relink also argued that its income depended entirely on enforcing the ’755 Patent and that a stay could affect its ability to license the patent. The court found that Relink had not explained how the stay would prevent licensing or why a later damages award would not provide complete recovery. Relink’s litigation investment also did not establish prejudice, given the limited proceedings so far.

Ruling

The court held that all three factors favored a stay. Judge Rita F. Lin granted Tesla’s motion to stay, and the action is stayed pending completion of the ex parte reexamination proceedings, including any appeals. The parties must file a status report on February 11, 2026, and every 120 days afterward, as well as within 14 days after the reexamination proceedings and any appeals are completed.