UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
PALO ALTO NETWORKS, INC.,
Case No. 1:22-cv-02306-ER Plaintiff, v.
NOTICE OF MOTION
TAASERA LICENSING LLC and QUEST PATENT RESEARCH CORPORATION, ORAL ARGUMENT REQUESTED Defendants.
PLEASE TAKE NOTICE that, upon the accompanying Memorandum of Law in Support of Defendant Quest Patent Research Corporation’s Motion to Dismiss Palo Alto Networks, Inc.’s (“Palo Alto” or “Plaintiff”) First Amended Complaint (D.I. 21) for Declaratory Judgment of NonInfringement and the exhibits thereto, the Declaration of John C. Scahill, and all prior pleadings and proceedings had herein, Defendant Quest Patent Research Corporation hereby moves this Court, at a time and date determined by the Court, for an order (i) pursuant to 12(b)(1) 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 as against Defendant Quest Patent Research Corporation in its entirety, and (b) a determination that 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. Defendant Quest Patent Research Corporation's motion to dismiss, Doc. 25, is denied without prejudice. Defendant is directed to file a letter requesting a pre-motion conference in connection with its motion to dismiss pursuant to the Court's Individual Practices. It is SO ORDERED.
June 1, 2022
2Dated: New York, New York May 31, 2021
Respectfully submitted, TARTER KRINSKY & DROGIN LLP
By: /s/ Mark J. Rosenberg Mark J. Rosenberg 1350 Broadway, 11th Floor New York, New York 10018 Tel. (212) 216-8000 Fax (212) 216-8001 mrosenberg@tarterkrinsky.com Attorneys for Defendant Quest Patent Research Corporation