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S.D.N.Y.Procedural orderFiled June 28, 2023

Bell Semiconductor, LLC v. ASMedia Technology, Inc.

Judge
Lewis Liman
Docket
1:22-cv-08166
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureIntellectual PropertyMotion to Dismiss
In one sentence

Bell Semiconductor v. ASMedia: Judge Liman stayed the case pending Delaware proceedings and denied the pending jurisdictional dismissal motion without prejudice.

Who this affects

Bell Semiconductor, LLC and ASMedia Technology, Inc.; the case is paused while the related Delaware litigation proceeds.

What happened

In Bell Semiconductor, LLC v. ASMedia Technology, Inc., the court considered ASMedia’s request to pause the case while a related Delaware case was resolved. The Delaware case involves Bell Semiconductor and other parties.

The court granted ASMedia’s motion to stay the case. It concluded that an exception for lawsuits involving a patent owner’s customer applied to the usual first-filed-case rule. The court required the parties to file status reports every 60 days, beginning August 25, 2023.

Judge Lewis J. Liman also denied the pending motion to dismiss for lack of jurisdiction without prejudice to renewal. The action remains stayed, but either side may ask to lift the stay if circumstances in the Delaware case change.

The detailed version

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

Case
Bell Semiconductor, LLC v. ASMedia Technology, Inc. · No. 1:22-cv-08166
Judge
Lewis Liman
Date
June 28, 2023

Background

Bell Semiconductor, LLC brought this action against ASMedia Technology, Inc. A related case, Synopsys, Inc. & Cadence Design Sys., Inc. v. Bell Semiconductor, LLC, was pending in the U.S. District Court for the District of Delaware. ASMedia asked the court to stay, or pause, this action until the Delaware case was resolved.

Court’s Reasoning

The court held that the “customer-suit” exception to the first-to-file rule applied. That exception generally gives priority to a case brought by a manufacturer seeking a ruling that it did not infringe a patent or that the patent is invalid when a patent owner has first sued the manufacturer’s customer. The court stated that it was granting the stay substantially for the reasons ASMedia presented.

Rulings

The court granted ASMedia’s motion to stay the action pending resolution of the Delaware case. The stay was entered without prejudice to either side moving to lift it based on changed circumstances in Delaware, including a decision allowing an interlocutory appeal or a decision favorable to Bell Semiconductor in such an appeal.

The court denied the pending motion to dismiss for lack of jurisdiction without prejudice to renewal. The clerk was directed to close that motion and stay the action. The parties were ordered to file a joint status report on August 25, 2023, and every 60 days afterward.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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