Redstone Logics LLC v. Qualcomm Inc. — Entry #65: Response in Opposition to Motion, filed by Redstone Logics LLC, re [64] MOTION to Stay filed by Defendant Qualcomm Inc., Defendant Qualcomm Technologies, Inc

Case 7:24-cv-00231-ADA   Document 65    Filed 06/11/26   Page 1 of 13


                    UNITED STATES DISTRICT COURT
                  FOR THE WESTERN DISTRICT OF TEXAS
                       MIDLAND/ODESSA DIVISION


REDSTONE LOGICS LLC

            Plaintiff,                     Case No. 7:24-cv-00231-ADA

    v.
                                           JURY TRIAL DEMANDED
QUALCOMM INC.; QUALCOMM
TECHNOLOGIES, INC.,

            Defendants.


         PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION TO STAY


             Case 7:24-cv-00231-ADA                           Document 65                Filed 06/11/26                Page 2 of 13


                                                              TABLE OF CONTENTS

I.         Introduction ............................................................................................................................. 1
II.        Legal Standard ........................................................................................................................ 1
III. ARGUMENT .......................................................................................................................... 2
      A.      Redstone Will Be Prejudiced By A Stay ............................................................................ 2
      B.      There Is No Simplification To Be Had By A Stay ............................................................. 4
      C.      Two Years Of Litigation Do Not Favor a Stay ................................................................... 6
IV. Conclusion .............................................................................................................................. 7


                                                                            i


         Case 7:24-cv-00231-ADA                     Document 65               Filed 06/11/26            Page 3 of 13


                                             TABLE OF AUTHORITIES

Cases
Apple Inc. v. Redstone Logics LLC,
  IPR2025-01532, Paper 10 (PTAB Jan. 27, 2026)....................................................................... 5

Cybor Corp. v. FAS Techs., Inc.,
  138 F.3d 1448 (Fed. Cir. 1998) .................................................................................................. 3

Eastman Kodak Co. v. Goodyear Tire & Rubber Co.,
  114 F.3d 1547 (Fed. Cir. 1997) .................................................................................................. 3

EchoStar Techs. Corp. v. TiVo, Inc.,
  No. 5:05-CV-81, 2006 WL 2501494 (E.D. Tex. July 14, 2006). ............................................... 1

EON Corp. IP Holdings, LLC v. Sensus USA Inc.,
  No. 6:09-CV-116, 2009 WL 9506927 (E.D. Tex. Dec. 18, 2009) ............................................. 2

E-Watch, Inc. v. Lorex Canada, Inc.,
  No. H-12-3314, 2013 WL 55425298, (S.D. Tex. Sept. 26, 2013)) ............................................ 1

Impinj, Inc. v. NXP USA, Inc.,
  No. 6:21-CV-00530-ADA, 2023 WL 7476358 (W.D. Tex. May 18, 2023) .......................... 4, 7

Kirsch Rsch. & Dev., LLC v. IKO Indus. Inc.,
  No. 6:20-CV-00317- ADA, 2021 WL 455610 (W.D. Tex. Oct. 5, 2021) .................................. 1

Malikie Innovations LTD. et al v. Mara Holdings INC.,
 No. 7:25-cv-00222-DC-DTG (W.D. Tex. June 1, 2026) ............................................................ 1

MediaTek, Inc. et al v Redstone Logics LLC,
 IPR2025-00085, Paper 7 (PTAB Apr. 22, 2025) ........................................................................ 5

MiMedx Grp., Inc. v. Tissue Transplant Tech. Ltd.,
  2015 WL 11573771 (W.D. Tex. Jan. 5, 2015) ........................................................................... 3

NXP USA, Inc. f/k/a NXP Semiconductors USA, Inc. et al. v. Redstone Logics LLC,
  IPR2025-00485, Paper 1 (PTAB Jan. 22, 2025)......................................................................... 2

NXP USA, Inc. f/k/a NXP Semiconductors USA, Inc. et al. v. Redstone Logics LLC,
  IPR2025-00485, Paper 11 (PTAB Jul. 10, 2025) ....................................................................... 2

Realtime Data, LLC v. Rackspace US, Inc.,
  No. 6:16-CV-00961-RWS-JDl, 2017 WL 772654 (E.D. Tex. Feb. 27, 2017) ........................... 1

Redstone Logics LLC v. Advanced Micro Devices, Inc.,
  No. 7:25-cv-00182, Dkt 40 (W.D. Tex. May 8, 2026) ............................................................... 5


                                                                 ii


        Case 7:24-cv-00231-ADA                   Document 65            Filed 06/11/26           Page 4 of 13


Redstone Logics LLC v. MediaTek Inc. et al,
  No. 7:24-cv-00029 (W.D. Tex. Jan. 26, 2024) ........................................................................... 3

Redstone Logics LLC v. Samsung Electronics Col, Ltd et al,
  No. 2:23-cv-00485 (E.D. Tex. Oct. 17, 2023) ............................................................................ 3

TC Tech. LLC v. T-Mobile USA,
  No. 6-20-CV-00899- ADA, 2021 WL 8083373 (W.D. Tex. 2021) ........................................... 3

Videoshare, LLC v. Meta Platforms Inc.,
  No. 6-21-CV-00254-ADA, 2022 WL 3142622 (W.D. Tex. Aug. 5, 2022) ............................... 6

Walker Digital, LLC v. Google, Inc.,
 No. CV 11-318-LPS, 2014 WL 2880474 (D. Del. June 24, 2014) ............................................. 3

Worldwide Oilfield Mach., Inc. v. Ameriforge Grp., Inc.,
 No. H-13-3123, 2015 WL 12780757 (S.D. Tex. June 5, 2015) ................................................. 1


       Case 7:24-cv-00231-ADA             Document 65          Filed 06/11/26       Page 5 of 13


I.      INTRODUCTION

        After just shy of two years of litigation, with trial in sight, and after sitting on the underlying

EPR decision for four months, Defendants now ask the Court for a stay. It is too late. Although,

based on Defendants delays and conflicts, no trial has been set in this case, it is entirely certain

that the average and median time to completion of EPRs places the conclusion of this EPR well

after trial in this case. If that were not enough, a stay will offer no simplification here, any claim

likely to be canceled will be narrowed out and unlike an IPR no estoppel can attach meaning the

Court will have to consider the exact issues raised in the EPR regardless. The only result will be

costly delay, a cost born only by Plaintiff. As such, a stay is not justified here and Defendants

motion should be denied.

II.     LEGAL STANDARD1

        Patent infringement suits are not automatically stayed pending the resolution of parallel

USPTO proceedings. See Kirsch Rsch. & Dev., LLC v. IKO Indus. Inc., No. 6:20-CV-00317-

ADA, 2021 WL 455610, at *2 (W.D. Tex. Oct. 5, 2021) (quoting Realtime Data, LLC v. Rackspace

US, Inc., No. 6:16-CV-00961-RWS-JDl, 2017 WL 772654, at *2 (E.D. Tex. Feb. 27, 2017)).

Rather, courts must first determine if the stay’s benefits outweigh its inherent costs. Id. (quoting

EchoStar Techs. Corp. v. TiVo, Inc., No. 5:05-CV-81, 2006 WL 2501494, at *1 (E.D. Tex. July

14, 2006). To do so, courts generally weigh (1) whether a stay would unduly prejudice or tactically

disadvantage the non-movant; (2) the stage of the proceedings; and (3) whether a stay would

simplify the issues in this case. See id.; see also Worldwide Oilfield Mach., Inc. v. Ameriforge

Grp., Inc., No. H-13-3123, 2015 WL 12780757, at *1 (S.D. Tex. June 5, 2015) (citing E-Watch,

Inc. v. Lorex Canada, Inc., No. H-12-3314, 2013 WL 55425298, (S.D. Tex. Sept. 26, 2013)).


1
 See Malikie Innovations LTD. et al v. Mara Holdings INC., Case No. 7:25-cv-00222-DC-DTG (W.D. Tex. June 1,
2026).


                                                     1


       Case 7:24-cv-00231-ADA           Document 65         Filed 06/11/26      Page 6 of 13


III.   ARGUMENT

       A.      Redstone Will Be Prejudiced By A Stay

       Defendants ignore the law and the circumstances in an attempt to get not a second, but a

third bite at the proverbial apple. A stay will permit Defendants a full three attacks at the validity

of Plaintiff’s patent on largely the same grounds. Moreover, a stay will materially damage

Redstone, harming its licensing position, while the only “prejudice” Defendants can allege is

simply continuing its litigation.

       First, while Defendants attempt to hide this issue in a footnote, it is indisputable that a stay

would grant Defendants a full three attempts at the same invalidity argument. First, Defendants

assert invalidity in this case, including based on White. Ex. 1 at 10. Second, Defendants sought to

have an IPR instituted raising White as its primary reference. See NXP USA, Inc. f/k/a NXP

Semiconductors USA, Inc. et al. v. Redstone Logics LLC, IPR2025-00485, Paper 1 (PTAB Jan. 22,

2025). This IPR was defeated on discretionary grounds. See NXP USA, Inc. f/k/a NXP

Semiconductors USA, Inc. et al. v. Redstone Logics LLC, IPR2025-00485, Paper 11 (PTAB Jul.

10, 2025). Third, though brought by a different defendant, the EPR at the heart of Defendants

motion likewise raises White and other references Defendants also raises in its contentions.

Compare Motion Ex. 4 with Ex. 1. A stay will permit Defendants to learn not only from its failed

IPR (which although it was denied on discretionary grounds, Redstone still had to file its patent

owner preliminary response addressing the merits), but to also learn from Plaintiff’s EPR

arguments and modify their invalidity arguments in this case based on those arguments.

Effectively, Defendants will have three attempts to invalidate Redstone’s patent when justice

grants them but one. This is real prejudice to Redstone. See EON Corp. IP Holdings, LLC v. Sensus

USA Inc., No. 6:09-CV-116, 2009 WL 9506927, at *2 (E.D. Tex. Dec. 18, 2009).


                                                  2


        Case 7:24-cv-00231-ADA                Document 65           Filed 06/11/26          Page 7 of 13


         Second, contrary to Defendants arguments, Redstone is still prejudiced by a stay even if

only seeking monetary damages. As this Court has previously held, a patent owner that seeks solely

monetary relief still has an interest in enforcing its patent right. TC Tech. LLC v. T-Mobile USA,

No. 6-20-CV-00899- ADA, 2021 WL 8083373, at *2 (W.D. Tex. 2021) (citing MiMedx Grp., Inc.

v. Tissue Transplant Tech. Ltd., 2015 WL 11573771, at *2 (W.D. Tex. Jan. 5, 2015)). As

recognized by now Federal Circuit Judge Stark, the longer Defendants are allowed to fragrantly

infringe the patent-in-suit, the lower the value of the patent-in-suit. Walker Digital, LLC v. Google,

Inc., No. CV 11-318-LPS, 2014 WL 2880474, at *1 (D. Del. June 24, 2014). Other infringers

seeing Apple practice without payment will be less inclined to take a license and that damage

cannot be cured by a monetary award when such an award is limited to a reasonable royalty.

         Moreover, Redstone has not delayed its case. While Qualcomm identifies its infringement

dating back to 2015, Redstone only came to possess the ’339 in late 2022. Ex. 2. Shortly thereafter,

Redstone began enforcing its rights. See Redstone Logics LLC v. Samsung Electronics Col, Ltd et

al, Case No. 2:23-cv-00485 (E.D. Tex. Oct. 17, 2023); Redstone Logics LLC v. MediaTek Inc. et

al, Case No. 7:24-cv-00029 (W.D. Tex. Jan. 26, 2024); Redstone Logics LLC v. NXP

Semiconductors NV et al, Case No. 7:24-cv-00028 (W.D. Tex. Jan. 26, 2024); Redstone Logics

LLC v. Qualcomm Inc. et al, Case No. 7:24-cv-00231 (W.D. Tex. Sep. 20, 2024). Redstone should

not be faulted for not having brought suit against Defendants sooner, 2 unlike Defendants,

Redstone’s resources are limited and it cannot support unlimited litigation and must instead


2
  While Defendants attempt to blame Redstone for the prior patent owner not having brought suit, it has no support
for such a contention. Indeed, the case Defendants cite addresses laches and specifically explained that laches had
already rendered the patent unenforceable before the assignment and “[a] patentee cannot avoid the consequences of
his laches by transferring the patent.” Eastman Kodak Co. v. Goodyear Tire & Rubber Co., 114 F.3d 1547, 1559
(Fed. Cir. 1997), abrogated by Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed. Cir. 1998). Unlike the
unenforceability associated with laches that had attached to the patent prior to transfer, in this case when Redstone
acquired the patent the EPR in question had not even been filed and no case against Defendants had been brought.


                                                          3


       Case 7:24-cv-00231-ADA             Document 65        Filed 06/11/26       Page 8 of 13


approach litigation piecemeal. As such, while Redstone’s limited resources have delayed its case

against Defendants, that is no basis to contend further delay will not prejudice Redstone.

        By contrast, Defendants are not entitled to claim prejudice. A prejudice here is an injury or

harm not merely failing to gain a boon to which Defendants never had a claim. Defendants’ claim

of prejudice is having to litigate this action. That is not prejudice, that is standard litigation.

        Because Redstone’s prejudice here will be serious and indefinite and Defendants have no

claim to prejudice if a stay is not granted, this factor weighs against a stay.

        B.      There Is No Simplification To Be Had By A Stay

        “[W]hether a stay would likely result in a simplification of issues before the court” is the

most important factor (Impinj, Inc. v. NXP USA, Inc., No. 6:21-CV-00530-ADA, 2023 WL

7476358, at *4 (W.D. Tex. May 18, 2023)) but Defendants argument on this factor misrepresents

how this case will proceed. First, unlike with an IPR, there will be no estoppel here narrowing the

invalidity case. The only possible simplification is to Redstone’s infringement case, but this

simplification will occur regardless of the stay and thus there is no simplification to be gained by

staying this action. Second, the history of the ’339 Patent demonstrates it is particularly unlikely

any claim will be canceled. And last, any conclusion of the EPR will arrive well after trail and thus

not arrive in time to simplify any issues for trial.

        It is a simple fact that the parties are not going to litigate every single claim of the ’339

Patent and Redstone will be well positioned to avoid claims likely to be changed or canceled.

Indeed, the parties have already agreed to narrow the number of asserted claims in this action with

a deadline to meet and confer in September. Dkt. 59. Redstone’s choice in narrowing its claims

will be informed by the progression of the ex parte reexamination. The examiner will enter office

actions informing Redstone and the public of its position as to what claims are or are not valid.

Redstone will aim to avoid claims it might need to change or that will be canceled. In the meantime,


                                                    4


        Case 7:24-cv-00231-ADA                Document 65           Filed 06/11/26         Page 9 of 13


there is nearly no difference in the effort the parties and the Court will expend in addressing

Redstone’s patent claims. The effort required to litigation even one patent claim is largely

equivalent to that of litigating multiple claims from that same patent. The claims, by their nature,

have a similar scope and common subject matter.

         While Defendants contend this means “the target is moving” and a stay is “the most

appropriate and efficient solution,” it offers no explanation why. The target is not “moving,” the

examiner is not going to decide some claims are valid in the first office action but then in the

second action are invalid. Nor has Qualcomm identified any additional effort that the Court or

parties will expend by following this path. As such it is unclear why a hugely disruptive stay, at

the close of fact discovery, would be more efficient.

         Only if all of the claims of the ’339 Patent are canceled will Redstone not be able to simply

assert only the claims expected to be confirmed. Historically, that has only occurred in about 15%

of EPRs. Motion Ex. 3 at 2. But here, the EPR is particularly weak and unlikely to result in any

cancelation or changing of any claim. 3

         Indeed, Redstone has already defeated three prior patent office challenges to its ’339

Patent, including one from Apple. See MediaTek, Inc. et al v Redstone Logics LLC, IPR2025-

00085, Paper 7 (PTAB Apr. 22, 2025); NXP USA, Inc. f/k/a NXP Semiconductors USA, Inc. et al.

v. Redstone Logics LLC, IPR2025-00485, Paper 11 (PTAB Jul. 10, 2025); Apple Inc. v. Redstone

Logics LLC, IPR2025-01532, Paper 10 (PTAB Jan. 27, 2026). More strikingly, the EPR cites only

a single reference not included in these failed IPRs. See Motion Ex. 4. While two of these IPRs

were denied on discretionary factors, those factors include weakness of the petition. The Patent


3
 Indeed, the original party to file the EPR recognized this and took a license settling Redstone’s action against
AMD. Redstone Logics LLC v. Advanced Micro Devices, Inc., 7:25-cv-00182, Dkt 40 (W.D. Tex. May 8, 2026).


                                                         5


      Case 7:24-cv-00231-ADA           Document 65        Filed 06/11/26      Page 10 of 13


Office has thus spoken, the grounds underlying the EPR are weak and unlikely to result in

cancellation of any, much less all claims.

       Last, under the current schedule, trial can be expected between 6 months and a year before

the EPR concludes. The median pendency for an EPR places the certificate issuing in August of

2027 with the average pendency placing it at January 2028. See Motion Ex. 3 at 2. This case will

be ready for trial in December of 2026, see Dkt. 59, and while trial is not currently set a delay of

more than 6 months is not reasonable. When “the USPTO will not complete the reexamination

until after trial has occurred, [] the reexamination decision will not arrive in time to simplify any

issues for trial.” Videoshare, LLC v. Meta Platforms Inc., No. 6-21-CV-00254-ADA, 2022 WL

3142622, at *2 (W.D. Tex. Aug. 5, 2022).

       Because any simplification is unlikely, untimely, and will be achieved regardless of a stay,

this factor weighs strongly against staying this case.

       C.      Two Years Of Litigation Do Not Favor a Stay

       This case was not just filed, the parties have argued multiple motions to dismiss, claim

construction, and discovery disputes. The parties are exchanged discovery with deposition

scheduled and expert discovery just around the corner. While trial is not set, the case will be

prepared for trial by December. That is a significant investment that the Court should not simply

discard.

       Moreover, Defendants has been lackadaisical not diligent in this matter. If Defendants were

going to seek a stay in this case, it should have done so in March, when the EPR was granted.

Motion Ex. 1. Instead, Defendants delayed four months. Four months in which the parties litigated

this case, engaged in discovery, and ran up legal bills. For Defendants to now claim a stay “would

avoid the most burdensome and expensive phases of patent litigation” rings entirely hollow.


                                                  6


      Case 7:24-cv-00231-ADA               Document 65      Filed 06/11/26       Page 11 of 13


       Defendants’ counter arguments misconstrue this factor and flip it on its head. Defendants

are correct there is still significant work to be done on this case, but this factor is backwards

looking; “the question is whether the court has expended significant resources already, not whether

the most burdensome part of the case has occurred, which will inevitably result in further

expenditures.” Impinj, Inc. v. NXP USA, Inc., No. 6:21-CV-00530-ADA, 2023 WL 7476358, at

*3 (W.D. Tex. May 18, 2023) (internal citations omitted). The parties have accomplished much in

this action, this weighs against a stay.

IV.    CONCLUSION

       In light of Defendants’ many months of delay, placing its request for a stay nearly 2 years

into this case and that a stay will grant no greater simplification than simple rational litigation on

the part of Redstone will, Defendants’ motion to stay should be denied for the same reasons as

Apple’s motion.


  Dated: June 11, 2026                                 Respectfully submitted,

                                                      /s/ Joshua Scheufler
                                                      Reza Mirzaie
                                                      CA State Bar No. 246953
                                                      Marc A. Fenster
                                                      CA State Bar No. 181067
                                                      Neil A. Rubin
                                                      CA State Bar No. 250761
                                                      Christian W. Conkle
                                                      CA State Bar No. 306374
                                                      Jonathan Ma
                                                      CA State Bar No. 312773
                                                      Joshua Scheufler
                                                      TX State Bar No. 24123406
                                                      RUSS AUGUST & KABAT
                                                      12424 Wilshire Boulevard, 12th Floor
                                                      Los Angeles, CA 90025
                                                      Telephone: 310-826-7474


                                                  7


Case 7:24-cv-00231-ADA   Document 65      Filed 06/11/26     Page 12 of 13


                                    Email: rmirzaie@raklaw.com
                                    Email: mfenster@raklaw.com
                                    Email: nrubin@raklaw.com
                                    Email: cconkle@raklaw.com
                                    Email: jma@raklaw.com
                                    Email : jscheufler@raklaw.com

                                    Qi (Peter) Tong
                                    TX Bar No. 24119042
                                    RUSS AUGUST & KABAT
                                    8080 N. Central Expy., Suite 1503
                                    Dallas, TX 75206
                                    Telephone: 310-826-7474
                                    Email: ptong@raklaw.com

                                    Attorneys for Plaintiff Redstone Logics LLC


                                8


      Case 7:24-cv-00231-ADA          Document 65       Filed 06/11/26      Page 13 of 13


                                CERTIFICATE OF SERVICE

       I certify that on June 11, 2026, a true and correct copy of the foregoing document was

electronically filed with the Court and served on all parties of record via the Court’s CM/ECF

system.

                                                     /s/ Joshua Scheufler
                                                    Joshua Scheufler


                                                9