Washington Western District Court
Judge:James L Robart
Case #: 2:21-cv-00310
Nature of Suit880 Civil Rights - Defend Trade Secrets Act of 2016 (DTSA)
Cause18:1836(a) - Injunction against Misappropriation of Trade Secrets
Case Filed:Mar 08, 2021
Terminated:May 15, 2023
Last checked: Saturday Sep 04, 2021 1:49 AM PDT
Defendant
Deepthink LLC
Represented By
Christopher Michael Reed
Montgomery Purdue PLLC
contact info
Benjamin I VandenBerghe
Montgomery Purdue PLLC
contact info
Plaintiff
Convoyant LLC
Represented By
Timothy J Billick
Tbillick Law PLLC
contact info


Docket last updated: 01/03/2025 11:59 PM PST
Monday, May 15, 2023
39 39 2 pgs order Order on Stipulated Motion ~Util - Terminate Case Mon 05/15 2:01 PM
STIPULATION AND ORDER of Dismissal re Parties'38 Stipulated MOTION. This case is dismissed with prejudice and with each party to bear its own costs and attorney fees. Signed by Judge James L. Robart. (LH)
Related: [-]
38 38 motion Stipulated Motion Mon 05/15 1:11 PM
Stipulated MOTION of Dismissal with Prejudice , filed by Defendant Deepthink LLC. Noting Date 5/15/2023, Related [+]
Related: [-] ed, Christopher
Wednesday, April 12, 2023
37 37 2 pgs order Order on Stipulated Motion ~Util - Case Stayed ~Util - Set/Reset Motion Noting Date Thu 04/13 9:17 AM
ORDER re Parties'36 Stipulated MOTION to stay deadlines pending settlement . All remaining case deadlines, including all deadlines associated with Defendant's pending motion for partial summary judgment (Dkt. No.34 ), are hereby stayed for forty-five (45) days. If an order dismissing all claims against all parties is not entered within forty-five (45) days after entry of this Order, the parties shall file a joint status report with the Court by such date. Signed by Judge James L. Robart. (LH)
Related: [-]
36 36 motion Stipulated Motion Wed 04/12 2:02 PM
Stipulated MOTION to stay deadlines pending settlement , filed by Plaintiff Convoyant LLC. Noting Date 4/12/2023, (Billick, Timothy)
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Att: 1 Proposed Order
Wednesday, March 29, 2023
35 35 misc Praecipe to Attach Document Wed 03/29 4:58 PM
PRAECIPE to attach document Appendix A re34 MOTION for Partial Summary Judgment by Defendant Deepthink LLC Related [+]
Related: [-] ed, Christopher
Att: 1 Exhibit
34 34 motion Partial Summary Judgment Wed 03/29 3:20 PM
MOTION for Partial Summary Judgment , filed by Defendant Deepthink LLC. Noting Date 4/21/2023, Related [+]
Related: [-] ed, Christopher
Att: 1 Proposed Order
Wednesday, September 07, 2022
33 33 notice Notice-Other Wed 09/07 4:49 PM
CERTIFICATE of Finality by Washington Supreme Court re28 Order. (LH)
Related: [-]
Friday, August 26, 2022
32 32 order JLR Minute Order Setting Trial Date & Related Dates(FORM) Fri 08/26 3:26 PM
MINUTE ORDER SETTING TRIAL DATE AND RELATED DATES by Judge James L. Robart; Length of Trial: *6 days*. Bench Trial is set for 10/23/2023 at 01:30 PM in Courtroom 14106 before Judge James L. Robart. Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 4/26/2023, Motions due by 5/26/2023, Discovery completed by 6/26/2023, Dispositive motions due by 7/25/2023, Attorney settlement conference to be held by 8/24/2023, Motions in Limine due by 9/11/2023, Pretrial Order due by 10/2/2023, Deposition Designations due by 10/4/2023, Pretrial Conference set for 10/10/2023 at 02:00 PM in Courtroom 14106 before Judge James L. Robart. Trial briefs to be submitted by 10/16/2023, Proposed Findings of Fact and Conclusions of Law to be submitted by 10/16/2023. (AD)
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31 31 2 pgs order Order Lifting Stay ~Util - Terminate Deadlines/Hearings ~Util - Set/Reset Deadlines/Hearings Fri 08/26 2:39 PM
ORDER: The court GRANTS the parties' request for an eight-month continuance; VACATES the February 21, 2023 trial date; SETS trial on October 23, 2023; DIRECTS the Clerk to issue a new scheduling order that resets all unexpired deadlines based on the new trial date; and LIFTS the stay in this matter. Signed by Judge James L. Robart. (LH)
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Thursday, August 25, 2022
30 30 misc Joint Status Report Thu 08/25 2:43 PM
JOINT STATUS REPORT signed by all parties. Estimated Trial Days: 6. (VandenBerghe, Benjamin)
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Friday, January 07, 2022
29 29 misc Letter Fri 01/07 3:51 PM
LETTER from Washington Supreme Court re28 Order Certifying Question. (LH)
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Monday, January 03, 2022
28 28 order ~Util - Set/Clear Flags ~Util - Terminate Motions 1 - Order Mon 01/03 8:32 AM
ORDER CERTIFYING QUESTION: The Clerk is DIRECTED to submit to the Washington Supreme Court certified copies of this order, a copy of the docket in the above-captioned matter, and docket numbers 1, 8, 15-22, and 25- 27.2 The court STAYS this action pending the Washington Supreme Court's final decision on the certified question and DENIES DeepThink's motion for partial summary judgment (Dkt. #15 ) on Convoyant's tort and unfair competition claims without prejudice to renewing its motion after the Washington Supreme Court issues its final decision. The parties shall file a joint status report within fourteen days after the Washington Supreme Court issues its final decision. Signed by Judge James L. Robart. (LH)
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Friday, December 17, 2021
27 27 misc Supplement Fri 12/17 3:12 PM
SUPPLEMENT re25 Order, SUPPLEMENTAL BRIEF ON CERTIFICATION TO THE WASHINGTON SUPREME COURT by Plaintiff Convoyant LLC (Billick, Timothy)
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26 26 misc Supplement Fri 12/17 8:34 AM
SUPPLEMENT re25 Order, Supplemental Briefing re: Certification of Preemption Question to Washington State Supreme Court by Defendant Deepthink LLC Related [+]
Related: [-] ed, Christopher
Tuesday, December 07, 2021
25 25 order 1 - Order Tue 12/07 3:54 PM
ORDER ON MOTION FOR PARTIAL SUMMARY JUDGMENT: The court GRANTS in part, DENIES in part, and DEFERS in part DeepThink's15 motion for partial summary judgment. The court ORDERS the parties to submit supplemental briefing by December 17, 2021. Signed by Judge James L. Robart. (LH)
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Wednesday, November 17, 2021
24 24 respm Surreply Wed 11/17 9:29 PM
SURREPLY filed by Plaintiff Convoyant LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) (Billick, Timothy)
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Tuesday, November 16, 2021
23 23 notice Notice-Other Tue 11/16 12:07 PM
NOTICE OF INTENT TO FILE SURREPLY re21 Reply to Response to Motion,22 Declaration, ; filed by Plaintiff Convoyant LLC. (Billick, Timothy)
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Friday, November 12, 2021
22 22 respm Declaration Fri 11/12 2:15 PM
DECLARATION of Christopher M. Reed in Support of Defendant's Motion for Partial Summary Judgment filed by Defendant Deepthink LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) Related [+]
Related: [-] ed, Christopher
21 21 respm Reply to Response to Motion Fri 11/12 2:12 PM
REPLY, filed by Defendant Deepthink LLC, TO RESPONSE to15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) Related [+]
Related: [-] ed, Christopher
Att: 1 Proposed Order Proposed Order
Wednesday, November 10, 2021
misc Receipt Wed 11/10 12:48 PM
RECEIPT of USB Drive (Exhibit B) re19 -2 Declaration of James Mayfield. (SR)(USB Drive placed in expando folder in Clerk's Office)
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Monday, November 08, 2021
20 20 respm Declaration Mon 11/08 6:54 PM
DECLARATION of Nathan Mayfield filed by Plaintiff Convoyant LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) (Billick, Timothy)
Related: [-]
19 19 respm Declaration Mon 11/08 6:53 PM
DECLARATION of James Mayfield filed by Plaintiff Convoyant LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2)(Billick, Timothy)
Related: [-]
Att: 1 Exhibit A,
Att: 2 Exhibit B
18 18 respm Declaration Mon 11/08 6:51 PM
DECLARATION of Tim Billick filed by Plaintiff Convoyant LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2)(Billick, Timothy)
Related: [-]
Att: 1 Exhibit A,
Att: 2 Exhibit B
17 17 respm Response to Motion Mon 11/08 6:48 PM
RESPONSE, by Plaintiff Convoyant LLC, to15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) . (Billick, Timothy)
Related: [-]
Thursday, October 14, 2021
16 16 respm Declaration Thu 10/14 3:22 PM
DECLARATION of Richard Aday in Support of Defendant's Motion for Partial Summary Judgment filed by Defendant Deepthink LLC re15 MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) (VandenBerghe, Benjamin)
Related: [-]
15 15 motion Partial Summary Judgment Thu 10/14 3:13 PM
MOTION for Partial Summary Judgment (Count Nos. 4, 5, 8, 9, 10, 11, 12, 13, 14, 15 and Parts of 1 and 2) , filed by Defendant Deepthink LLC. Noting Date 11/12/2021, (VandenBerghe, Benjamin)
Related: [-]
Att: 1 Proposed Order
Wednesday, May 19, 2021
14 14 5 pgs order Order on Stipulated Motion Wed 05/19 9:32 AM
ORDER re Parties'13 Stipulated Motion for Injunctive Relief . Signed by Judge James L. Robart. (LH)
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Tuesday, May 18, 2021
13 13 motion Stipulated Motion Tue 05/18 3:03 PM
Stipulated MOTION for Injunctive Relief , filed by Plaintiff Convoyant LLC. Noting Date 5/18/2021, (Billick, Timothy)
Related: [-]
Att: 1 Proposed Order Proposed Order
Thursday, May 13, 2021
12 12 order JLR Minute Order Setting Trial Date & Related Dates(FORM) Thu 05/13 2:34 PM
MINUTE ORDER SETTING TRIAL DATE AND RELATED DATES by Judge James L. Robart; Length of Trial: *6 days*. Bench Trial is set for 2/21/2023 at 01:30 PM in Courtroom 14106 before Judge James L. Robart. Joinder of Parties due by 7/12/2021, Amended Pleadings due by 8/25/2022, Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 8/25/2022, Motions due by 9/26/2022, Discovery completed by 10/24/2022, Dispositive motions due by 11/23/2022, Attorney settlement conference to be held by 12/23/2022, Motions in Limine due by 1/10/2023, Pretrial Order due by 1/31/2023, Deposition Designations due by 2/2/2023, Pretrial Conference set for 2/6/2023 at 02:00 PM in Courtroom 14106 before Judge James L. Robart. Trial briefs to be submitted by 2/14/2023, Proposed Findings of Fact and Conclusions of Law to be submitted by 2/14/2023. (AD)
Related: [-]
Monday, May 10, 2021
11 11 misc Joint Status Report Mon 05/10 7:30 AM
JOINT STATUS REPORT signed by all parties. Estimated Trial Days: six. Filed by Plaintiff Convoyant LLC.(Billick, Timothy)
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Thursday, April 08, 2021
10 10 discov Corporate Disclosure Statement Thu 04/08 4:27 PM
CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1. Filed by Deepthink LLC Related [+]
Related: [-] ed, Christopher
Monday, April 05, 2021
9 9 order Joint Status Report Order Form for District Judges Mon 04/05 4:22 PM
ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT by Judge James L. Robart. Joint Status Report due by 5/10/2021, FRCP 26(f) Conference Deadline is 4/19/2021, Initial Disclosure Deadline is 5/3/2021. (AD)
Related: [-]
Thursday, April 01, 2021
8 8 answer Answer to Complaint Thu 04/01 2:36 PM
ANSWER to1 Complaint,, and Affirmative Defenses by Deepthink LLC Related [+]
Related: [-] ed, Christopher
7 7 notice Notice of Appearance Thu 04/01 2:31 PM
NOTICE of Appearance by attorney Christopher Michael Reed on behalf of Defendant Deepthink LLC. Related [+]
Related: [-] ed, Christopher
utility Add and Terminate Attorneys Fri 04/02 4:17 PM
Attorney Benjamin I. VandenBerghe added for Deepthink LLC; per7 Notice of Appearance. (SR)
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Monday, March 15, 2021
6 6 discov Corporate Disclosure Statement Mon 03/15 10:47 AM
CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1. Filed by Convoyant LLC (Billick, Timothy)
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5 5 service Affidavit of Service of Summons & Complaint Mon 03/15 10:46 AM
AFFIDAVIT of Service of Summons and Complaint on Deepthink LLC dba ResNexus on 3/12/2021, filed by Plaintiff Convoyant LLC. (Billick, Timothy)
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Thursday, March 11, 2021
4 4 service Summons Issued Thu 03/11 10:03 AM
Summons(es) Electronically Issued as to defendant(s) Deepthink LLC (LH)
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Wednesday, March 10, 2021
3 3 misc Praecipe for a Summons Wed 03/10 1:04 PM
PRAECIPE TO ISSUE SUMMONS re1 Complaint,, by Plaintiff Convoyant LLC(Billick, Timothy)
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Att: 1 Summons Summons
Tuesday, March 09, 2021
2 2 misc Praecipe to Attach Document Tue 03/09 2:23 PM
PRAECIPE to attach document Summons re1 Complaint,, by Plaintiff Convoyant LLC(Billick, Timothy)
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Att: 1 Summons
utility Add and Terminate Judges Tue 03/09 8:45 AM
Judge James L. Robart added. (CDA)
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utility Corporate Disclosure Statement - Notice of Deadlines Tue 03/09 8:46 AM
NOTICE Pursuant to Fed.R.Civ.P 7.1, Plaintiff must file a Corporate Disclosure Statement by 3/16/2021. (CDA)
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Monday, March 08, 2021
1 1 cmp Complaint Mon 03/08 7:06 PM
COMPLAINT for DAMAGES AND INJUNCTIVE RELIEF against defendant(s) Convoyant LLC Related [+] Attorney Timothy J Billick added to party Convoyant LLC(pty:pla), filed by Convoyant LLC.(Billick, Timothy)
Related: [-] ceipt # AWAWDC-6990892
Att: 1 Exhibit A,
Att: 2 Exhibit B,
Att: 3 Exhibit C,
Att: 4 Exhibit D,
Att: 5 Exhibit E,
Att: 6 Exhibit F,
Att: 7 Exhibit G,
Att: 8 Exhibit H,
Att: 9 Exhibit I,
Att: 10 Exhibit J,
Att: 11 Exhibit K,
Att: 12 Exhibit L,
Att: 13 Exhibit M,
Att: 14 Exhibit N,
Att: 15 Exhibit O,
Att: 16 Exhibit P,
Att: 17 Exhibit Q,
Att: 18 Exhibit R,
Att: 19 Exhibit S,
Att: 20 Civil Cover Sheet Civil Cover Sheet