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No. 52 UNOPPOSED MOTION for Leave to File Motion to Dismiss or Transfer Under Rule 12(b)(3) and 28 ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 52 (E.D.Tex. Nov. 18, 2024)
Pursuant to Eastern District of Texas Local Rule 5(a)(7)(C), Defendant Electrify America, LLC (“Electrify America”)1 moves to file under seal (i) its Motion to Dismiss or Transfer Under Rule 12(b)(3) and 28 U.S.C. § 1406(a) (the “Motion”); and (ii) Exhibit 3 to the accompanying Declaration of William H. Milliken submitted in support of that motion.
Accordingly, to preserve the confidentiality of this information, Electrify America respectfully requests that the Motion and Exhibit 3 be filed under seal.
Electrify America has conferred with Plaintiff RFCyber Corp. in advance of filing this sealing motion.
RFCyber has stated that it does not oppose Electrify America’s request to seal the information contained in the Motion and Exhibit 3.
Pursuant to Local Rule CV-5(a)(7)(E), a redacted version of the Motion and Exhibit 3 will be filed within seven days.
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No. 59 MOTION to Dismiss PURSUANT TO RULE 12(B)(6) by Volkswagen Group of America, Inc., Electrify ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 59 (E.D.Tex. Nov. 18, 2024)
The patents, according to RFCyber, “generally cover apparatus and methods for enabling secure contactless payment with a portable device.” This motion is filed on behalf of Defendants VWGoA and Electrify America only.
VWGoA previously moved to dismiss the allegations of pre-suit indirect and willful infringement in RFCyber’s initial complaint.
“To survive dismissal at the pleading stage, a complaint must state enough facts such that the claim to relief is plausible on its face.” Signode Indus.
(dismissing claims for pre-suit willful infringement where there was “a total absence of facts in the Complaint to suggest that Defendant had pre-suit knowledge of the Asserted Patents”) (cleaned up); Arigna Tech. Ltd. v. Bayerische Motoren Werke AG, 2022 WL 610796, at *7 (E.D.
VWGoA and Electrify America respectfully request that the Court dismiss RFCyber’s allegations of pre-suit willful and indirect infringement.
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No. 31 JOINT MOTION for Extension of Time to File Answer to First Amended Complaint and Responsive ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 31 (E.D.Tex. Oct. 28, 2024)
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No. 19 REPLY to Response re 14 MOTION PARTIAL MOTION PURSUANT TO RULE 12(b)(6) TO DISMISS PRE-SUIT ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 19 (E.D.Tex. Oct. 23, 2024)
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No. 14 MOTION PARTIAL MOTION PURSUANT TO RULE 12(b)(6) TO DISMISS PRE-SUIT WILLFUL INFRINGEMENT AND ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 14 (E.D.Tex. Sep. 30, 2024)
LLC v. HTC Corp., 408 F. Supp. 3d 819 (E.D. Tex. 2019) ...................................................................................3, 6 Nonend Inventions, N.V. v. Apple, Inc., No. 15-cv-466-JRG-RSP, 2016 U.S. Dist.
See, e.g., Nonend Inventions, N.V. v. Apple, Inc., No. 15-cv-466-JRG- RSP, 2016 U.S. Dist.
... with Glob.-Tech, this Court has held that “‘willful blindness’ requires that a defendant must (1) subjectively believe that there is a high probability that a fact exists and (2) take deliberate action to avoid learning of that fact.” Nonend ...
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No. 1 COMPLAINT FOR PATENT INFRINGEMENT against Starbucks Corporation ( Filing fee $ 405 receipt ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 1 (E.D.Tex. Jul. 18, 2024)
This Court has specific and personal jurisdiction over Defendant consistent with the requirements of the Due Process Clause of the United States Constitution and the Texas Long Arm Statute.
Further, upon information and belief, Starbucks has admitted or not contested proper venue in this Judicial District in other patent infringement actions.
Starbucks has manufactured, used, marketed, distributed, sold, offered for sale, and exported from, and imported into the United States devices and software that infringe the Patent- in-Suit.
RFCyber has not licensed or otherwise authorized Starbucks to make, use, offer for sale, sell, or import any products that embody the inventions of the ’855 Patent.
For example, upon information and belief, any subsequent operation of the emulator portion of the Starbucks App (e.g., to load funds or conduct transactions with a given card applet) are protected by such fingerprints, keys, and/or certificates.
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No. 89 RESPONSE in Support re 59 MOTION to Dismiss PURSUANT TO RULE 12(B)(6) filed by Electrify America, ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 89 (E.D.Tex. Dec. 23, 2024)
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No. 88

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 88 (E.D.Tex. Dec. 23, 2024)

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No. 86 RESPONSE in Opposition re 59 MOTION to Dismiss PURSUANT TO RULE 12(B)(6) filed by RFCyber ...

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 86 (E.D.Tex. Dec. 16, 2024)
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No. 51

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 51 (E.D.Tex. Nov. 18, 2024)

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No. 50

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 50 (E.D.Tex. Nov. 11, 2024)

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No. 26

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 26 (E.D.Tex. Oct. 28, 2024)

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No. 27

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 27 (E.D.Tex. Oct. 28, 2024)

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No. 30

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 30 (E.D.Tex. Oct. 28, 2024)

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No. 25

Document RFCyber Corp. v. Starbucks Corporation, 2:24-cv-00550, No. 25 (E.D.Tex. Oct. 25, 2024)

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