Alfred R. Fabricant FABRICANT LLP
411 Theodore Fremd Avenue, Defendant Taasera Licensing LLC's motion to dismiss, Suite 206 South Doc. 32, is denied without prejudice. Defendant is Rye, New York 10580
directed to file a letter requesting a pre-motion
Tel. (212) 257-5797
conference in connection with its motion to dismiss Fax (212) 257-5796
pursuant to the Court's Individual Practices. It is SO ffabricant@fabricantllp.com
ORDERED.
Attorneys for Defendant Taasera Licensing LLC
June 1, 2022
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
PALO ALTO NETWORKS, INC., Case No. 1:22-cv-02306-ER/SDA
Plaintiff, NOTICE OF MOTION v. ORAL ARGUMENT REQUESTED TAASERA LICENSING LLC and QUEST PATENT RESEARCH CORPORATION,
Defendants.
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, and2 (ii) granting such other and further relief as the Court deems just and proper. Dated: Rye, New York
May 31, 2021 Respectfully submitted,
FABRICANT LLP
By: /s/ Alfred R. Fabricant Alfred R. Fabricant Attorneys for Defendant Taasera Licensing LLC
TO: Counsel for Defendant (by ECF)