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PHX 332720192v5 PH 134582

SPENCER FANE LLP 

Andrew M. Federhar (No. 006567)

Jessica A. Gale (No. 030583)

2425 East Camelback Road, Suite 850

Phoenix, AZ 85016-4251

Telephone: (602) 333-5427

Facsimile: (602) 333-5431

E-mail: afederhar@spencerfane.com

E-mail: jgale@spencerfane.com

Maximilian A. Grant (admitted pro hac vice)

David A. Zucker (admitted pro hac vice)

LATHAM & WATKINS LLP

555 Eleventh Street, N.W., Ste. 1000

Washington, D.C. 20004

max.grant@lw.com

david.zucker@lw.com

Attorneys for Plaintiff/Counterdefendant 

SiteLock, LLC

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

SiteLock, LLC, an Arizona limited 

liability company

Plaintiff,

v.

Comodo CA Limited, a United 

Kingdom corporation, 

Defendants.

Case No.: CV-17-04080-PHX-JJT

JOINT PROPOSED RULE 26(f) 

CASE MANAGEMENT REPORT

Comodo CA Limited, a United 

Kingdom corporation, 

Counterclaimant, 

v. 

SiteLock, LLC, an Arizona limited 

liability company

Counterdefendant.

Case 2:17-cv-04080-JJT Document 60 Filed 05/22/18 Page 1 of 15
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Plaintiff/Counterdefendant SiteLock, LLC (“Plaintiff”) and 

Defendant/Counterclaimant Comodo CA Limited (“Defendant”), pursuant to this Court’s 

Order dated April 9, 2018, respectfully submit their Joint Proposed Case Management 

Report as follows:

1. The nature of the case, setting forth in brief statements (no more than 

one page per side) the factual and legal basis of Plaintiff’s claims and Defendant’s 

defenses.

Plaintiff: SiteLock, LLC (“SiteLock”) is a provider of website security solutions, 

including cloud-based website protection that monitors and fixed threats, prevents future 

attacks, and accelerates website performance. SiteLock competes in that space with a 

collection of entities known as Comodo, including, among others, Comodo CA Limited.

In October 2017, following a business offer that SiteLock rejected, Comodo sent 

SiteLock an ultimatum, giving SiteLock 48 hours to either accept the offer or take an 

extortionate license to U.S. Patent No. 7,603,699 (the “’699 patent”). Comodo made clear 

that if SiteLock did neither, Comodo would sue for infringement of the ’699 patent. At 

the time, SiteLock was communicating primarily with Comodo Security Solutions, Inc., a 

New Jersey Corporation. According to public records at the time, the ’699 patent was held 

by Comodo Holdings, Limited, a British Virgin Islands corporation. Later-revealed 

public records show that since at least September 2017, prior to all of the above events, 

the ’699 patent was owned by Comodo CA Limited (“Comodo CA”). 

Faced with this threat, SiteLock filed this action seeking a declaratory judgment 

that it does not infringe any claim of the ’699 patent, and that the ’699 patent is invalid. 

under 35 U.S.C. § 101 for failing to claim eligible subject matter. SiteLock has also 

raised claims for interference with existing and prospective business relationships, 

unlawful business practices, and in response to Comodo CA’s counterclaim of 

infringement, various affirmative defenses limiting Comodo CA’s rights to assert the ’699 

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patent.

Defendant: Comodo CA is the owner of the patent in suit, the ‘699 patent, which 

was duly issued on October 13, 2009 by the United States Patent and Trademark Office 

(“USPTO”). Comodo CA denies that the ‘699 patent is invalid under 35 U.S.C. for failing 

to claim patent-eligible subject matter. 

By its Counterclaim, Comodo CA asserts that SiteLock infringes, directly and/or 

indirectly, the ‘699 patent. Comodo CA seeks, among other things, permanent injunctive 

relief, monetary damages, and recovery of Comodo CA’s costs and reasonable attorneys’ 

fees incurred in connection with this action.

2. A list of the elements of proof necessary for each count of the 

Complaint and each affirmative defense. Where the burden of proof shifts, each 

party shall list the elements of proof that party must satisfy to prevail. The list of 

elements of proof must contain citations to relevant legal authority, (i.e., United 

States statutory or administrative law, United States Supreme Court case law, Ninth 

Circuit Court of Appeals case law, Arizona case law or statutory law, or other 

authority as required by choice of law rules).

Alleged Patent ineligibility under 35 U.S.C. § 101

A patent falls outside the scope of 35 U.S.C. § 101, and is therefore invalid, where 

“(1) it is directed to a patent ineligible concept, i.e., a law of nature, natural phenomenon, 

or abstract idea, and (2), if so, the particular elements of the claim, considered both 

individually and as an ordered combination, to not add enough to transform the nature of 

the claim into a patent-eligible invention.” Elec. Power Grp., LLC, v. Alston S.A., 830 

F.2d 1350, 1353 (Fed. Cir. 2016). 

“A patent shall be presumed to be valid . . . The burden of establishing invalidity 

of a patent or any claim thereof shall rest on the party asserting such invalidity.” 35 U.S.C. 

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§ 282(a). Therefore, a party challenging the validity of a patent claim must show 

invalidity (including invalidity under 35 U.S.C. § 101) by clear and convincing evidence. 

Microsoft Corp. v. i4i Ltd. P’ship, 564 U.S. 91, 95 (2011); Berkheimer v. HP Inc., 881 

F.3d 1360, 1369 (Fed. Cir. 2018). 

Alleged Non-infringement 

Infringement may only be shown where the accused product meets each and every 

limitation of the asserted patent claim(s), either literally or under the Doctrine of 

Equivalents. The failure to “meet a single limitation is sufficient to negate infringement 

of the claim.” Laitram Corp. v. Rexnord, Inc., 939 F.2d 1533, 1535 (Fed. Cir. 1991).

The fact that SiteLock has raised non-infringement as a declaratory judgment claim 

does not change the fact that Comodo bears the “the burden of proving infringement” as 

the patentee. Medtronic, Inc. v. Mirowski Family Ventures, LLC, 134 S. Ct. 843, 849 

(2014).

Alleged Interference with Existing and Prospective Business Relationships

A claim for interference with existing and prospective business relationships exists 

when a plaintiff shows “the existence of a valid contractual relationship or business 

expectancy; intentional interference inducing or causing a breach or termination of the 

relationship or expectancy; and resultant damage to the party whose relationship or 

expectancy has been damaged.” Dube v. Likins, 216 Ariz. 406, 167 P.3d 93 (Ct. App. 

2007).

Alleged Unlawful practices under A.R.S. §§ 44-1522

A claim for unlawful practices under A.R.S. §§ 44-1522 exists where the plaintiff 

shows that the defendant 1) used or employed any deception, deceptive or unfair act or 

practice, fraud, false pretense, false promise, misrepresentation, or concealment, 

suppression, or omission of any material fact with the intent that others rely on such 

concealment, suppression, or omission, 2) in connection with the sale or advertisement of 

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any merchandise. A.R.S. §§ 44-1522(A). “Merchandise” can include any intangibles, 

services, objects, wares, goods, commodities, or real estate. A.R.S. §§ 44-1521(5). This 

claim does not require that any person “has in fact been misled, deceived, or damaged” by 

the deceptive or unfair act. A.R.S. §§ 44-1522(A).

Alleged Invalidity under 35 U.S.C. §§ 102, 103, and 112: 

A party challenging the validity of a patent claim must show invalidity by clear and 

convincing evidence. Microsoft Corp. v. i4i Ltd. P’ship, 564 U.S. 91, 95 (2011). A “claim 

is anticipated [under § 102] if each and every limitation is found either expressly or 

inherently in a single prior art reference.” Nidec Motor Corp. v. Zhongshan Broad Ocean 

Motor Co. Ltd., 851 F.3d 1270, 1273 (Fed. Cir. 2017). A claim is obvious under § 103 

where, “though the invention is not identically disclosed or described as set forth in 

section 102, if the differences between the subject matter sought to be patented and the 

prior art are such that the subject matter as a whole would have been obvious at the time 

the invention was made to a person having ordinary skill in the art to which said subject 

matter pertains.” 35 U.S.C. § 103. Similarly, invalidity under §112 must be proven by 

clear and convincing evidence. i4i, 564 U.S. at 95.

Alleged Lack of Basis for Injunctive Relief

Although pled as an affirmative defense, the burden of proof for injunctive relief 

remains on the patentee. In order to receive any injunctive relief, a patentee must show 

“(1) that it has suffered an irreparable injury; (2) that remedies available at law, such as 

monetary damages, are inadequate to compensate for that injury; (3) that, considering the 

balance of hardships between the plaintiff and defendant, a remedy in equity is warranted, 

and (4) that the public interest would not be disserved by a permanent injunction.” eBay, 

Inc. v. Mercexchange, 547 U.S. 388 (2006).

Alleged Limitation on Damages

Comodo CA carries the burden of proving damages. A patentee may not make any 

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recovery for infringement committed more than six years prior to the filing of the 

counterclaim for infringement. 35 U.S.C. § 286. Similarly, a patentee may not recover 

damages if it is shown that he failed to give notice to the public in the manner required by 

35 U.S.C. § 287, unless the accused infringer was notified of its alleged infringement and 

continued to infringe afterward, in which case damages may be recovered only for 

infringement occurring after that notification. 35 U.S.C. § 287.

Alleged Failure to State a Claim

A cause of action should be dismissed for failure to state a claim upon which relief 

can be granted where the pleading fails to state anything more than “labels and 

conclusions” or a “formulaic recitation of the elements of a cause of action.” Bell Atl. 

Corp. v. Twombly, 550 U.S. 544, 555 (2007). “To survive a motion to dismiss, a 

complaint must contain sufficient factual matter, accepted as true, to state a claim to relief 

that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

Alleged Laches, Unclean Hands, Estoppel, and/or Waiver

A patentee is equitably estopped from a claim of patent infringement where “(1) 

the patentee, through misleading conduct, led the alleged infringer to reasonably believe 

that the patentee did not intend to enforce its patent against the infringer; (2) the alleged 

infringer relied on that conduct, and (3) due to its reliance, the alleged infringer would be 

materially prejudiced if the patentee were permitted to proceed with its charge of 

infringement.” Aspex Eyewear Inc. v. Clariti Eyewear, Inc., 605 F.3d 1305, 1320 (Fed. 

Cir. 2010). 

Similarly, a patentee may be precluded from relief under the doctrine of unclean 

hands when that party’s “misconduct” has “affect[ed] the equitable relations between the 

parties in respect of something brought before the court.” Keystone Driller Co. v. General 

Excavator Co., 290 U.S. 240, 245 (1933). A patentee may also be precluded by waiver, 

“the express, voluntary, intentional relinquishment of a known right or such conduct as 

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warrants an inference of such an intentional relinquishment. Waiver by conduct must be 

established by evidence of acts inconsistent with an intent to assert the right.” Am. Cont’l 

Life Ins. Co. v. Ranier Const. Co., Inc., 125 Ariz. 53, 55 (1980) (citations omitted).

Alleged Patent Infringement

For direct infringement, the patent owner bears the burden of proof by a 

preponderance of the evidence to show the presence in the accused product of each and 

every element or its equivalent of each asserted claim for each asserted patent. Uniloc 

USA, Inc. v. Microsoft Corp., 632 F.3d 1292, 1301 (Fed. Cir. 2011).

For inducement, “the patentee must [ ]show that the accused inducer took an 

affirmative act to encourage infringement with the knowledge that the induced acts 

constitute patent infringement.” Power Integrations, Inc. v. Fairchild Semiconductor Int'l, 

Inc., 843 F.3d 1315, 1332 (Fed. Cir. 2016) (citing Astornet Techs. Inc. v. BAE Sys., Inc., 

802 F.3d 1271, 1279 (Fed. Cir. 2015) (quoting Info–Hold, Inc. v. Muzak LLC, 783 F.3d 

1365, 1372 (Fed. Cir. 2015)). As to the knowledge element, the patentee must show 

that “the alleged infringer knew or was willfully blind to the fact that the induced acts 

constituted patent infringement of at least one patent claim ....” Warsaw Orthopedic, Inc. 

v. NuVasive, Inc., 824 F.3d 1344, 1348 (Fed. Cir. 2016).

3. The factual and legal issues genuinely in dispute (no more than one 

page per side), and whether they can be narrowed by stipulation or motion.

 Whether the ’699 patent is invalid under 35 U.S.C. § 101.

 Whether the ’699 patent is invalid under 35 U.S.C. §§ 102, 103, or 112.

 Whether the ‘699 patent is “merchandise” under A.R.S. § 44-1521(5).

 Whether SiteLock’s accused products infringe the ’699 patent directly.

 Whether SiteLock induced third parties’ infringement of the ’699 patent.

 If SiteLock is found to infringe a claim of the ’699 patent, and that patent is not 

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invalid, the amount of damages to which Comodo CA is entitled, if any.

 If SiteLock is found to infringe a claim of the ‘699 patent, and that patent is not 

invalid, whether SiteLock’s infringement was/is willful and whether the amount of 

damages to which Comodo CA is entitled, if any, should be trebled.

 Whether SiteLock’s recovery is limited or barred by statute, or by the doctrines of 

laches, estoppel, unclean hands, or waiver. 

 Whether Comodo CA’s recovery is limited or barred by statute, or by the doctrines of 

estoppel, unclean hands, or waiver.

 If SiteLock is found to infringe a claim of the ’699 patent, and that patent is not 

invalid, whether Comodo CA is entitled to any injunctive relief.

 Whether and to what amount either party is entitled to its costs and attorneys’ fees at 

the conclusion of this case.

 Whether Comodo CA interfered with the existing or prospective business relationships 

between SiteLock and its actual or potential customers.

 Whether Comodo CA’s material omission of the true ownership of the ’699 patent 

during its business discussions with SiteLock violated A.R.S. §§ 44-1522.

4. The jurisdictional basis of the case, citing specific statutes. If 

jurisdiction is based on diversity of citizenship, a statement of the citizenship of every 

party and a description of the amount in dispute shall be included. See 28 U.S.C. § 

1332. The parties are reminded that (1) a corporation is a citizen of the state where it 

is incorporated and the state of its principal place of business, and (2) partnerships 

and limited liability companies are citizens of every state in which their partners or 

members are citizens. See 28 U.S.C. § 1332(c); Johnson v. Columbia Props. 

Anchorage, LP, 437 F.3d 894, 899 (9th Cir. 2006); Indus. Tectonics, Inc. v. Aero Alloy, 

912 F.2d 1090, 1092 (9th Cir. 1990). The parties are further reminded that the use of 

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fictitious parties (“John Doe” or “ABC Corporation”) “casts no magical spell on a 

complaint otherwise lacking in diversity jurisdiction.” Fifty Assocs. v. Prudential Ins. 

Co. of Am., 446 F.2d 1187, 1191 (9th Cir. 1970);

This action and counterclaims arise under the patent laws of the United States, 35 

U.S.C. §§ 1 et seq., and the Declaratory Judgment Act, 28 U.S.C. § 2201 et seq, so this 

Court has federal question subject matter jurisdiction under 35 U.S.C. §§ 1331 and 1338. 

The Court has personal jurisdiction over SiteLock as a citizen of Arizona, as SiteLock has 

its principal place of business and place of incorporation in Arizona. The Court has 

personal jurisdiction over Comodo CA because Comodo CA has consented to the 

jurisdiction of this court by filing its answer and counterclaims.

5. Parties, if any, that have not been served, as well as parties that have 

not filed an Answer or otherwise appeared, including fictitious parties. Unless 

counsel can otherwise show cause, they shall submit with the Proposed Case 

Management Plan a proposed Order dismissing any party that has not been served, 

including fictitious parties, and a motion for the entry of default against any nonappearing party if the time for answering or otherwise appearing has expired. If a 

party has been served but not appeared, Plaintiff(s) or Counterclaimant(s) shall 

provide a copy of this Order to that party;

None.

6. The names of parties not subject to the Court’s jurisdiction; 

None.

7. Whether there are dispositive or partially dispositive issues to be 

decided by pretrial motions, and the legal issues about which any pretrial motions 

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are contemplated;

The parties are likely to file motions for summary judgment, or other motions for 

early determination, in this case. The timing and precise focus of such motions are not yet 

known, but may include the alleged validity or invalidity of the ’699 patent and/or 

SiteLock’s alleged infringement or non-infringement of the ’699 patent. The parties may 

also file one or more Daubert motions to exclude, or partially exclude, the testimony of 

opposing party’s experts concerning issues of, for example, infringement, invalidity, 

and/or damages.

8. Whether the case is suitable for reference to a United States Magistrate 

Judge or a special master;

The parties do not believe this case is suitable for reference to a Unites States 

Magistrate Judge or Special Master.

9. The status of related cases pending before other judges of this Court or 

before other courts.

None.

10. A description of the parties’ discussions of the mandatory initial 

discovery responses, including any disputes. See General Order 17-08 at 4 ¶ 9;

SiteLock’s Statement

SiteLock served its mandatory initial discovery responses on May 3, 2018. To date, 

Comodo CA has not served its responses, and has not raised any dispute regarding 

SiteLock’s responses.

Comodo CA’s Statement

Comodo CA intends to serve its mandatory initial discovery responses on or before 

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June 13, 2018, thirty (30) days from the date SiteLock filed its answer to Comodo CA’s 

counterclaim. 

11. Proposed deadlines (month/day/year)1for:

Event Proposed Deadline

File motions to amend the Complaint or to join 

additional parties

June 22, 2018

Comodo CA to provide infringement contentions June 29, 2018

SiteLock to provide invalidity contentions July 27, 2018

Comodo CA proposal:

2

SiteLock to respond to 

infringement contentions

July 27, 2018

Parties to exchange proposed terms for claim 

construction

August 17, 2018

Parties to exchange claim constructions and extrinsic 

evidence

September 7, 2018

Joint claim construction chart and pre-hearing 

statement

September 28, 2018

Claim construction discovery ends October 12, 2018

Filing of opening claim construction briefs by both 

parties

November 9, 2018

Filing of responsive claim construction briefs by both 

parties

November 30, 2018

Filing of reply claim construction briefs by both parties December 14, 2018

 

1

The Court prefers to set deadlines for Fridays.

2

SiteLock does not agree with Comodo CA’s proposed deadline as it is not a deadline that 

is typically included in patent cases.

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Markman hearing To be determined

Completion of all fact discovery May 31, 2019

Disclosure of expert testimony by parties with the 

burden of proof

August 1, 2019

Disclosure of rebuttal expert testimony August 30, 2019

Closure of all discovery October 4, 2019

Completion of good faith settlement discussions No later than November 12019

Filing of dispositive motions, including Daubert

motions

December 5, 2019

12. The scope of discovery, including any suggested changes in the 

limitations on discovery imposed by the Federal Rules of Civil Procedure, and 

whether discovery should be conducted in phases or should be limited to or focused 

upon particular issues. For example, where dispositive motions will be filed (e.g., 

motions for summary judgment on a statute of limitations defense), counsel should 

consider limiting discovery to the issue at hand until the Court has ruled on the 

motion;

The parties intend to propound written discovery, including requests for 

production, interrogatories, and requests for admission, and conduct depositions as 

deemed necessary. 

13. Estimated length of trial, and any suggestions for shortening the trial;

The parties believe that 10 days will be sufficient.

14. Whether a jury trial has been requested and whether the request for a 

jury trial is contested. If the request for a jury trial is contested, the Proposed Case 

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Management Plan shall set forth the reasons that a trial by jury is in dispute;

Both parties have requested a jury trial on all issues so triable.

15. The prospects for settlement, including any request to have a settlement 

conference before another United States District Judge or a Magistrate Judge, or 

any other request of the Court for assistance in settlement efforts;

The parties believe that this case has the potential to settle, and believe that it is 

best suited for mediation before a private mediator.

16. Whether any unusual, difficult, or complex problems or issues exist that 

require this case to be placed on the complex track for case management purposes 

(see LRCiv 16.2).

None.

17. Any other matters that counsel believe will aid the Court in resolving 

this case in a just, speedy, and inexpensive manner. However, the parties may not 

opt out of compliance with the provisions of General Order 17-08.

None.

DATED this 22nd day of May, 2018.

SPENCER FANE LLP

By s/ Andrew M. Federhar 

Andrew M. Federhar

Jessica A. Gale

SPENCER FANE LLP

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PH 134582

2425 E. Camelback Road, Suite 850 

Phoenix AZ 85016-4251

AFederhar@spencerfane.com 

JGale@spencerfane.com

Maximilian A. Grant (admitted pro hac 

vice)

David A. Zucker (admitted pro hac vice)

LATHAM & WATKINS LLP

555 Eleventh Street, N.W., Ste. 1000

Washington, D.C. 20004

max.grant@lw.com

david.zucker@lw.com

Counsel for Plaintiff/Counterdefendant 

SiteLock, LLC

GREENBERG TRAURIG, LLP

By s/ Aaron T. Lloyd

E. Jeffrey Walsh

Aaron T. Lloyd 

Greenberg Traurig, LLP 

2375 E. Camelback Road, Suite 700

Phoenix, AZ 85016

walshj@gtlaw.com

lloyda@gtlaw.com

Attorneys for Defendant/Counterclaimant 

Comodo CA Limited

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PH 134582

CERTIFICATE OF SERVICE

I hereby certify that on this 22nd day of May, 2018, I electronically transmitted the 

attached document to the Clerk’s office using the CM/ECF System for filing and 

transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:

E. Jeffrey Walsh

Aaron T. Lloyd 

Greenberg Traurig, LLP 

2375 E. Camelback Road

Phoenix, AZ 85016

walshj@gtlaw.com

lloyda@gtlaw.com

Attorneys for Defendant Comodo CA Limited 

s/ Terri Hartloff

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