Koji IP, LLC v. Renesas Electronics America, Inc.
- Kang
- 3:24-cv-03089
- U.S. District Court · District of Minnesota
- 5
Counsel of record per CourtListener. Firm names are approximate.
In Koji IP, LLC v. Renesas Electronics America, Inc., Magistrate Judge Kang denied without prejudice attorney Kalra's motion to withdraw as counsel for corporate plaintiff Koji because doing so would leave the corporation unrepresented.
Attorneys and corporate litigants in federal court who face counsel withdrawal disputes, particularly corporations that cannot represent themselves and must find licensed replacement counsel before existing counsel may be permitted to withdraw.
What happened
In Koji IP, LLC v. Renesas Electronics America, Inc. (Case No. 24-cv-03089-PHK), Koji IP, LLC filed a patent infringement lawsuit against Renesas Electronics America, Inc. Koji's attorney, Attorney Kalra, sought to withdraw from the case in May 2026, citing a conflict of interest arising from sanctions the court had imposed. Koji opposed the withdrawal, and despite months of effort — reportedly reaching out to more than 50 law firms — Koji was unable to find replacement counsel.
Under federal court rules, a corporation cannot represent itself without a licensed attorney. Allowing Attorney Kalra to withdraw without a replacement in place would have left Koji legally unable to file papers, oppose motions, or present evidence on its own behalf. The court also noted that all currently pending motions had already been fully briefed, meaning the case was at a late stage where switching counsel would cause further delay. Additionally, the court observed that the attorneys' fees award that partly motivated Kalra's withdrawal request had since been paid in full, potentially reducing her conflict concerns.
Magistrate Judge Peter H. Kang denied Attorney Kalra's motion to withdraw without prejudice, meaning she may renew the motion later under different circumstances. The court also denied as moot a related motion to shorten the time for hearing the withdrawal motion. The court ordered Koji to continue actively seeking substitute counsel, and ordered Attorneys Kalra and Ramey to assist in that search. The hearing previously scheduled for August 27, 2026 was vacated.
The detailed version
- Koji IP, LLC v. Renesas Electronics America, Inc. · No. 3:24-cv-03089
- Kang
- Aug. 24, 2026
Background
Koji IP, LLC ("Koji") filed a patent infringement action against Renesas Electronics America, Inc. ("Renesas") on May 22, 2024. The opinion notes this is Koji's third such action against Renesas. Earlier in the litigation, the court issued a Sanctions Order (March 26, 2025) and a Fees Order (March 31, 2025), both incorporated by reference in this opinion.
On May 20, 2026, Attorney Kalra — Koji's counsel of record — moved to withdraw, asserting that the court's imposition of monetary and nonmonetary sanctions created a conflict of interest between herself and Koji, making her continued representation materially limited under California Rule of Professional Conduct 1.7(b). Attorney Kalra noted she was jointly and severally liable for the fees award along with Koji and Attorneys Ramey and Kubiak.
Koji opposed the withdrawal. Renesas filed a statement of non-opposition. The court set a deadline for Koji to identify substitute counsel by June 9, 2026, then ordered status reports when that deadline passed without success. Multiple status reports filed between June and August 2026 confirmed Koji's ongoing failure to secure replacement counsel. Koji reported reaching out to more than 50 law firms. On July 27, 2026, Renesas filed a notice reporting full payment of the attorneys' fees award, with the opinion noting this payment was apparently made by Attorney Kubiak.
Legal Standard
The court applied Civil Local Rule 11-5(a), which prohibits counsel from withdrawing without a court order, and Civil Local Rule 3-9(b), which requires corporations to appear only through a licensed member of the bar. The court cited the well-established rule that a corporation may appear in federal court only through licensed counsel, and noted that courts have discretion to deny withdrawal motions — particularly where doing so would leave a corporate entity unrepresented. Key factors include the reason for withdrawal, potential prejudice to litigants, and the extent to which withdrawal would delay resolution.
Analysis and Ruling
The court identified several reasons to deny the withdrawal motion at this stage:
1. Corporate representation requirement: As a corporation, Koji cannot represent itself. Granting withdrawal without a replacement attorney in place would render Koji unable to file pleadings, oppose motions, or present evidence — a result the court found clearly prejudicial.
2. Late stage of proceedings: The case has been pending since May 2024, all outstanding motions are fully briefed, and substituting counsel at this point would cause unnecessary delay and hinder efficient administration of justice.
3. Partial mitigation of withdrawal grounds: Attorney Kalra's conflict-of-interest concern was based partly on her personal financial exposure from the fees award. Because the fees award has since been paid in full, the court found this may at least partially reduce the conflict motivating her withdrawal request. The court also noted that because all pending motions are fully briefed, Kalra's involvement going forward would be limited.
4. Koji's difficulty in finding substitute counsel: Despite months of effort and outreach to more than 50 firms, Koji has been unable to retain replacement counsel, making it uncertain whether withdrawal would ever be followed by timely substitution.
Disposition
Magistrate Judge Kang denied without prejudice Attorney Kalra's Motion to Withdraw (Dkt. 137). "Without prejudice" means the motion may be refiled if circumstances change. The court also denied as moot the motion to shorten time on the withdrawal motion (Dkt. 138).
The court issued the following affirmative orders: - Koji must continue diligently seeking substitute counsel, or work to resolve the issues prompting the withdrawal motion with Attorney Kalra if possible. - Attorneys Kalra and Ramey must continue to assist Koji in finding substitute counsel. - If substitute counsel is retained, Koji and Attorney Kalra must inform that counsel, who must promptly enter an appearance and cooperate with Attorney Kalra on the substitution; Attorney Kalra must likewise cooperate. - The hearing previously scheduled for August 27, 2026 is vacated.
This order resolves Dkts. 137 and 138. Dkts. 162, 163, and 165 (status reports) were also referenced but no separate disposition was stated for those docket entries.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.