Opinion
1:22-cv-02306-ER/SDA
06-01-2022
PALO ALTO NETWORKS, INC., Plaintiff, v. TAASERA LICENSING LLC and QUEST PATENT RESEARCH CORPORATION, Defendants.
Alfred R. Fabricant FABRICANT LLP Attorneys for Defendant Taasera Licensing LLC.
Alfred R. Fabricant FABRICANT LLP Attorneys for Defendant Taasera Licensing LLC.
NOTICE OF MOTION ORAL ARGUMENT REQUESTED
PLEASE TAKE NOTICE that, upon the accompanying Memorandum of Law in Support of Defendant Taasera Licensing LLC's Motion to Dismiss Palo Alto Networks, Inc.'s (“Palo Alto” or “Plaintiff”) First Amended Complaint (D.I. 21) for Declaratory Judgment of Non-Infringement and all prior pleadings and proceedings had herein, Defendant Taasera Licensing LLC hereby moves this Court, at a time and date determined by the Court, for an order (i) pursuant to 12(b)(2) and 12(b)(6) of the Federal Rules of Civil Procedure (a) granting dismissal of Plaintiff Palo Alto Networks, Inc. First Amended Complaint (D.I. 21) for Declaratory Judgment of Non-Infringement relative to Defendant Taasera Licensing LLC in its entirety, and (b) a determination of no alter ego exists between defendants Taasera Licensing LLC and Quest Patent Research Corporation, and (ii) granting such other and further relief as the Court deems just and proper.