ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

Spinelogik, Inc.,

Plaintiff,

v.

Globus Medical, Inc.,

Defendant.

Case No. 2:23-cv-529

 JURY TRIAL DEMANDED

ORIGRINAL COMPLAINT FOR PATENT INFRINGEMENT

Spinelogik, Inc. (“Plaintiff”) hereby files this Original Complaint for Patent Infringement against 

Globus Medical, Inc. (“Globus” or “Defendant”), and alleges, upon information and belief, as follows:

THE PARTIES

1. Spinelogik, Inc. is a corporation organized and existing under the laws of the State of Oregon

with its principal place of business at 1203 Willamette Street, Suite 200, Eugene, Oregon 97401.

2. Upon information and belief, Globus Medical, Inc. is a company organized and existing under 

the laws of the State of Delaware, and as shown below, with a place of business in this District in 

Tyler, Whitehouse, Bullard, McKinney and Plano, Texas. Upon information and belief, 

Defendant can be served with process upon its registered agent, Corporation Service Company 

d/b/a CSC-Lawyers Incorporating Service Company, located at 211 E. 7th Street, Suite 620, 

Austin, TX 78701.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331 and 1338(a).

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4. This Court has personal jurisdiction over Defendant because Defendant conducts business in and 

has committed acts of patent infringement in this District and the State of Texas and has 

established minimum contacts with this forum state such that the exercise of jurisdiction over 

Defendant would not offend the traditional notions of fair play and substantial justice.

5. Defendant is subject to this Court’s general and specific jurisdiction pursuant to due process 

and/or the Texas Long Arm Statute due at least to Defendant’s substantial business in the State 

of Texas and this District, including through its past and ongoing infringing activities, because 

Defendant regularly does and solicits business herein, and/or because Defendant has engaged in 

persistent conduct and/or has derived substantial revenues from goods and services provided in 

the State of Texas and this District.

6. Defendant transacts substantial business with entities and individuals in the State of Texas and 

this District, by among other things, willfully using the infringing methods and systems 

throughout the State of Texas and this District. Defendant relies on the infringing methods and 

systems to introduce and sell millions of products into the stream of commerce with the 

knowledge and expectation that they will be sold in the State of Texas and this District. 

7. Defendant maintains regular, physical, continuous, and established places of businesses, 

including places of business for team leaders of sales, sales operation managers and system 

network architects, in this District, which Defendant has established, ratified, and controlled; 

have employed people to conduct their business from this District; and from which they have

willfully infringed the Asserted Patents in order to benefit themselves in this District. Defendant

commits acts of infringement in this District, including as explained further below by making 

and using the infringing systems in, and performing at least one step of the accused methods of 

the Asserted Patents, at their regular and established places of business in this District.

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 3

8. Upon information and belief, Defendant has authorized sales/customer service agents in the 

Eastern District of Texas, including Kent Miller in Whitehouse, TX, as shown below 

(collectively “Customer Agents”). Defendant has a regular and established place of business in 

this District through the Customer Agents acting as agents. Defendant manifests assent to the 

Customer Agents that they shall act on Defendant’s behalf and subject to its control, and the 

Customer Agents manifest assent or otherwise consent to act. Defendant maintains “interim 

control” over the Customer Agents’ work, in which they rely on interactions and Defendant’s 

instructions within the scope of their work.

See https://www.linkedin.com/in/kent-miller-a4a61536/ (screenshot of Kent Miller’s LinkedIn

page, as “Associate Spine Specialist” of Defendant in Whitehouse, TX).

9. Upon information and belief, the contracts between Defendant and the Customer Agents 

establish (1) Defendant has the right to direct and control the Customer Agents, (2) Defendant 

has manifested consent that Customer Agents act on its behalf, and (3) the Customer Agents 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 4

have consented to act on behalf of Defendant. The Customer Agents sell, monitor, train, oversee 

use, and handle complaints and returns, instruments and implants obtained from and on behalf of 

Defendant for customers in this District. Those activities involve storage, transport, training, 

monitor and exchange of goods and services and are part of Defendant’s business.

10. Upon information and belief, Defendant has established and ratified the Customer Agents’ places 

of business because the contracts affect how they perform hospital set ups, approval of 

procedures to be performed at hospitals with Defendant products, sales, training, handling 

complaints, returns. Defendant also provides the Customer Agents with all information required 

to properly get products approved at hospitals. 

11. The Customer Agents in this district have fixed geographical locations. They are “regular” and 

“established” because they operate in a “steady, uniform, orderly, and methodical manner” and 

are sufficiently permanent. These locations are “of the defendant” because Defendant has 

contractual rights with them—authorized distributors in the United States.

12. Defendant ratifies the Customer Agents’ locations because it exercises interim control over the 

Customer Agents’ activities and holds out to the public that Defendant’s distribution, 

warehousing, marketing and sales of the products are being performed at and by Customer 

Agents’ locations in this District.

13. Defendant also has regular, physical presences of Defendant employees in this District 

conducting Defendant’s business. Defendant maintains a regular and established place of 

business at the Defendant defined places and separate areas at the Customer Agents’ locations by 

the regular, physical presence of its employees.

14. As shown below, Defendant has employees in the Eastern District of Texas:

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 5

See https://www.linkedin.com/in/brendan-miller-21b57b73/ (screenshot of Brendan Miller’s 

LinkedIn page, as “Spine Territory Manager” of Defendant in Bullard, TX).

See https://www.linkedin.com/in/nick-norton-70a68722b/ (screenshot of Nick Norton’s LinkedIn 

page, as “Associate Spine Specialist” of Defendant in Tyler, TX).

See https://www.linkedin.com/in/colt-david-b03a7277/ (screenshot of Colt David’s LinkedIn 

page, as “Surgical Sales” of Defendant in McKinney, TX).

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 6

See https://www.linkedin.com/in/colby-dalrymple-2a188592/ (screenshot of Colby Dalrymple’s 

LinkedIn page, as “Associate Spine Specialist” of Defendant in Plano, TX).

15. As shown above, these employees are located in this District in Tyler, Whitehouse, Bullard, 

McKinney and Plano, Texas. Their locations within the Eastern District of Texas are important 

to the business performed and defendant had intention to maintain some place of business in the 

Eastern District of Texas in the event any employees decided to terminate their residences as a 

place there.

16. Defendant’s employees also not merely possess inventory. Their use in the Eastern District of 

Texas part of Defendant’s services to its Eastern District of Texas customers, a job that falls on 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 7

these employees. When sample products or inventory arrive at these employees’ places of 

businesses, they then visit local customers to deliver or show the samples.

17. Defendant has further solicited salespeople in public advertisements to cover the challenged 

venue area and preferred that those employees live in their assigned sales area. Their locations

within the Eastern District of Texas are important to the business performed and defendant had

intention to maintain some place of business in the Eastern District of Texas in the event any

employees decided to terminate their residences as a place there.

18. Defendant has regular, physical presences of Defendant employees in this District conducting 

Defendant’s business. Defendant maintains a regular and established place of business at the 

Defendant defined places and separate areas by the regular, physical presence of its employees.

19. Venue is proper in this District as to Defendant pursuant to at least 28 U.S.C. §§ 1391(c)(2) and 

1400(b). As noted above, Defendant maintains a regular and established business presence in 

this District. See In re Monolithic Power Sys., Inc., 50 F.4th 157, 160 (Fed. Cir. 2022); see also 

AGIS Software Dev. LLC v. Google LLC, No. 2:19-CV-00361-JRG, 2022 WL 1511757, at *9

(E.D. Tex. May 12, 2022); IOT INNOVATIONS LLC, Plaintiff, v. MONITRONICS 

INTERNATIONAL, INC., d/b/a BRINKS HOME, Defendant., No. 2:22-CV-0432-JRG-RSP, 2023 

WL 6318049, at *5 (E.D. Tex. Sept. 11, 2023), report and recommendation adopted sub nom.

Iot Innovations LLC v. Monitronics Int'l, Inc., No. 222CV00432JRGRSP, 2023 WL 6300560 

(E.D. Tex. Sept. 27, 2023).

20. Furthermore, venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1391(b), 1391(c) 

and 1400(b) because, among other things, Defendant is subject to personal jurisdiction in this 

Judicial District, regularly conducted business in this Judicial District, certain of the acts 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 8

complained of herein occurred in this Judicial District, and they are not residents in the United 

States and may be sued in any judicial district.

BACKGROUND AND PATENTS-IN-SUIT 

21. Plaintiff is the sole and exclusive owner, by assignment, of U.S. Patent Nos. 8,460,385 (“the 

’385 Patent”) and 9,730,805 (“the ’805 Patent” and collectively the “Asserted Patents”) relating 

to spinal implants and surgical procedures for spinal fusion and stabilization.

22. By operation of law, the Asserted Patents originally issued and exclusively vested to the named 

inventor, Dr. Jeffrey Paris Wensel, as of the issue date of the ’385 Patent. See 35 U.S.C. § 261; 

Schwendimann v. Arkwright Advanced Coating, Inc., 959 F.3d 1065, 1072 (Fed. Cir. 2020); 

Suppes v. Katti, 710 Fed. Appx. 883, 887 (Fed. Cir. 2017); Taylor v. Taylor Made Plastics, Inc., 

565 Fed. Appx. 888, 889 (Fed. Cir. 2014). The inventors, in a written instrument, and filed with 

the United States Patent and Trademark Office, assigned all rights, title, and interest in the 

Asserted Patents to Spinelogik, Inc. 

23. The Asserted Patents valid, enforceable, and was duly issued in full compliance with Title 35 of 

the United States Code.

24. The inventions described and claimed in the Asserted Patents were invented individually and 

independently by Dr. Jeffrey Paris Wensel.

25. The Asserted Patents includes numerous claims defining distinct inventions. As represented in 

Figs. 1A, 16 and 26A of the Asserted Patents below, the inventions generally relate to spinal 

implants and surgical procedures for spinal fusion and stabilization.

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26. The priority date of the ’385 Patent is at least as early as May 1, 2008. As of the priority date, 

the inventions as claimed were novel, non-obvious, unconventional, and non-routine. 

27. The priority date of the ’805 Patent is at least as early as March 17, 2008. As of the priority date, 

the inventions as claimed were novel, non-obvious, unconventional, and non-routine. 

28. Back and neck pain are the leading causes of disability and lost productivity for American 

workers under the age of 45. Degenerative disc disease and its sequelae, whereby the 

fibrocartilaginous disc between adjacent vertebral bodies loses height, hydration and structural 

integrity, is one of the most common causes of back and neck pain and may develop secondary 

to traumatic injuries, inflammatory processes or various degenerative disorders. When 

conservative treatment fails, surgical fusion of the vertebral segments across the abnormal disc 

may be the only currently available procedure for pain relief. An increasing number of these 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 11

spinal fusions are performed each year. It is estimated that over half a million of these 

procedures were performed in the United States last year alone.

29. Before the inventions of the Asserted Patents, approaches often failed due to inadequate 

structural integrity. Subsequently, cortical bone dowels and femoral ring allografts were 

employed in an attempt to restore disc space height and augment structural integrity. Other prior 

art devices incorporated or were coated with human bone morphogenetic protein or other agents 

to promote new bone formation and accelerate fusion. Despite these advancements, failure rates 

for spinal fusion surgeries remain unacceptably high, greater than 10 percent in most series.

30. Therefore, there is a need in the art for an improved method to effect a more rapid, reliable 

fusion between unstable vertebral segments and avoid the considerable medical and economic 

impact of failed spinal fusions.

31. The inventor of the Asserted Patents conceived new an apparatus that (1) delivers a fusion 

member between two vertebral bodies after at least a portion of the fibrocartilaginous disc 

between the vertebral bodies has been removed, and (2) affixes the fusion member to the 

vertebral bodies. In some embodiments, the apparatus includes (1) a fusion member that is 

delivered and positioned between the vertebral bodies, (2) a delivery mechanism that delivers 

and positions the fusion member between the vertebral bodies, and (3) an anchoring member that 

affixes the fusion member to the vertebral bodies.

32. The Asserted Patents are pioneering and have been, respectively, cited as relevant prior art in 52 

and 54 subsequent United States Patent Applications, including Applications Assigned to 

Defendant and such technology leaders and academia as Genesys Spine, Alphatec Spine, Inc.,

DePuy Synthes Products, Pinnacle Spine Group and In Queue Innovations.

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33. The claims of the Asserted Patents were all properly issued and are valid and enforceable for the 

respective terms of their statutory life through expiration and are enforceable for purposes of 

seeking damages for past infringement even post-expiration. See, e.g., Genetics Institute, LLC v. 

Novartis Vaccines and Diagnostics, Inc., 655 F.3d 1291, 1299 (Fed. Cir. 2011) (“[A]n expired 

patent is not viewed as having ‘never existed.’ Much to the contrary, a patent does have value 

beyond its expiration date. For example, an expired patent may form the basis of an action for 

past damages subject to the six-year limitation under 35 U.S.C. § 286”) (internal citations 

omitted).

DEFENDANT’S INFRINGING PRODUCTS 

34. Upon information and belief, Defendant makes, sells, advertises, offers for sale, uses, or 

otherwise provides endoscopic targeting methods and systems, including, but not limited to, the 

COALITION MIS spacer, the CORBEL spacer, the HEDRON IA ALIF spacer, and the 

INDEPENDENCE MIS spacer (“Accused Instrumentalities”), that utilize the Asserted Patents’ 

patented spinal implants methods and systems. On information and belief, these spinal implants

systems and methods include, and as shown exemplary in the HEDRON IA ALIF spacer (see 

https://www.globusmedical.com/products/hedron-ia/):

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 14

• a fusion member configured to position between first and second vertebral bodies, the fusion 

member comprising a first curved channel and a second curved channel;

• a first anchoring member configured to insert through the first curved channel and partially

into the first vertebral body while a portion of the first anchoring member remains within the 

fusion member, in order to couple the fusion member with the first vertebral body;

• a second anchoring member configured to insert through the second curved channel and 

partially into the second vertebral body while a portion of the second anchoring member 

remains within the fusion member, in order to couple the fusion member with the second 

vertebral body; and

• wherein the first curved channel has a first cross-sectional plane along a first path that is 

traversed by the first curved channel through the fusion member and the second curved 

channel has a second cross-sectional plane along a second path that is traversed by the 

second curved channel through the fusion member, wherein the first and second crosssectional planes are parallel to each other, as invented in the Asserted Patents.

• a delivery mechanism for delivering the fusion member between the two vertebral bodies, the 

delivery mechanism extending outside a patient's body to a medical practitioner while the 

delivery mechanism is coupled to the fusion member and the fusion member is positioned 

between the two vertebral bodies, the delivery mechanism having a second plurality of 

channels, wherein each channel of the first plurality of channels is configured to be aligned 

with a different channel of the second plurality of channels when the delivery mechanism 

delivers the fusion member between the two vertebral bodies.

35. As shown above, Defendant’s products include each and every limitation of at least, but not 

limited to, claim 1 of the Asserted Patents and therefore literally infringe these claims. Plaintiff

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 15

reserves the right to assert additional claims and to assert infringement under the doctrine of 

equivalents in light of information learned during discovery or in view of this Court’s claim 

construction order.

COUNT I

Infringement of U.S. Patent No. 8,460,385

36. Plaintiff incorporates the above paragraphs by reference.

37. Defendant without authority, made, used, sold, offered to sell, and/or imported into the United 

States its Accused Instrumentalities as shown above.

38. Defendant thus has infringed at least claim 1 of the ’385 Patent literally and/or under the 

doctrine of equivalents.

39. Defendant has also actively induced the infringement of at least one of claim 1 of the ’385

Patent, in violation of 35 U.S.C. § 271(b), by, among other things, actively and knowingly aiding 

and abetting infringement of others through activities such as creating and/or distributing videos 

of use such as the videos above, brochures, manuals, instructional documents, and/or similar 

materials with instructions on creating, manufacturing, designing, assembling and/or 

implementing infringing products, with the specific intent to induce others to directly make, use, 

offer for sale, sell, and/or import into the United States products that fall within the scope of the 

’385 Patent, without license or authority from Plaintiff. On information and belief, Defendant

knows that the induced acts constitute infringement of the ’385 Patent.

40. Defendant individually, collectively, or through others or intermediaries, has contributorily 

infringed in violation of 35 U.S.C. § 271(c), at least one claim of the ’385 Patent by making, 

using, offering for sale, selling, and/or importing, material parts of the inventions claimed in the 

’385 Patent, which are not a staple article or commodity of commerce suitable for substantial 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 16

non-infringing use, and knowing the accused parts to be especially made or especially adapted 

for use in an infringement of the ’385 claims.

41. Defendant has been on actual notice of the ’385 Patent at least as early as September 2011, as it 

was cited it in Defendant’s own patent file histories, as shown below. Defendant’s direct and 

indirect infringement of the ’385 Patent has thus been committed with knowledge of the ’385

Patent, making Defendant liable for direct, indirect, and willful infringement.

See https://patents.google.com/patent/US9730805B1/en?oq=9%2c730%2c805#citedBy

(screenshot of Google Patent list of “Cited By” patents and applications for the ’805 Patent).

42. Plaintiff has been damaged because of the infringing conduct by Defendant alleged above. Thus, 

Defendant is liable to Plaintiff in an amount that adequately compensates it for such 

infringement, which, by law, cannot be less than a reasonable royalty, together with interest and 

costs as fixed by this Court under 35 U.S.C. § 284.

43. Plaintiff and/or its predecessors-in-interest have satisfied all statutory obligations required to 

collect pre-filing damages for the full period allowed by law.

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 17

COUNT 2

Infringement of U.S. Patent No. 9,730,805

44. Plaintiff incorporates the above paragraphs by reference.

45. Defendant without authority, made, used, sold, offered to sell, and/or imported into the United 

States its Accused Instrumentalities as shown above.

46. Defendant thus has infringed at least claim 1 of the ’385 Patent literally and/or under the doctrine 

of equivalents.

47. Defendant has also actively induced the infringement of at least one of claim 1 of the ’805

Patent, in violation of 35 U.S.C. § 271(b), by, among other things, actively and knowingly aiding 

and abetting infringement of others through activities such as creating and/or distributing videos 

of use such as the videos above, brochures, manuals, instructional documents, and/or similar 

materials with instructions on creating, manufacturing, designing, assembling and/or 

implementing infringing products, with the specific intent to induce others to directly make, use, 

offer for sale, sell, and/or import into the United States products that fall within the scope of the 

’805 Patent, without license or authority from Plaintiff. On information and belief, Defendant

knows that the induced acts constitute infringement of the ’805 Patent.

48. Defendant individually, collectively, or through others or intermediaries, has contributorily 

infringed, and/or is contributorily infringing, in violation of 35 U.S.C. § 271(c), at least one 

claim of the ’805 Patent by making, using, offering for sale, selling, and/or importing, material 

parts of the inventions claimed in the ’805 Patent, which are not a staple article or commodity of 

commerce suitable for substantial non-infringing use, and knowing the accused parts to be 

especially made or especially adapted for use in an infringement of the ’805 claims.

49. Defendant has been on actual notice of the ’805 Patent at least as early as September 2011, as it 

was cited it in Defendant’s own patent file histories, as shown below. Defendant’s direct and 

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indirect infringement of the ’805 Patent has thus been committed with knowledge of the ’805

Patent, making Defendant liable for direct, indirect, and willful infringement.

See https://patents.google.com/patent/US9730805B1/en?oq=9%2c730%2c805#citedBy

(screenshot of Google Patent list of “Cited By” patents and applications for the ’805 Patent).

50. Plaintiff has been damaged because of the infringing conduct by Defendant alleged above. Thus, 

Defendant is liable to Plaintiff in an amount that adequately compensates it for such 

infringement, which, by law, cannot be less than a reasonable royalty, together with interest and 

costs as fixed by this Court under 35 U.S.C. § 284.

51. Plaintiff and/or its predecessors-in-interest have satisfied all statutory obligations required to 

collect pre-filing damages for the full period allowed by law.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests the Court enter judgment against Defendant as 

follows:

1. Declaring that Defendant has infringed the Asserted Patents;

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2. Awarding Plaintiff its damages suffered because of Defendant’s infringement of the 

Asserted Patents;

3. Awarding Plaintiff its costs, reasonable attorneys’ fees, expenses, and interest; 

4. An award to Plaintiff of enhanced damages, up to and including trebling of Plaintiff’s 

damages pursuant to 35 U.S.C. § 284 for Defendant’s willful infringement of the 

Asserted Patents; and

5. Granting Plaintiff such further relief as the Court finds appropriate.

JURY DEMAND

Plaintiff demands trial by jury, under Fed. R. Civ. P. 38.

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Respectfully Submitted

/s/ Christopher A. Honea

M. Scott Fuller

 Texas Bar No. 24036607

 sfuller@ghiplaw.com

Randall Garteiser 

 Texas Bar No. 24038912

 rgarteiser@ghiplaw.com

Christopher A. Honea

 Texas Bar No. 24059967

 chonea@ghiplaw.com

GARTEISER HONEA, PLLC

119 W. Ferguson Street

Tyler, Texas 75702

Telephone: (903) 705-7420

Hao Ni

Texas Bar No. 24047205

hni@nilawfirm.com

Neal Massand

Texas Bar No. 24039038

nmassand@nilawfirm.com

NI, WANG & MASSAND, PLLC

8140 Walnut Hill Ln., Ste. 615

Dallas, TX 75231

Tel: (972) 331-4600

Fax: (972) 314-0900

ATTORNEYS FOR PLAINTIFF

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