Unreported / Non-Citable
Background
ABC IP, LLC and Rare Breed Triggers, Inc. sought a consolidated preliminary injunction against defendants in multidistrict litigation involving alleged patent infringement. Several defendant groups moved to stay or extend briefing and discovery deadlines, require a structured conferral process, and obtain a status conference.
The defendants also asked the court to stay the preliminary-injunction proceedings pending Federal Circuit appeals involving Partisan and Hoffman and to hold the injunction motion in abeyance until the court resolved motions for leave to amend the complaints to assert U.S. Patent No. 12,626,403.
The Court’s Holding
The court denied as moot the request to enlarge deadlines and impose a 21-day conferral period because it had already authorized expedited discovery and established a preliminary-injunction briefing schedule. It directed the parties to meet and confer before the October 15, 2026 case-management conference and to raise any unresolved procedural issues there.
The court denied the requested appellate stay. The Partisan-related request was moot because the Federal Circuit had already affirmed the denial of injunctive relief in that case. The court declined to await Hoffman because that appeal concerned different parties and a different evidentiary record and therefore would not substantially affect the preliminary-injunction issues before it. The court also denied the abeyance request as moot because it had granted leave to amend the underlying complaints to add the ’403 patent.
Key Takeaways
- The consolidated preliminary-injunction proceedings will continue under the court’s existing discovery and briefing schedule.
- An appeal involving the same patent owner and similar alleged harm did not justify a stay where it concerned different parties and a different evidentiary record.
- Intervening case-management rulings rendered the requested deadline extensions, structured conferral period, and patent-related abeyance moot.
Why It Matters
The decision keeps the preliminary-injunction phase of the Rare Breed Triggers multidistrict litigation moving despite related Federal Circuit proceedings. It also underscores that overlapping patent issues alone may not warrant a stay when the requested injunction turns on defendant-specific claims and evidence.