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S.D.N.Y.Procedural orderFiled Sept. 1, 2020

Ideal Industries Lighting LLC v. RAB Lighting Inc.

Judge
Lewis Liman
Docket
1:20-cv-05424
Court
U.S. District Court · Southern District of New York
Pages
3
Civil ProcedureIntellectual Property
In one sentence

In Ideal Industries Lighting v. RAB Lighting, Judge Liman stayed the patent case pending final resolution of a parallel International Trade Commission proceeding.

Who this affects

Ideal Industries Lighting LLC and RAB Lighting Inc.; the federal patent case is paused while the related International Trade Commission proceeding, including any appeals, becomes final.

What happened

Ideal Industries Lighting LLC sued RAB Lighting Inc. for allegedly infringing five patents. Cree Lighting, the name used by Ideal Industries Lighting, also brought the same patent allegations before the International Trade Commission.

RAB asked the court to pause the federal case under a law requiring a stay when the same parties and issues are before the Commission. Cree Lighting did not oppose the request.

Judge Lewis Liman ordered that the action be stayed until the Commission’s determination, including any appeals, becomes final. The court also postponed all conferences and deadlines and required the parties to file a joint status letter every four months.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Ideal Industries Lighting LLC v. RAB Lighting Inc. · No. 1:20-cv-05424
Judge
Lewis Liman
Date
Sept. 1, 2020

Background

Ideal Industries Lighting LLC, doing business as Cree Lighting, filed this patent-infringement action against RAB Lighting Inc. The complaint concerned five patents: U.S. Patent Nos. 8,403,531; 8,596,819; 8,777,449; 9,261,270; and 9,476,570.

The day after filing the federal case, Cree Lighting filed a complaint with the U.S. International Trade Commission requesting an investigation against RAB under Section 337 of the Tariff Act of 1930. The Commission later issued a notice instituting an investigation involving the same parties and the same five patents.

Motion to Stay

RAB moved under 28 U.S.C. § 1659(a) to stay the federal action. That statute requires a district court to stay proceedings involving claims with the same issues as an International Trade Commission proceeding when a qualifying party requests the stay. The request must be made within the statutory 30-day period. RAB argued that its motion was timely because it was filed within 30 days after the Commission’s notice of investigation was published. Cree Lighting confirmed that it did not oppose the motion.

Ruling

The order states: “This action is hereby STAYED.” The stay remains in place until the International Trade Commission’s determination, including any appeals, becomes final. Judge Lewis Liman also adjourned all conferences and deadlines indefinitely and directed the parties to file a joint letter reporting on the status of the Commission proceeding every four months. The order did not decide the patent-infringement allegations.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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