Carbon Autonomous Robotic Systems Inc. v. Laudando & Associates LLC

Summary

The United States District Court for the Eastern District of California grants Carbon Autonomous Robotic Systems Inc.’s motion for a preliminary injunction against Laudando & Associates LLC in a patent infringement action. The court concludes that plaintiff is likely to prove infringement of claim 1 of U.S. Patent No. 12,240,372 by the defendant’s L&Aser Module configured with AgCeption software. The order also addresses defense counsel’s renewed motion to withdraw.

Holdings

1. Plaintiff demonstrated that it will likely prove that the accused product practices every element of claim 1 of the '372 patent and therefore will likely prove infringement.
2. Plaintiff showed that defendant was unlikely to establish by clear and convincing evidence at trial that claim 1 of the '372 patent was anticipated by the Nadimi paper.
3. Claim 1 of the '372 patent was not shown to be directed to an abstract idea and was therefore likely patent-eligible on the record before the court.
4. Plaintiff satisfied the requirements for a preliminary injunction because it showed likely success on the merits, likely irreparable harm, a balance of equities favoring relief, and a public interest at least slightly favoring enforcement of valid patent rights.
5. Defense counsel demonstrated good cause to withdraw because the corporate defendant materially breached its fee agreement, consented to withdrawal, and was warned of the consequences of proceeding without counsel.

Questions Presented

1. Whether plaintiff demonstrated a likelihood of success in proving that the accused product infringes claim 1 of U.S. Patent No. 12,240,372.
2. Whether defendant raised a substantial question that claim 1 of the '372 patent is invalid for anticipation under 35 U.S.C. § 102.
3. Whether claim 1 of the '372 patent is directed to patent-ineligible subject matter under 35 U.S.C. § 101.
4. Whether plaintiff established likely irreparable harm, a favorable balance of equities, and a public interest supporting a preliminary injunction.
5. Whether defense counsel demonstrated good cause to withdraw from representing the corporate defendant.

Disposition

other