KABIR v. WEBMD LLC
2:25-cv-15207
Overview
Case Number
2:25-cv-15207
Filing Date
2025-09-03
Status
Litigation filed
Court
District Court, D. New Jersey (njd)
Presiding Judge
Evelyn Padin
Nature of Suit
830 Patent
Jurisdiction Type
Federal Question
Cause of Action
28:1338 Patent Infringement
Jury Demand
Plaintiff
Parties
Defendant
WEBMD LLC
Represented By
5 Attorneys ListedDYKEMA GOSSETT PLLC
Tel: +1 (312) 876-1700
COUNSEL NOT ADMITTED TO USDC - NJ BAR, 10 SOUTH WACKER DRIVE
DYKEMA GOSSETT PLLC
Tel: +1 (512) 703-6300
COUNSEL NOT ADMITTED TO USDC - NJ BAR, 111 CONGRESS AVENUE
ELLIS GEORGE LLP
Tel: +1 (212) 413-2600
Fax: +1 (212) 413-2629
CARNEGIE HALL TOWER, 152 WEST 57TH STREET
Plaintiff
Court & Judges
Court
District Court, D. New Jersey (njd)
Presiding Judge
Evelyn Padin
Patents Involved
There are 3 patents involved in this case.
| Application Number | Patent Number | External Links |
|---|---|---|
| - | US11972865 | |
| - | US9536051 | |
| - | US9536865 |
Docket Entries
COMPLAINT filed by DOCTOR AI, LLC against WEBMD LLC. Filing Fee $ 405.00, Receipt Number 43631 (Attachments: # (1) Civil Cover Sheet, # (2) Index, # (3) Case Timeline, # (4) Explanation for Self-Representation and Jurisdiction, # (5) Jurisdiction Rationale, # (6) Exhibit 1 - E-mail, # (7) Exhibit 2 - E-mail, # (8) Exhibit 3 - DM Exchange, # (9) Exhibit 4 - DM Exchage, # (10) Exhibit 5 - DM Exchange, # (11) Exhibit 6 - Notice of WebMD sale, # (12) Exhibit 7 - Patent US 11,972,865 Bl, # (13) Exhibit 8 - Intellectual Property Agreement, # (14) Exhibit 9 - February 2025 Calendar, # (15) Exhibit 1- March 2025 Calendar, # (16) Exhibit 11 - April 2025 Calendar, # (17) Exhibit 12 - Claim Chart Analysis, # (18) Exhibit 13 - Narrative of Copyright Ownership) (tlf).
2025-04-21
1
Summons issued as to WEBMD, LLC (tlf).
2025-04-21
1
ORDER setting deadline by which counsel must enter an appearance. Ordered by US DISTRICT JUDGE CLAY D LAND on 4/22/2025. (esl)
2025-04-22
1
MOTION for Pro Se Representation, in response to [3] Order, Filed by DOCTOR AI LLC. (Attachments: # (1) Assignment Agreement, # (2) Notarized Assignment Application, # (3) Patent Assignment Cover Sheet, # (4) Cover Letter - Index of filing)(esl)
2025-05-08
1
ORDER granting [4] Motion (construed as a Motion for Leave to Amend the Complaint). Ordered by US DISTRICT JUDGE CLAY D LAND on 5/9/2025 (esl)
2025-05-09
1
AMENDED [1] Complaint, against WEBMD LLC, AZAD KABIR by AZAD KABIR (Attachments: # (1) Exhibit Symptom Checker, # (2) Exhibit CV of Patrick Dean Cummins, # (3) Civil Cover Sheet) (esl)
2025-05-14
1
MOTION to Stay Case Filed by AZAD KABIR. (Attachments: # (1) Exhibit Symptom Checker, # (2) Exhibit CV of Patrick Dean Cummins)(esl)
2025-05-14
1
MOTION for Limited Discovery Filed by AZAD KABIR. (Attachments: # (1) Exhibit 13 - Analysis of similarities of symptom checkers, # (2) Exhibit 14 - City of Biloxi PD Request, # (3) Cover Letter)(esl)
2025-05-15
1
ORDER denying [7] Motion to Stay; denying [8] Motion for Discovery Ordered by US DISTRICT JUDGE CLAY D LAND on 05/16/2025 (CCL)
2025-05-16
1
STIPULATION Extending Time for Defendant to Answer by WEBMD LLC (STARR, JEFFERSON)
2025-07-15
1
NOTICE of Clarification Regarding Timeline Submission by AZAD KABIR re [6] Amended Complaint/Petition (Attachments: # (1) Exhibit A - Updated Case Timeline and Exhibits Related to Intellectual Property/Trade Secret Case)(esl)
2025-07-16
1
MOTION to preserve evidence filed by Dr. AZAD KABIR (Attachments: # (1) Attachment A - Scope of Preservation, # (2) Exhibit 23 - Litigation Hold Notice) (tlf).
2025-07-28
1
NOTICE OF CLERK'S DECISION RE: E-Filing for AZAD KABIR. Your request to E-File is GRANTED. You must register to E-File via PACER.gov within five business days. Failure to register may result in rescission of e-filing privileges (tlf).
2025-07-28
1
EXHIBIT(S) 24 and 25 by AZAD ALAMGIR KABIR re [1] Complaint,,, (Attachments: # (1) Exhibit Exhibit 24: High-Level Summary: Kabir Patent Supremacy vs. WebMD Infringement, # (2) Exhibit Exhibit 25: WebMDPatent Infringement Presentation)(KABIR, AZAD)
2025-07-29
1
EXHIBIT(S) Exhibit 26: High-level Kabir Patent Analysis by AZAD ALAMGIR KABIR re [1] Complaint,,, (Attachments: # (1) Exhibit Exhibit 26: High-level Kabir Patent Analysis)(KABIR, AZAD)
2025-07-31
1
EMERGENCY MOTION for Leave to File LEAVE TO FILE EMERGENCY MOTION FOR INJUNCTIVE RELIEF AGAINST THOUGHTi, INC. Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-07-31
1
FIRST MOTION for Preliminary Injunction Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit Exhibit 7 Copy of U.S. Patent No. 11,972,865 B1, # (2) Exhibit Exhibit 24 - High-Level Patent Summary, # (3) Exhibit Exhibit 25 - WebMD Patent Infringement, # (4) Exhibit Exhibit 26 High-level Kabir Patent Analysis elaborating on the uniqueness and validity of the invention, # (5) Exhibit Exhibit 28 Claim chart analysis by Patrick Cummings and his resume, # (6) Exhibit Exhibit 29 - Claim chart analysis, by Neha Sharma, # (7) Exhibit Exhibit 27 -WebMD Settlement Email)(KABIR, AZAD)
2025-07-31
1
This is a text only entry; no document issued. ORDER denying [16] Motion for Leave to File. Plaintiff seeks leave to file an emergency motion for injunctive relief against THOUGHTi, Inc. Based on the Court's review of the operative complaint (Amended Complaint, ECF No. [6]), THOUGHTi, Inc. is not currently a Defendant in this action. Accordingly, Plaintiff's present motion (ECF No. [16]) is denied. If Plaintiff seeks leave to amend his complaint to assert claims against THOUGHTi, Inc., he should file a motion for leave to amend his complaint in accordance with the Federal Rules of Civil Procedure. Ordered by US DISTRICT JUDGE CLAY D LAND on 08/01/2025 (CCL)
2025-08-01
1
FIRST MOTION for Leave to File Motion for Leave to File Second Amended Complaint Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit 31 - Proposed Second Amended Complaint, # (2) Exhibit 30 - Case Timeline Criminal Complaint Biloxi Updated)(KABIR, AZAD)
2025-08-01
1
This is a text only entry; no document issued. ORDER granting [19] Motion for Leave to File. Plaintiff's motion for leave to file a second amended complaint is granted. The second amended complaint shall be filed by August 11, 2024. The second amended complaint shall comply with the form of pleadings set out in Federal Rule of Civil Procedure 10, including the requirement for sequentially numbered paragraphs. Because the amended complaint will be the operative complaint in this action, it should provide a clear reference to any exhibits, and any exhibits referenced in the second amended complaint should also be attached to the second amended complaint. Ordered by US DISTRICT JUDGE CLAY D LAND on 08/04/2025 (CCL)
2025-08-04
1
PETITION TO THE CLERK FOR ADMISSION TO PLEAD AND PRACTICE PRO HAC VICE on behalf of WEBMD LLC Attorney Admission Fee (Pro Hac Vice) paid by Receipt # AGAMDC-5015103, $100. LOCAL COUNSEL Name and Georgia Bar #: Jefferson M. Starr GBN: 992352. (Attachments: # (1) Certificate of Good Standing)(ZELLER, STEVEN)
2025-08-07
1
Order granting Petition for Admission Pro Hac Vice (Petition Attached); Attorney Admission Fee Met by STEVEN MCMAHON ZELLER. (aen)
2025-08-07
1
FIRST MOTION to Seal Document(s) Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit 33 Confidential Settlement Communication)(KABIR, AZAD)
2025-08-12
1
FIRST MOTION for Leave to File Motion for Leave to File Out of Time Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit Exhibit 1 Proposed Second Amended Complaint)(KABIR, AZAD)
2025-08-12
1
MOTION for Extension of Time to File Answer re [6] Amended Complaint/Petition by WEBMD LLC filed by STEVEN MCMAHON ZELLER.(ZELLER, STEVEN)
2025-08-14
1
RESPONSE filed by AZAD ALAMGIR KABIR re [25] MOTION for Extension of Time to File Answer re [6] Amended Complaint/Petition (KABIR, AZAD)
2025-08-14
1
ORDER terminating [23] Motion to Seal Document; granting [24] Motion for Leave to File Second Amended Complaint by August 28, 2025; granting [25] Motion for Extension of Time to Answer. Ordered by US DISTRICT JUDGE CLAY D LAND on 08/14/2025 (CCL)
2025-08-14
1
EMERGENCY MOTION for Protective Order Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-08-14
1
This is a text only entry; no document issued. ORDER denying [28] Motion for Protective Order. Plaintiff filed a motion for entry of a preservation order on July 28, 2025 (ECF No. 12). Under the local rules, the response to that motion is due by August 18, 2025. Yesterday, on August 14, 2025, Plaintiff filed what appears to be a duplicative motion seeking the same relief: entry of a preservation order (ECF No. 28). Plaintiff asks that the new motion be heard on an emergency basis. That duplicative motion (ECF No. 28) is denied. The Court will review the original motion (ECF No. 12) in due course after the response is filed on August 18, 2025. In the future, Plaintiff should not file duplicative motions. In addition, neither party shall file a motion regarding a disputed discovery-related matter unless the party certifies that it has conferred in good faith with the other party regarding the dispute and was unable to reach a resolution despite good faith efforts. Ordered by US DISTRICT JUDGE CLAY D LAND on 08/15/2025 (CCL)
2025-08-15
1
PETITION TO THE CLERK FOR ADMISSION TO PLEAD AND PRACTICE PRO HAC VICE on behalf of WEBMD LLC Attorney Admission Fee (Pro Hac Vice) paid by Receipt # AGAMDC-5025131, $100. LOCAL COUNSEL Name and Georgia Bar #: 992352. (Attachments: # (1) Certificate of Service)(ADAMS, MICHAEL)
2025-08-15
1
NOTICE Declaration of Pro Se Plaintiff Dr. Azad Kabir regarding efforts to obtain counsel and evidence preservation concerns by AZAD ALAMGIR KABIR (KABIR, AZAD)
2025-08-16
1
Order granting Petition for Admission Pro Hac Vice (Petition Attached); Attorney Admission Fee Met by MICHAEL P ADAMS. (aen)
2025-08-18
1
SECOND AMENDED COMPLAINT amending [6] Amended Complaint against WEBMD LLC, Thoughti, Inc by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit Declaration of Case Timeline of Events, # (2) Exhibit 3 LinkedIn correspondence between Anupam Das (CEO of THOUGHTi INC) and Azad Kabir Part 1, # (3) Exhibit 4 LinkedIn correspondence between Anupam Das (CEO of THOUGHTi INC) and Azad Kabir Part 2, # (4) Exhibit 5 LinkedIn correspondence between Anupam Das (CEO of THOUGHTi INC) and Azad Kabir Part 3, # (5) Exhibit 6 WebMD is acquired by Internet Brands, # (6) Exhibit 7 Patent grant for U.S. Patent No. US11972865B1, # (7) Exhibit 8 NDA and Code Assignment Agreement with THOUGHTi INC, # (8) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (9) Exhibit 13 Doctor AI Database Copy Right Declaration, # (10) Exhibit 16 Nilesh Server Access Details, # (11) Exhibit 19 Nilesh From India, # (12) Exhibit 20 Nilesh Upwork Oct 2017, # (13) Exhibit 21 Nilesh Started Working, # (14) Exhibit 22 Anupam Das Current Address, # (15) Exhibit 23 Notify Anupam Das About Nilesh Wrng Doing, # (16) Exhibit 24 High Level Patent Summary, # (17) Exhibit 25 WebMD Patent Infringement, # (18) Exhibit 26 A Revolution in Clinical Reasoning and Diagnostic Precision, # (19) Exhibit 28 Claim Chart Analysis by Patrick Cummings and Resume, # (20) Exhibit 29 Claim Chart Analysis by Neha Sharma)(KABIR, AZAD) Modified document name on 8/18/2025 (esl).
2025-08-18
1
RESPONSE filed by WEBMD LLC re [12] MOTION preserve evidence (ZELLER, STEVEN)
2025-08-18
1
Corporate Disclosure Statement by WEBMD LLC identifying Corporate Parent WEBMD HEALTH CORP., Corporate Parent MH SUB I LLC for WEBMD LLC. (ZELLER, STEVEN)
2025-08-18
1
REPLY to Response filed by AZAD ALAMGIR KABIR re [12] MOTION preserve evidence (KABIR, AZAD)
2025-08-19
1
FIRST MOTION for Leave to File CORRECTED SECOND AMENDED COMPLAINT Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - CORRECTED SECOND AMENDED COMPLAINT)(KABIR, AZAD)
2025-08-21
1
FIRST MOTION for Leave to File CORRECTED SECOND AMENDED COMPLAINT Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - CORRECTED SECOND AMENDED COMPLAINT)(KABIR, AZAD)
2025-08-21
2
JOINT MOTION for Protective Order by WEBMD LLC filed by STEVEN MCMAHON ZELLER. (Attachments: # (1) Proposed Order Stipulated Protective Order)(ZELLER, STEVEN)
2025-08-21
1
RESPONSE filed by WEBMD LLC re [17] MOTION for Preliminary Injunction (Attachments: # (1) Exhibit Ex A - Declaration of Heidi Schoembs, # (2) Exhibit Ex B - Declaration of Abdallah Abuhussein (REDACTED), # (3) Exhibit Ex C - Declaration of Tyler Lohse, # (4) Exhibit Ex D - Declaration of Steven McMahon Zeller)(ZELLER, STEVEN)
2025-08-21
1
RESPONSE filed by WEBMD LLC re [17] MOTION for Preliminary Injunction (Attachments: # (1) Exhibit Ex A - Declaration of Heidi Schoembs, # (2) Exhibit Ex B - Declaration of Abdallah Abuhussein (REDACTED), # (3) Exhibit Ex C - Declaration of Tyler Lohse, # (4) Exhibit Ex D - Declaration of Steven McMahon Zeller)(ZELLER, STEVEN)
2025-08-21
2
RESPONSE filed by WEBMD LLC re [17] MOTION for Preliminary Injunction (Attachments: # (1) Exhibit Ex A - Declaration of Heidi Schoembs, # (2) Exhibit Ex B - Declaration of Abdallah Abuhussein (REDACTED), # (3) Exhibit Ex C - Declaration of Tyler Lohse, # (4) Exhibit Ex D - Declaration of Steven McMahon Zeller)(ZELLER, STEVEN)
2025-08-21
2
RESPONSE filed by WEBMD LLC re [17] MOTION for Preliminary Injunction (Attachments: # (1) Exhibit Ex A - Declaration of Heidi Schoembs, # (2) Exhibit Ex B - Declaration of Abdallah Abuhussein (REDACTED), # (3) Exhibit Ex C - Declaration of Tyler Lohse, # (4) Exhibit Ex D - Declaration of Steven McMahon Zeller)(ZELLER, STEVEN)
2025-08-21
2
RESPONSE filed by WEBMD LLC re [17] MOTION for Preliminary Injunction (Attachments: # (1) Exhibit Ex A - Declaration of Heidi Schoembs, # (2) Exhibit Ex B - Declaration of Abdallah Abuhussein (REDACTED), # (3) Exhibit Ex C - Declaration of Tyler Lohse, # (4) Exhibit Ex D - Declaration of Steven McMahon Zeller)(ZELLER, STEVEN)
2025-08-21
2
MOTION to Seal Document(s) [40] Response to Motion, by WEBMD LLC filed by STEVEN MCMAHON ZELLER.(ZELLER, STEVEN)
2025-08-21
1
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
1
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
REPLY to Response filed by AZAD ALAMGIR KABIR re [17] MOTION for Injunction (Attachments: # (1) Exhibit 3 LinkedIn Message with Anupam Part 1, # (2) Exhibit 4 LinkedIn Message with Anupam Part 2, # (3) Exhibit 5 LinkedIn Message with Anupam Part 3, # (4) Exhibit 12 Declaration of Dr. Azad Kabir, M.D., M.S.P.H. (Expert Statistical Explanation), # (5) Exhibit 16 Nilesh October 2017 Server Access, # (6) Exhibit 25 WebMD Patent Infringement, # (7) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (8) Exhibit 29 Claim Chart Analysis by Neha Sharma, # (9) Exhibit 34 In-Pursuit-of-an-Expert-Artificial-Intelligence-System, # (10) Exhibit 35 Similarities of WebMD and Kabir Patent Results, # (11) Exhibit 39 Demonstration of Keyword Absence From Prior Art Article, # (12) Exhibit 40 WebMD Office Address of Privacy, # (13) Exhibit 41 Colony Square - Wikipedia WebMD Office)(KABIR, AZAD) Modified on 8/25/2025 to link to [17] motion (esl).
2025-08-23
2
FIRST MOTION for Leave to File Motion for Leave to Disclose Under-Seal Materials to the Department of Justice Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-08-23
1
FIRST MOTION to Seal Document(s) Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-08-23
1
FIRST MOTION for Protective Order Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - Plantiff Email About Future Amendment and Rush Request, # (2) Exhibit B - AMENDMENT NO 1 TO PROPOSED PROTECTIVE ORDER, # (3) Exhibit C - Kabir v WebMD - Proposed Stipulated Protective Order)(KABIR, AZAD)
2025-08-24
1
FIRST MOTION for Leave to File Excess Pages (Oversized Reply) Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - Response to Motion for Injunction, # (2) Exhibit B - Response to Motion for Injunction Short)(KABIR, AZAD) Modified event on 8/27/2025 (esl).
2025-08-26
1
FIRST MOTION to Seal Document(s) Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-08-26
1
FIRST MOTION for Discovery, MOTION for Partial Summary Judgment, MOTION for Protective Order Filed by AZAD ALAMGIR KABIR.(KABIR, AZAD)
2025-08-26
1
MOTION for Hearing on motions by AZAD ALAMGIR KABIR (KABIR, AZAD) Modified event on 8/27/2025 and linked to motions (esl).
2025-08-26
1
MEMORANDUM in Support filed by AZAD ALAMGIR KABIR re: [45] MOTION for Protective Order (Attachments: # (1) Exhibit A Plaintiff Email Demonstrating Approval Under Time Pressure and Express Reservation of Right to Amend, # (2) Exhibit B Defense Email Stating Protective Order Prohibits Disclosure of Evidence to Law-Enforcement or Regulatory Authorities)(KABIR, AZAD)
2025-08-27
1
MEMORANDUM in Support filed by AZAD ALAMGIR KABIR re: [45] MOTION for Protective Order (Attachments: # (1) Exhibit A Plaintiff Email Demonstrating Approval Under Time Pressure and Express Reservation of Right to Amend, # (2) Exhibit B Defense Email Stating Protective Order Prohibits Disclosure of Evidence to Law-Enforcement or Regulatory Authorities)(KABIR, AZAD)
2025-08-27
2
MEMORANDUM in Support filed by AZAD ALAMGIR KABIR re: [45] MOTION for Protective Order (Attachments: # (1) Exhibit A Plaintiff Email Demonstrating Approval Under Time Pressure and Express Reservation of Right to Amend, # (2) Exhibit B Defense Email Stating Protective Order Prohibits Disclosure of Evidence to Law-Enforcement or Regulatory Authorities)(KABIR, AZAD)
2025-08-27
2
PROTECTIVE ORDER - (granting [39] Joint Motion for Protective Order). Ordered by US DISTRICT JUDGE CLAY D LAND on 8/28/2025. (esl)
2025-08-28
1
FIRST MOTION for Leave to File Leave to File Under Seal Evidencing WebMD Collaboration Filed by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit B - AMENDMENT NO 1 TO PROPOSED PROTECTIVE ORDER)(KABIR, AZAD)
2025-08-29
1
ORDER TO SHOW CAUSE. By September 26, 2025, Plaintiff shall show cause why this action should not be transferred to the United States District Court for the District of New Jersey under 28 U.S.C. § 1406(a). The Court defers ruling on all pending motions until it determines whether this action should be transferred. Ordered by US DISTRICT JUDGE CLAY D LAND on 08/29/2025. (CCL)
2025-08-29
1
RESPONSE to Court Order filed by AZAD ALAMGIR KABIR re [53] Order to Show Cause, (KABIR, AZAD)
2025-08-30
1
MOTION for Extension of Time to File Answer re [34] Amended Complaint/Petition and MOTION to Stay all briefing on pending motions by WEBMD LLC filed by STEVEN MCMAHON ZELLER.(ZELLER, STEVEN). Added MOTION to Stay on 9/2/2025 (esl).
2025-08-30
1
ORDER OF TRANSFER transferring proceedings to the U.S. District Court for the District of New Jersey. ORDER also grants WebMD's [55] Motion for Extension of Time to Answer the second amended complaint [34]. This answer/response should be filed in the transferee court after the action is transferred to the District of New Jersey. Accordingly, WebMD shall answer or otherwise respond to the second amended complaint within 14 days after the action is transferred to the New Jersey district court. Ordered by US DISTRICT JUDGE CLAY D LAND on 9/2/2025. (esl)
2025-09-02
1
Certified Copy of Transfer Order and docket received, Case transferred in from District of Georgia Middle; Case Number 4:25-cv-00130. Original file certified copy of transfer order and docket sheet received.
2025-09-03
1
CONSENT & REGISTRATION FORM to received NEF from AZAD KABIR. (ADS) (lag, )
2025-09-05
1
MOTION for Electronic Filing (CM/ECF) Access, by AZAD ALAMGIR KABIR. (Attachments: # (1) Envelope)(wh)
2025-09-05
1
MOTION for Leave to File and to Vacate the Stipulated Protective Order Entered in the Transferring Court, by AZAD ALAMGIR KABIR. (Attachments: # (1) Envelope)(wh)
2025-09-05
1
NOTICE of Renewal and MOTION to Re-Calendar Priorly Filed Motions; Request for Coordinated Scheduling, by AZAD ALAMGIR KABIR. (Attachments: # (1) Envelope)(wh)
2025-09-05
1
CROSS-MOTION to Deny Sealing of the Declaration of Abdallah Abuhussein, by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit 41: Declaration of Dr. Kabir, # (2) Exhibit 42: Abuhussein Linkedin, # (3) Exhibit A: Schreenshots and Data, # (4) Exhibit B: Defense Email, # (5) Exhibit B: Abuhussein Declaration (Sealed), # (6) Exhibit 25: WebMD Patent Infringement Presentation, # (7) Envelope)(wh) Modified on 9/12/2025 (wh).
2025-09-05
1
NOTICE REGARDING USE OF COGNITIVE ARTIFICIAL INTELLIGENCE by AZAD ALAMGIR KABIR (ld)(Received via ADS)(n/m).
2025-09-06
1
MOTION for Leave to File Third Amended Complaint by AZAD ALAMGIR KABIR. (Attachments: # (1) Third Amended Complaint, # (2) Case Timeline of Events, # (3) Exhibit 1, # (4) Exhibit 3, # (5) Exhibit 4, # (6) Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9) Exhibit 8, # (10) Exhibit 12, # (11) Exhibit 13, # (12) Exhibit 16, # (13) Exhibit 19, # (14) Exhibit 20, # (15) Exhibit 21, # (16) Exhibit 22, # (17) Exhibit 23, # (18) Exhibit 24, # (19) Exhibit 25, # (20) Exhibit 26, # (21) Exhibit 28, # (22) Exhibit 29, # (23) Exhibit 34, # (24) Exhibit 35, # (25) Exhibit 44, # (26) Exhibit A, # (27) Exhibit B) (Received via ADS) (mj)
2025-09-08
1
MOTION to Seal by AZAD ALAMGIR KABIR. (Received via ADS) (mj)
2025-09-08
1
MOTION for Entry of a Preservation Order by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit 45) (Received via ADS) (mj)
2025-09-10
1
Clerk's Letter: Attorney is not admitted to the Federal Bar of New Jersey. Notice has been mailed to the attorney's address. (tjg, )
2025-09-11
1
Clerk's Letter: Attorney is not admitted to the Federal Bar of New Jersey. Notice has been mailed to the attorney's address. (tjg, )
2025-09-11
1
Clerk's Letter: Attorney is not admitted to the Federal Bar of New Jersey. Notice has been mailed to the attorney's address. (tjg, )
2025-09-11
1
NOTICE OF FILING CORRECTED DOCUMENT by AZAD ALAMGIR KABIR (Attachments: # (1) Suppliment to Priliminary Injunction Against WebMD Corrected, # (2) Suppliment to Priliminary Injunction Against WebMD, # (3) Exhibit 28 Claim Chart Analysis Patrick Cummings and Resume, # (4) Exhibit 29 - Claim Chart Analysis by Neha Sharma, # (5) Exhibit 37 Declaration About Suicide or Accidental Death, # (6) Exhibit 44 - WebMD API JSON Payload Showing Open AI Model (1), # (7) Exhibit 45 -Evolution of ChatGPT regarding Symptoms Checker [httpschatgpt.comshare68c1755d-ad1, # (8) Exhibit 46 - Copyright and Patent Infringement Lawsuits Against OpenAI, # (9) Exhibit 47 - Large Language)(ld)(Received via ADS)
2025-09-11
1
Sealed Submission from AZAD ALAMGIR KABIR. (wh)NOTICE TO COUNSEL: Counsel is advised that pursuant to Local Civil Rule 5.3(c)(2), a single, consolidated motion to seal shall be filed within 14 days following the completed briefing of the materials sought to be sealed, or within 14 days following the date on which the last of such materials was filed under temporary seal if the motion is resolved, unless otherwise directed by the Court.
2025-09-11
1
CROSS MOTION TO DENY SEALING OF THE DECLARATION OF ABDALLAH ABUHUSSEIN by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet) (Received via ADS) (mj)
2025-09-12
1
MOTION FOR LEAVE TO FILE AND TO VACATE THE STIPULATED PROTECTIVE ORDER ENTERED IN THE TRANSFERRING COURT by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet, # (2) Exhibit A - Kabir Email Asking For Ammendent In Future As I Had No Time But Agreed To Stipulation, # (3) Exhibit B - Defense Email Stating Protective Order Prohibits Disclosure (2))(ld)(Received via ADS)
2025-09-12
1
NOTICE OF RENEWAL AND MOTION TO RE-CALENDAR PRIORLY FILED MOTIONS; REQUEST FOR COORDINATED SCHEDULING by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet)(ld)(Received via ADS)
2025-09-12
1
PLAINTIFF'S MOTION FOR LEAVE TO FILE UNDER SEAL DOCUMENTS ELECTRONICALLY and PLAINTIFF'S MOTION FOR ELECTRONIC FILING (CM/ECF) ACCESS by AZAD ALAMGIR KABIR. (ADS) (lag, )
2025-09-12
1
Request for Summons to be Issued by AZAD ALAMGIR KABIR as to THOUGHTI, INC.. (Attachments: # (1) Cover Sheet)(Received via ADS)(wh)
2025-09-15
1
SUMMONS ISSUED as to THOUGHTI, INC.. Attached is the official court Summons, please fill out Defendant and Plaintiffs attorney information and serve. (wh)
2025-09-15
1
MOTION FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - Open Ai Subpoena Final, # (2) Exhibit 44 - WebMD API JSON Payload Showing Open AI Model, # (3) COVER SHEET)(ld)(Received via ADS)
2025-09-15
1
NOTICE of Appearance by JEFFREY A. MITCHELL on behalf of WEBMD LLC (MITCHELL, JEFFREY)
2025-09-16
1
NOTICE of Appearance by NICHOLAS PRADAXAY on behalf of WEBMD LLC (PRADAXAY, NICHOLAS)
2025-09-16
1
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting an extension of time for WebMD LLC to respond to the Second Amended Complaint. (MITCHELL, JEFFREY)
2025-09-16
1
NOTICE OF CLARIFICATION REGARDING PLAINTIFF'S POSITION ON SEALING by AZAD ALAMGIR KABIR (ld)(Received via ADS)
2025-09-16
1
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
1
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
2
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
2
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
2
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
2
LETTER RESPONSE TO DENY DEFENDANT'S REQUEST FOR EXTENSION OR, IN THE ALTERNATIVE, TO GRANT EXTENSION ONLY SUBJECT TO SAFEGUARDS. by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 47 - Offer to Meet About Disclosure of Third-Party Entities and Processes, # (2) Exhibit 48 - Request to extend WebMD's time to respond to the Second Amended Complaint, # (3) Exhibit 49 - Steve Email Asking Time Just to File Motion to Dismiss Based on Venue If I Agree to Extend, # (4) Exhibit 50 - Steve's Email for 30 days extension to respond to complaint, # (5) Exhibit 51 - Steve's email for filling response for extension of the second amended complaint)(ld)(Received via ADS)
2025-09-16
2
REVISED CROSS MOTION TO DENY SEALING OF THE DECLARATION OF ABDALLAH ABUHUSSEIN by AZAD ALAMGIR KABIR. (sm)
2025-09-16
1
TEXT ORDER This case was transferred to this Court on September 2, 2025. (ECF No. 56). At the time of transfer, the operative complaint was the Second Amended Complaint. (See id.) Since that time, Plaintiff has filed twelve (12) motions seeking assorted relief including requests to seal, amend, and for discovery. Included in Plaintiff's many motions is a motion for leave to file a Third Amended Complaint. (ECF No. 59). Establishing the operative Complaint is paramount to the orderly progression of the case, as the Complaint sets the scope of the claims and defenses as well as discovery. Further, the Court has broad discretion to control its docket. See In re Fine Paper Antitrust Litig., 685 F.2d 810, 817 (3d Cir. 1982). Accordingly, the Court will exercise its discretion and proceed as follows. All pending motions other than Plaintiff's motion for leave to file a third amended complaint are denied without prejudice as premature. Any opposition to Plaintiff's motion to amend shall be filed by October 1, 2025. Plaintiff may file a single reply brief by October 8, 2025. The Court will not entertain any other submissions in connection with the pending motion to amend. Defendant's obligation to answer or otherwise move in response to the Second Amended Complaint is suspended pending resolution of Plaintiff's motion to amend to file a Third Amended Complaint. Further, any materials that were previously filed under seal shall remain under seal until the parties have had an opportunity to confer and submit an appropriate omnibus motion pursuant to Local Civil Rule 5.3(c). The Court will not consider any further discovery-related motions until Plaintiff's motion to amend is decided. Should Plaintiff continue to file any such motions without leave of court, they will be summarily denied as being filed in violation of this Court's Local Rules and this Order. The Clerk of the Court is requested to terminate all pending motions (ECF Nos. 60, 64, 67-70, 72-75, & 78) other than Plaintiff's motion to amend at ECF No. 59. So Ordered by Magistrate Judge Jessica S. Allen on 09/17/2025. (Allen, Jessica)
2025-09-17
1
TEXT ORDER Based on the Court's Order dated 9/17/25, Plaintiff's [85] "revised cross-motion to deny sealing" is denied without prejudice. SO ORDERED by Magistrate Judge Jessica S. Allen on 9/24/2025. (mj)
2025-09-24
1
NOTICE REGARDING SUBMISSION OF CLEAN COPY AND MARKED (UNDERLINE/REDLINE) COPY OF PROPOSED THIRD AMENDED COMPLAINT by AZAD ALAMGIR KABIR (Attachments: # (1) Proposed Third Amended Complaint (Clean Version), # (2) Proposed Third Amended Complaint (Marked - Underlined Version))(ld)(Received via ADS)
2025-09-24
1
NOTICE REGARDING SUBMISSION OF CLEAN COPY AND MARKED (UNDERLINE/REDLINE) COPY OF PROPOSED THIRD AMENDED COMPLAINT by AZAD ALAMGIR KABIR (Attachments: # (1) Proposed Third Amended Complaint (Clean Version), # (2) Proposed Third Amended Complaint (Marked - Underlined Version))(ld)(Received via ADS)
2025-09-24
2
NOTICE REGARDING SUBMISSION OF CLEAN COPY AND MARKED (UNDERLINE/REDLINE) COPY OF PROPOSED THIRD AMENDED COMPLAINT by AZAD ALAMGIR KABIR (Attachments: # (1) Proposed Third Amended Complaint (Clean Version), # (2) Proposed Third Amended Complaint (Marked - Underlined Version))(ld)(Received via ADS)
2025-09-24
2
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting the admission Pro Hac Vice of Co-Counsel (on Consent). (Attachments: # (1) Certification of Jeffrey A. Mitchell in Support of Application for Admission Pro Hac Vice of Co-Counsel, # (2) Certification of Steven McMahon Zeller in Support of Application for Admission Pro Hac Vice, # (3) Certification of Michael P. Adams in Support of Application for Admission Pro Hac Vice, # (4) Text of Proposed Order for Pro Hac Vice Admission)(MITCHELL, JEFFREY) Modified on 9/26/2025 (aji, ).
2025-09-24
1
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting the admission Pro Hac Vice of Co-Counsel (on Consent). (Attachments: # (1) Certification of Jeffrey A. Mitchell in Support of Application for Admission Pro Hac Vice of Co-Counsel, # (2) Certification of Steven McMahon Zeller in Support of Application for Admission Pro Hac Vice, # (3) Certification of Michael P. Adams in Support of Application for Admission Pro Hac Vice, # (4) Text of Proposed Order for Pro Hac Vice Admission)(MITCHELL, JEFFREY) Modified on 9/26/2025 (aji, ).
2025-09-24
2
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting the admission Pro Hac Vice of Co-Counsel (on Consent). (Attachments: # (1) Certification of Jeffrey A. Mitchell in Support of Application for Admission Pro Hac Vice of Co-Counsel, # (2) Certification of Steven McMahon Zeller in Support of Application for Admission Pro Hac Vice, # (3) Certification of Michael P. Adams in Support of Application for Admission Pro Hac Vice, # (4) Text of Proposed Order for Pro Hac Vice Admission)(MITCHELL, JEFFREY) Modified on 9/26/2025 (aji, ).
2025-09-24
2
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting the admission Pro Hac Vice of Co-Counsel (on Consent). (Attachments: # (1) Certification of Jeffrey A. Mitchell in Support of Application for Admission Pro Hac Vice of Co-Counsel, # (2) Certification of Steven McMahon Zeller in Support of Application for Admission Pro Hac Vice, # (3) Certification of Michael P. Adams in Support of Application for Admission Pro Hac Vice, # (4) Text of Proposed Order for Pro Hac Vice Admission)(MITCHELL, JEFFREY) Modified on 9/26/2025 (aji, ).
2025-09-24
2
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. requesting the admission Pro Hac Vice of Co-Counsel (on Consent). (Attachments: # (1) Certification of Jeffrey A. Mitchell in Support of Application for Admission Pro Hac Vice of Co-Counsel, # (2) Certification of Steven McMahon Zeller in Support of Application for Admission Pro Hac Vice, # (3) Certification of Michael P. Adams in Support of Application for Admission Pro Hac Vice, # (4) Text of Proposed Order for Pro Hac Vice Admission)(MITCHELL, JEFFREY) Modified on 9/26/2025 (aji, ).
2025-09-24
2
NOTICE OF SERVICE OF SUMMONS AND COMPLAINT ON DEFENDANT THOUGHTI, INC. by AZAD ALAMGIR KABIR (Attachments: # (1) Summons Served Thoughti)(ld)(Received via ADS)
2025-09-25
1
ORDER granting [88] Motion for Leave to File as to Steven McMahon Zeller, Esq. and Michael P. Adams, Esq.. Signed by Magistrate Judge Jessica S. Allen on 09/26/2025. (aji, ) Modified on 9/29/2025 (aji, ).
2025-09-26
1
Notice of Request by Pro Hac Vice Steven McMahon Zeller to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-16684554.) (PRADAXAY, NICHOLAS)
2025-09-26
1
Notice of Request by Pro Hac Vice Michael P. Adams to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-16684601.) (PRADAXAY, NICHOLAS)
2025-09-26
1
RESPONSE to Motion filed by WEBMD LLC re [59] MOTION for Leave to File Third Amended Complaint (MITCHELL, JEFFREY)
2025-10-01
1
ORDER granting [59] Plaintiff's Motion for Leave to File a third amended complaint in the form appearing at ECT [59-1] within 10 days. Signed by Magistrate Judge Jessica S. Allen on 10/6/2025. (sm)
2025-10-06
1
THIRD AMENDED COMPLAINT against THOUGHTI, INC., WEBMD LLC, JOHN DOE 1 THOUGHTI, INC. answer due 10/20/2025; WEBMD LLC answer due 10/20/2025; NILESH PATKAR answer due 10/20/2025; JOHN DOE 1 answer due 10/20/2025., filed by AZAD ALAMGIR KABIR. (Received via ADS)_ (Attachments: # (1) Notice of Filing, # (2) Cover Letter)(sm) Modified on 10/16/2025 (sm).
2025-10-06
1
THIRD AMENDED COMPLAINT against THOUGHTI, INC., WEBMD LLC, JOHN DOE 1 THOUGHTI, INC. answer due 10/20/2025; WEBMD LLC answer due 10/20/2025; NILESH PATKAR answer due 10/20/2025; JOHN DOE 1 answer due 10/20/2025., filed by AZAD ALAMGIR KABIR. (Received via ADS)_ (Attachments: # (1) Notice of Filing, # (2) Cover Letter)(sm) Modified on 10/16/2025 (sm).
2025-10-06
2
THIRD AMENDED COMPLAINT against THOUGHTI, INC., WEBMD LLC, JOHN DOE 1 THOUGHTI, INC. answer due 10/20/2025; WEBMD LLC answer due 10/20/2025; NILESH PATKAR answer due 10/20/2025; JOHN DOE 1 answer due 10/20/2025., filed by AZAD ALAMGIR KABIR. (Received via ADS)_ (Attachments: # (1) Notice of Filing, # (2) Cover Letter)(sm) Modified on 10/16/2025 (sm).
2025-10-06
2
NOTICE of Appearance by WENDI OPPER UZAR on behalf of THOUGHTI, INC. (UZAR, WENDI)
2025-10-07
1
Application and Proposed Order for Clerk's Order to extend time to answer as to Thoughti Inc... (UZAR, WENDI)
2025-10-07
1
Application and Proposed Order for Clerk's Order to extend time to answer as to Defendant WebMD LLC.. (PRADAXAY, NICHOLAS)
2025-10-08
1
Application and Proposed Order for Clerk's Order to extend time to answer as to Defendant Thoughti Inc... (UZAR, WENDI)
2025-10-09
1
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
1
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
2
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
2
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
2
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
2
DOCUMENTS RECEIVED regarding evidentiary record from AZAD KABIR. (ADS) (Attachments: # (1) Exhibit A, # (2) Exhibit 3-5, # (3) Exhibit 66, # (4) Exhibit 75, # (5) Exhibit 76)(lag, )
2025-10-09
2
Letter from THOUGHTi, Inc.. (UZAR, WENDI)
2025-10-14
1
NOTICE OF PLAINTIFF'S INTENT TO SEEK LEAVE TO FILE FOURTH AMENDED COMPLAINT (ADDING DEFENDANT NILESH PATKAR A/K/A "NEIL PRO") by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 81 - Thoughti Inc. October 14, 2025 Letter Regarding Nilesh Patkar)(ld)(Received via ADS)
2025-10-26
1
NOTICE OF PLAINTIFF'S INTENT TO SEEK LEAVE TO FILE FOURTH AMENDED COMPLAINT (ADDING DEFENDANT NILESH PATKAR A/K/A "NEIL PRO") by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit 81 - Thoughti Inc. October 14, 2025 Letter Regarding Nilesh Patkar)(ld)(Received via ADS)
2025-10-26
2
Corporate Disclosure Statement by THOUGHTI, INC. identifying THOUGHTi India Private Limited as Corporate Parent.. (Attachments: # (1) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
1
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
1
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss by THOUGHTI, INC.. Responses due by 11/17/2025. (Attachments: # (1) Brief Brief ISO Motion to Dismiss, # (2) Declaration Declaration of A. Das, # (3) Exhibit Exhibit A - Cert. of Formation, # (4) Exhibit Exhibit B - Cert of Conversion, # (5) Text of Proposed Order Proposed Order, # (6) Certificate of Service Certificate of Service)(UZAR, WENDI)
2025-11-03
2
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
1
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
2
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
2
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
2
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
2
MOTION to Dismiss the Third Amended Complaint by WEBMD LLC. Responses due by 11/17/2025. (Attachments: # (1) Declaration of Steven McMahon Zeller in Support, # (2) Exhibit 1: U.S. Patent No. 9,536,051 B1, # (3) Exhibit 2: U.S. Patent No. 11,972,865 B1, # (4) Memorandum of Law in Support, # (5) Text of Proposed Order)(MITCHELL, JEFFREY)
2025-11-03
2
Letter from Wendi Opper Uzar, Esq.. (UZAR, WENDI)
2025-11-20
1
NOTICE OF PLAINTIFF'S MOTION FOR LEAVE TO FILE EXHIBIT 32.2 UNDER SEAL PURSUANT TO L. CIV. R. 5.3(c)(2) by AZAD ALAMGIR KABIR. (Received via ADS) (Attachments: # (1) Redacted Exhibit)(sm)
2025-11-20
1
MOTION FOR LEAVE TO FILE UNDER SEAL THE OPPOSITION BRIEF TO DEFENDANT WEBMD LLC'S MOTION TO DISMISS (ECF No. 105) by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A - Meet-and-Confer Motion for Leave to File, # (2) Exhibit B - Notice Pursuant to Georgia Protective Order, # (3) Exhibit C Notice Pursuant to Georgia Protective Order, # (4) Exhibit D - Extension of Protective Order to Thoughti)(ld)(Received via ADS)
2025-11-20
1
MOTION for leave to file oversized brief and opposition to motion by AZAD ALAMGIR KABIR. (ADS) (Attachments: # (1) Exhibit)(lag, ) Modified on 12/4/2025 (bt).
2025-11-20
1
Letter to Judge Padin from AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit 65) (Received via ADS) (mj)
2025-11-21
1
Letter from Jeffrey A. Mitchell to The Honorable Evelyn Padin, U.S.D.J. regarding Docket No. 106. (MITCHELL, JEFFREY)
2025-11-21
1
TEXT ORDER: The Court is in receipt of Defendants' Letter requesting a conference or clarity on how to proceed given Plaintiff's numerous, voluminous, and untimely filings. D.E. [106] & [109]. The Court is aware of Plaintiff's numerous filings, and while Defendants mention several new filings that Plaintiff has served or attempted to serve on Defendants, such as (1) an untimely and overlength opposition; (2) a motion to file an overlength opposition; (3) a motion to file an untimely opposition; and (4) a motion to seal, those filings have not yet been docketed, and the Court is therefore unable to consider them. The Court will therefore STAY Defendants' reply deadline. Once Plaintiff's filings are docketed and the Court is able to consider them, the Court will apprise Defendants of what their reply deadline is. The Court will caution Plaintiff that although he proceeds pro se, he must nevertheless comply with the Federal Rules of Civil Procedure. Sykes v. Blockbuster Video, 205 F. App'x 961, 963 (3d Cir. 2006) (expecting pro se litigants to comply with the Federal Rules of Civil Procedure); Blount v. Mason, No. 22-56, 2023 WL 6276680, at *8 (M.D. Pa. Sept. 26, 2023) (explaining that the Federal Rules of Civil Procedure apply to all parties, even if pro se). He must also comply with this District's Local Civil Rules and with this Court's Judicial Preferences. L. Civ. R. 101.1(d); see Section I.A of this Court's Judicial Preferences ("All of the matters addressed in this Procedures apply to all litigants in any matter pending before Judge Padin, including all pro se litigants, unless stated otherwise."). The Court will further caution Plaintiff that the "Court may reject any brief or other paper not filed within the time specified, L. Civ. R. 7.1(d)(7), and that overlength briefs "will only be accepted if special permission of the Judge is obtained prior to submission of the brief," L. Civ. R. 7.2(b) (emphasis added); Section II.E.iv of this Court's Judicial Preferences ("Requests for overlength briefs are highly disfavored."). Failure to abide by the Federal Rules of Civil Procedure, this District's Local Rules, or this Court's Judicial Preferences may result in sanctions and/or rejection of papers filed. So Ordered by Judge Evelyn Padin on 11/21/2025. (bt) Modified on 12/1/2025 (bt).
2025-11-21
1
RESPONSE to Court Order ECF No. 110. by AZAD ALAMGIR KABIR (ld)(Received via ADS)
2025-11-21
1
MOTION for leave to file out of time and for an extension of time by AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc, ) Modified on 12/4/2025 (bt).
2025-11-24
1
PLAINTIFF'S MOTION FOR LEAVE TO FILE UNDER SEAL THE OPPOSITION TO DEFENDANT THOUGHTI INC.'S MOTION TO DISMISS (ECF No. 104) by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A-D) (Received via ADS) (arm)
2025-11-24
1
Exhibits : Opposition to WebMD's Motion from Azad Alamgir Kabir. (Received via ADS) (Attachments: # (1) Exhibit Motion for leave to file, # (2) Exhibit 3, 4, 5 Thought Inc., # (3) Exhibit 44 WebMD, # (4) Exhibit 45 Evolution of Chat, # (5) Exhibit 47 Large Language Model, # (6) Exhibit 63 Thought CEO, # (7) Exhibit 64 Thought Corporate Address, # (8) Exhibit 65 Declaration of Bad Faith, # (9) Exhibit 68 Plaintiff Symptoms, # (10) Exhibit 77 Neilesh Patkar SOW, # (11) Exhibit 78 Neilesh Patkar NDA, # (12) Exhibit 79 Neilesh Patkar, # (13) Exhibit 85 Expert Patent, # (14) Exhibit 90 U.S. Patent 9,536,865, # (15) Exhibit 91 U.S. Patent 9,536,051, # (16) Exhibit 92 Chat GPT, # (17) Exhibit 93 Evidence of Athena)(sm)
2025-11-24
1
MOTION for Leave to File oversized brief by AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc, ) Modified on 12/4/2025 (bt).
2025-11-25
1
Plaintiff's Notice Regarding Record Preservation, Docketing Issues, and Request to Proceed with Filed Submissions by AZAD ALAMGIR KABIR. (Received via ADS) (arm)
2025-11-28
1
Letter from Wendi Opper Uzar, Esq. re [111] MOTION FOR LEAVE TO FILE UNDER SEAL THE OPPOSITION BRIEF TO DEFENDANT WEBMD LLC'S MOTION TO DISMISS (ECF No. 105), [107] MOTION to Seal, [115] MOTION. (UZAR, WENDI)
2025-12-01
1
MOTION FOR LEAVE TO FILE UNDER SEAL THE OPPOSITION TO DEFENDANT THOUGHTI INC.'S MOTION TO DISMISS (ECF No. 104) by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet)(ld)(Received via ADS)
2025-12-01
1
MOTION FOR LEAVE TO FILE UNDER SEAL THE OPPOSITION BRIEF TO DEFENDANT WEBMD LLC'S MOTION TO DISMISS (ECF No. 105) by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet)(ld)(Received via ADS)
2025-12-01
1
MOTION FOR LEAVE TO FILE OVERSIZED BRIEF RESPONSE TO WebMD's MOTION TO DISMISS (ECF 105) by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet)(ld)(Received via ADS)
2025-12-01
1
MOTION FOR LEAVE TO FILE OUT OF TIME AND EXTENSION OF TIME UNTIL DECEMBER 1, 2025 TO FILE OPPOSITIONS TO THE TWO MOTIONS TO DISMISS by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet)(ld)(Received via ADS)
2025-12-01
1
TEXT ORDER: Plaintiff proceeds pro se and appears to seek leave to file untimely overlength briefs in response to THOUGHTi's and WebMD's motions to dismiss. See D.Es. [112], [113], [115]; see also D.Es. [106], [109]. The Court will GRANT Plaintiff's request for an extension, D.E. [112], but will DENY Plaintiff's request to file overlength briefs, D.Es. [113], [115]. Because of the delay in ADS docketing, the Court will permit Plaintiff to file compliant oppositions to D.Es. [104] and [105] before or on 12/15/2025.As discussed above in D.E. 110, Section II.E.iv of this Court's Judicial Preferences explains that "[r]equests for overlength briefs are highly disfavored." Plaintiff relies on a complex multi-district litigation involving 37 individual actions with different categories. See, e.g., D.E. [113] at 5 (citing In re Fine Paper Antitrust Litig., 685 F.2d 810, 817 (3d Cir. 1982)); D.E. [115] at 5 (same). Plaintiff also cites a case that appears not to exist. D.E. 113 at 5 (citing non-existent United States v. Schiff, No. 17-7306, 2020 WL 1234567 (D.N.J. Mar. 12, 2020)); D.E. [115] at 5 (same). The Westlaw identifier cited exists for no case and the case no. 17-7306 corresponds to a case Vandium LLC v. Datamotion, Inc. Hallucinated citations will not be excused, and the Court may sanction Plaintiff for further uses of hallucinated citations. Plaintiff's oppositions must comply with the page limits described in this Court's Judicial Preferences and with this District's Local Rules. The Court will provide Plaintiff more time to do so but warns Plaintiff that the Court will reject any opposition that does not comply with page limit requirements or which includes hallucinated citations. See L. Civ. R. 7.2(b); Section I.B. of this Court's Judicial Preferences (setting guidelines on the use of generative artificial intelligence). So Ordered by Judge Evelyn Padin on 12/2/2025. (bt)
2025-12-02
1
MOTION FOR LEAVE TO FILE SUPPLEMENTAL EXHIBIT / ADDENDUM by AZAD ALAMGIR KABIR. (Attachments: # (1) Supplement and Amendment to Plaintiff's Opposition to [104] and [105], # (2) Exhibit 94 - U.S. Copyright - 1-15032919121 Doctor AI Cognitive Diagnostic Reasoning Database, # (3) Cover Sheet)(ld)(Received via ADS)
2025-12-02
1
Plaintiff's Notice Regarding Record Preservation, Docketing Issues and Request to Proceed with Filed Submissions by AZAD ALAMGIR KABIR (Received via ADS) (Attachments: # (1) Cover Letter)(sm)
2025-12-02
1
PLAINTIFF'S OPPOSITION TO WEBMD'S MOTION TO DISMISS (ECF 105) AND CONDITIONAL RENEWAL OF PRELIMINARY INJUNCTION (FILED SUBJECT TO COURT'S LEAVE filed by AZAD ALAMGIR KABIR re [105] MOTION to Dismiss the Third Amended Complaint (Received via ADS) (Attachments: # (1) Cover Letter)(sm)
2025-12-02
1
PLAINTIFF'S OPPOSITION TO DEFENDANT THOUGHTI INC.'S MOTION TO DISMISS (ECF No. 104) filed by AZAD ALAMGIR KABIR re [104] MOTION to Dismiss (Received via ADS) (Attachments: # (1) Cover Letter)(sm)
2025-12-02
1
Plaintiff's Response to Thoughti Inc.'s Mischaracterization of Plaintiff's Opposition as "Impertinent" and "Unnecessary" (ECF 116) (Received via ADS) (sm)
2025-12-02
1
LETTER ORDER finding as moot [107] Motion to Seal and [111] Motion for Leave to File Under Seal the Opposition Brief to Defendant WEBMD LLC'S Motion to Dismiss (ECF No. [105]). Signed by Magistrate Judge Jessica S. Allen on 12/3/2025. (mlh)
2025-12-03
1
Letter to Judge Padin from AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc, )
2025-12-04
1
TEXT ORDER: The Court is in receipt of Plaintiff's Motion to Seal (ECF No. [120]). For the reasons set forth in this Court's prior Order of 12/3/25 (ECF No. [118]), Plaintiff's instant Motion (ECF No. [119]) is DENIED WITHOUT PREJUDICE. So Ordered by Magistrate Judge Jessica S. Allen on 1/5/25. (jbb)
2025-12-05
1
DOCUMENTS RECEIVED from AZAD KABIR. (ADS) (lag, )
2025-12-07
1
RESPONSE in Opposition filed by AZAD ALAMGIR KABIR re [104] MOTION to Dismiss (Attachments: # (1) Cover Sheet, # (2) Exhibits 1-104, # (3) Exhibit 94) (Received via ADS) (mj)
2025-12-07
1
EXHIBITS FOR -- PLAINTIFF'S OPPOSITION TO DEFENDANT WEBMD'S MOTION TO DISMISS (ECF No. 105) -- REDACTED VERSION FOR PUBLIC DOCKETING by AZAD ALAMGIR KABIR. (Received via ADS) (arm)
2025-12-07
1
PLAINTIFF'S OPPOSITION TO WEBMD'S MOTION TO DISMISS (ECF 105) AND CONDITIONAL RENEWAL OF PRELIMINARY INJUNCTION (FILED SUBJECT TO COURT'S LEAVE) PAGE LIMIT 40 PAGES filed by AZAD ALAMGIR KABIR re [105] MOTION to Dismiss the Third Amended Complaint (Received via ADS) (Attachments: # (1) Cover Letter, # (2) Exhibit 2 Opposition to WebMD [10], # (3) Exhibit 94 U.S. Copyright)(sm)
2025-12-07
1
Exhibits to [136] Response in Opposition to Motion, by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit 78 - NDAFalse, # (2) Exhibit 79 - NDACorrect, # (3) Exhibit 85- PDC, # (4) Exhibit 90 - 9,536,865, # (5) Exhibit 91 - 9,536,051, # (6) Exhibit 92- ChatGPT, # (7) Exhibit 93 Athena)(ld)(Received via ADS)
2025-12-07
1
MOTION to file under Seal by AZAD ALAMGIR KABIR. (Attachments: # (1) Cover Sheet ADS Filings, # (2) Discovery Confidentiality Order) (Received via ADS) (arm)
2025-12-07
1
TEXT ORDER: The Court has reviewed Plaintiff's motion to file a supplemental amendment to his oppositions to the pending motions to dismiss, D.Es. [104] and [105]. D.E. [121]. Because the Court rejected Plaintiff's proposed overlength oppositions and provided Plaintiff with additional time to file oppositions that comply with the Federal Rules of Civil Procedure, this District's Local Civil Rules, and this Court's Judicial Preferences, D.E. 117, the Court will DENY Plaintiff's motion to file a supplemental amendment, D.E. [121]. The Court also cautions Plaintiff that Judges "are not pigs searching for truffles and are unwilling to search through the massive record that has been developed in this case to find evidence of... alleged violations." United States v. Winkelman, 548 F. Supp. 2d 142, 150 (M.D. Pa. Mar. 10, 2008). Because of the numerous filings that have already appeared on this young docket, Plaintiff should take care to ensure that the relevant exhibits are attached to his filings when he submits his compliant oppositions to Defendants' motions to dismiss. So Ordered by Judge Evelyn Padin on 12/9/2025. (bt)
2025-12-09
1
TEXT ORDER: The Court has reviewed Plaintiff's Letter addressing the Court's prior Order at D.E. [117]. D.E. [129]. The Court reiterates its previous warning that hallucinated citations will not be permitted under any circumstances. D.E. [117]. Plaintiff also requests to submit his oppositions to WebMD's and THOUGHTi's motions to dismiss, D.Es. [104] and [105], via flash drive, rather than through the ADS system. D.E. [129] at 7, 18. The Court will DENY Plaintiff's request. The Court will consider only filings that are docketed. Plaintiff may contact the CM/ECF Helpline at 1-866-726-0726 for assistance in docketing his filings. Plaintiff may also refer to the ECF Policies and Procedures (https://www.njd.uscourts.gov/sites/njd/files/PoliciesandProcedures2014.pdf) and the ECF User's Manual (https://www.njd.uscourts.gov/sites/njd/files/CMECFUserGuide.pdf) for assistance. The Court again instructs Plaintiff that his oppositions and materials should be submitted together to avoid any confusion resulting from the already many filings that Plaintiff has filed on this docket. In addition, Plaintiff must file his oppositions to the pending motions to dismiss before or on 12/15/2025. The filings need not be processed by the ADS system by 12/15/2025. Once Plaintiff's compliant oppositions are processed and appear on the docket, the Court will advise Defendants what their reply deadlines are. So Ordered by Judge Evelyn Padin on 12/9/2025. (bt)
2025-12-09
1
TEXT ORDER: The Court is in receipt of Plaintiff's motions to seal (ECF Nos. [124] & [125]) and his motions to file an overlength brief and extension of time to file opposition papers, (ECF Nos. [126] & [127]), to the pending motions to dismiss. For the reasons set forth in the Order issued by District Judge Padin on 12/2/25 (ECF No. [117]) and this Court's prior Order of 12/3/25, (ECF No. [118] ), Plaintiff's instant motions (ECF Nos. [124] & [125]) are DENIED WITHOUT PREJUDICE and Plaintiff's motions (ECF Nos. [126] & [127]) are DISMISSED AS MOOT. So Ordered by Magistrate Judge Jessica S. Allen on 12/9/25. (jbb)
2025-12-09
1
TEXT ORDER: The Court has reviewed Plaintiff's oppositions at D.Es. [130] and [136]. The Court appreciates that Plaintiff has shortened his briefs, but they remain overlength. "Typeface shall be in 12-point non-proportional font (such as Courier New 12) or an equivalent 14-point proportional font (such as Times New Roman 14). If a 12-pont proportional font is used instead, the page limits shall be reduced by 25 percent." L. Civ. R. 7.2(d). Plaintiff's oppositions are written in 12-point font, and the page limit is therefore 30 pages, not 40 pages. Plaintiff must resubmit compliant briefs. Plaintiff's exhibits must also be reattached to those compliant briefs. So Ordered by Judge Evelyn Padin on 12/11/2025. (bt)
2025-12-11
1
Letter to the court About Appendix S DCO from AZAD ALAMGIR KABIR. (Attachments: # (1) APPXS discovery confidorder Signed (1), # (2) Exhibit 95 DNJ Protective Order)(ld)(Received via ADS)
2025-12-11
1
Letter from Defendants re [142] Letter, [118] Order on Motion to Seal, Order on Motion for Miscellaneous Relief. (Attachments: # (1) Exhibit Ex. A - Plaintiff's proposed confidentiality order, # (2) Exhibit Ex. B - Defendants' proposed confidentiality stipulation, # (3) Exhibit Ex. C - E-mail Thread, # (4) Exhibit Ex. D - Plaintiffs letter)(UZAR, WENDI)
2025-12-11
1
Letter requesting a one-week extension to submit Complaint 30-Page Oppositions from Azad Alamgir Kabir. (Received via ADS) (sm)
2025-12-11
1
TEXT ORDER: In response to the parties' respective letters regarding the proper form of the Discovery Confidentiality Order, (ECF Nos. [142] and [143]), the Court intended for the parties to enter the confidentiality order currently appearing as Appendix S to the Court's Local Civil Rules. Accordingly, Defendants proposed form of Order is the correct version. On or before 12/18/25, Plaintiff is directed to execute and return Defendants' version of the Discovery Confidentiality Order appearing at ECF No. [143]-[2]. Upon full execution, the proposed form of Order should be submitted to the Court for entry. So Ordered by Magistrate Judge Jessica S. Allen on 12/12/25. (jbb)
2025-12-12
1
Letter to Judge Padin and Judge Allen from AZAD KABIR. (ADS) (lag, )
2025-12-12
1
STIPULATION re [144] Text Order,, Confidentiality Order by THOUGHTI, INC.. (LABRUTTO, COREY)
2025-12-15
1
NOTICE OF PLAINTIFF'S EXECUTION OF DISCOVERY CONFIDENTIALITY ORDER (APPENDIX S) by AZAD ALAMGIR KABIR. (Received via ADS) (Attachments: # (1) Protective Order)(sm)
2025-12-15
1
Confidentiality Order filed. Signed by Magistrate Judge Jessica S. Allen on 12/16/2025. (kht)
2025-12-16
1
PLAINTIFF'S UPDATED MOTION for Leave to File Under Seal by AZAD ALAMGIR KABIR. (Attachments: # (1) Opposition, # (2) Opposition, # (3) Exhibit 1-104, # (4) Exhibit 2, # (5) Cover Sheet) (Received via ADS) (mj)
2025-12-16
1
TEXT ORDER: The Court has reviewed Plaintiff's request for an extension to submit compliant oppositions to WebMD's and THOUGHTi's motions to dismiss, D.Es. [104] and [105]. D.E. [147]. The Court will GRANT the extension request. Plaintiff must file his oppositions to D.Es. [104] and [105] before or on 12/22/2025. So Ordered by Judge Evelyn Padin on 12/17/2025. (bt)
2025-12-17
1
NOTICE OF RECORD PRESERVATION REGARDING DOCKETING BURDENS ON PRO SE by AZAD ALAMGIR KABIR (ld)(Received via ADS)
2025-12-27
1
RESPONSE to Motion filed by THOUGHTI, INC. re [151] MOTION for Leave to File (LABRUTTO, COREY)
2026-01-06
1
Letter to Judge Padin from AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc, )
2026-01-06
1
TEXT ORDER: Plaintiff has yet to file compliant oppositions in response to Defendants' motions to dismiss, D.Es. [104] & [105]. The Court has accounted for delays due to the ADS docketing process but the Court's third extended deadline for Plaintiff's briefs has now been outstanding for over two weeks. See D.E. 150. Plaintiff must file compliant oppositions before or on 1/9/2026 and must serve those compliant oppositions on Defendants WebMD and THOUGHTi by the same date. If Plaintiff fails to provide compliant oppositions, the Court will consider only the first thirty pages of the non-compliant oppositions Plaintiff filed at D.Es. [130] & [136]. Defendants WebMD and THOUGHTi should file their respective replies before or on 1/16/2026. So Ordered by Judge Evelyn Padin on 1/7/2026. (bt)
2026-01-07
1
Letter from AZAD KABIR. (ADS) (lag, )
2026-01-07
1
Plaintiff's Opposition filed by AZAD ALAMGIR KABIR re [104] MOTION to Dismiss (Attachments: # (1) Exhibit 75, # (2) Exhibit 81, # (3) Exhibit 84, # (4) Sealed Exhibit) (RECEIVED VIA ADS)(adc, )
2026-01-08
1
Letter to Judge Padin from AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc, )
2026-01-08
1
Motion for leave to file under seal by AZAD ALAMGIR KABIR. (RECEIVED VIA ADS) (adc) (Main Document 161 replaced on 1/13/2026) (adc). Modified on 1/13/2026 (adc).
2026-01-08
1
PLAINTIFF'S OPPOSITION to WebMD's motion to dismiss ECF 105 from AZAD KABIR. (ADS) (lag, )
2026-01-08
1
TEXT ORDER: The Court is in receipt of Plaintiff's Letter advising that he has sought to comply with this Court's orders and file compliant opposition briefs. D.E. [156]. Plaintiff represents that he submitted compliant oppositions on December 15, 2025. Id. It appears that Plaintiff's submissions, however, exceed the file size limits for uploads to the docket via the ADS system. The Clerk's Office has been in communication with Plaintiff regarding the ADS system's limitations, which Plaintiff must comply with for his submissions to get docketed. Indeed, there are multiple notices on this docket instructing Plaintiff that he has not complied with the technical requirements for using ADS. See, e.g., Dkt. at November 21, 2025, November 24, 2025, November 25, 2025, December 1, 2025, December 4, 2025, December 9, 2025. And this Court has provided Plaintiff with resources to assist him in docketing his filings. See D.E. 138. Although the Court can provide Plaintiff certain allowances due to his pro se status, the Court will not consider submissions that cannot be docketed. Plaintiff must comply with the technical requirements for using ADS. The Court will extend Plaintiff's opposition deadline to January 12, 2026 and will accordingly extend Defendants' reply deadline to January 19, 2026. So Ordered by Judge Evelyn Padin on 1/9/2026. (bt)
2026-01-09
1
BRIEF in Opposition filed by AZAD ALAMGIR KABIR re [104] MOTION to Dismiss (ld)
2026-01-09
1
RESPONSE in Opposition filed by AZAD ALAMGIR KABIR re [104] MOTION to Dismiss (amv)NOTICE TO COUNSEL: Counsel is advised that pursuant to Local Civil Rule 5.3(c)(2), a single, consolidated motion to seal shall be filed within 14 days following the completed briefing of the materials sought to be sealed, or within 14 days following the date on which the last of such materials was filed under temporary seal if the motion is resolved, unless otherwise directed by the Court. Counsel are further advised that service of sealed documents must be accomplished outside of ECF as provided by Federal R. Civ. Pro. 5(b)(2) only.
2026-01-09
1
MOTION to Alter or Amend Judgment; Renewal of Motion for CM/ECF Filing Access and Request for Telephonic Conference by AZAD ALAMGIR KABIR. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H)(Received via ADS) (dam)
2026-01-10
1
NOTICE of Withdrawal of Exhibit 80 by AZAD ALAMGIR KABIR. (Received via ADS) (dam)
2026-01-11
1
NOTICE OF RECORD PRESERVATION REGARDING DOCKETING BURDENS ON PRO SE by AZAD ALAMGIR KABIR. (Received via ADS) (mj)
2026-01-12
1
MOTION to Alter or Amend Judgment; Renewal of Motion for CM/ECF Filing Access; and Request for Telephonic Conference by AZAD ALAMGIR KABIR. (amv)
2026-01-15
1
Letter from Jeffrey A. Mitchell to The Honorable Evelyn Padin, U.S.D.J. regarding the Court's Order of January 9, 2026 (ECF 157). (MITCHELL, JEFFREY)
2026-01-15
1
Letter from Wendi Opper Uzar, Esq.. (UZAR, WENDI)
2026-01-15
1
NOTICE of record preservation by AZAD ALAMGIR KABIR (Attachments: # (1) Exhibit A, # (2) Exhibit B) (RECEIVED VIA ADS)(adc, )
2026-01-15
1
LETTER from Chief Judge Bumb to Azad Kabir re ADS filings. Signed by Chief Judge Renee Marie Bumb on 1/16/2026. (lag, )
2026-01-16
1
NOTICE of Petition for Writ of Mandamus and Supplemental Filings by AZAD ALAMGIR KABIR. (Filed via ADS) (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit)(amv)
2026-01-17
1
REPLY BRIEF to Opposition to Motion filed by THOUGHTI, INC. re [104] MOTION to Dismiss (Attachments: # (1) Certificate of Service Certificate of Service)(UZAR, WENDI)
2026-01-19
1
REPLY BRIEF to Opposition to Motion filed by WEBMD LLC re [105] MOTION to Dismiss the Third Amended Complaint (MITCHELL, JEFFREY)
2026-01-20
1
Letter from Wendi Opper Uzar, Esq. re [161] MOTION. (UZAR, WENDI)
2026-01-20
1
Letter from Jeffrey A. Mitchell to The Honorable Evelyn Padin, U.S.D.J. regarding re [161] MOTION. (MITCHELL, JEFFREY)
2026-01-20
1
NOTICE of Petition of Writ of Mandamus and Supplemental Filings in the USCA by AZAD ALAMGIR KABIR (Attachments: # (1) Email) (mj)
2026-01-20
1
Letter from Jeffrey A. Mitchell to The Honorable Jessica S. Allen, U.S.M.J. re [161] MOTION. (MITCHELL, JEFFREY)
2026-01-21
1
TEXT ORDER: Despite several instructions, Plaintiff's Opposition to THOUGHTi's Motion to Dismiss, D.E. [159], does not comply with this Court's Judicial Preferences and this District's Local Rules. Plaintiff's opposition to THOUGHTi's Motion to Dismiss contains hallucinated citations. D.E. [159] at 24-25 (relying on hallucinated citation Fairfield Indus. v. EP Energy E&P Co., No. 20-2753, 2021 WL 5495573 (S.D. Tex. Nov. 22, 2021); see also D.E. [130] at 30. Plaintiff has been instructed twice that he may not include hallucinated citations in his briefing. See, e.g., D.E. [117] ("Hallucinated citations will not be excused, and the Court may sanction Plaintiff for further uses of hallucinated citations."); D.E. [138] ("The Court reiterates its previous warning that hallucinated citations will not be permitted under any circumstances."). The Court will therefore STRIKE Plaintiff's Opposition to THOUGHTi's Motion to Dismiss. Because Plaintiff has received numerous opportunities to file compliant oppositions over the past two months and has not, despite warnings that Plaintiff may suffer sanctions, the Court will consider THOUGHTi's Motion to Dismiss unopposed because Plaintiff has failed to properly respond. On the other hand, Plaintiff's Opposition to WebMD's Motion to Dismiss appears compliant. D.E. [169]. WebMD's reply, filed on 1/20/2026 is proper. So Ordered by Judge Evelyn Padin on 1/21/2026. (bt)
2026-01-21
1
NOTICE of Record Preservation and Public-Interest Disclosure regarding use of Generative and Cognitive Artificial Intelligence in Court Filings by AZAD ALAMGIR KABIR (Received via ADS) (sks)
2026-01-24
1