K.C. COASTAL LLC v. J&M UNDERGROUND ENGINEERING CORP.

1:25-cv-22089

Overview

Case Number 1:25-cv-22089

Filing Date 2025-05-06

Status Litigation filed

Court flsd

Nature of Suit 830 Patent

Parties

Defendant

Lolita Lobue

Represented By

2 Attorneys Listed

Maximillian Scott Matiauda

Malloy , Malloy

Tel: +1 (786) 506-1590

Malloy , Malloy, 7985 SW 86th St

Oliver Alan Ruiz

Malloy & Malloy, P.L.

Tel: +1 (305) 858-8000

Fax: +1 (305) 858-0008

Malloy & Malloy, P.L., 2800 S.W. 3rd Avenue

Devin Lobue

Represented By

2 Attorneys Listed

Maximillian Scott Matiauda

Malloy , Malloy

Tel: +1 (786) 506-1590

Malloy , Malloy, 7985 SW 86th St

Oliver Alan Ruiz

Malloy & Malloy, P.L.

Tel: +1 (305) 858-8000

Fax: +1 (305) 858-0008

Malloy & Malloy, P.L., 2800 S.W. 3rd Avenue

John Does 1-10

Represented By

0 Attorneys Listed

No attorneys available

J&M UNDERGROUND ENGINEERING CORP.

Represented By

2 Attorneys Listed

Maximillian Scott Matiauda

Malloy , Malloy

Tel: +1 (786) 506-1590

Malloy , Malloy, 7985 SW 86th St

Oliver Alan Ruiz

Malloy & Malloy, P.L.

Tel: +1 (305) 858-8000

Fax: +1 (305) 858-0008

Malloy & Malloy, P.L., 2800 S.W. 3rd Avenue

Plaintiff

K.C. COASTAL LLC

Represented By

3 Attorneys Listed

Pedro Stefan Quintana

Lewis Brisbois Bisgaard & Smith LLP

Tel: +1 (954) 678-4082

110 SE 6th Street, Suite 2600

Joshua D. Curry

Lewis Brisbois Bisgaard & Smith LLP

Tel: +1 (404) 348-8585

600 Peachtree Street NE, Suite 4700, Atlanta, GA 30308

Joseph Robert Englander

Lewis Brisbois Bisgaard & Smith LLP

Tel: +1 (954) 939-3374

110 SE 6th Street, Suite 2600

Court & Judges

Court

flsd

Patents Involved

No asserted patent numbers detected in initial docket filings yet.

Docket Entries

COMPLAINT against J&M Underground Engineering Corp. Filing fees $ 405.00 receipt number AFLSDC-18427071, filed by K.C. COASTAL LLC. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Civil Cover Sheet, # 4 Summon(s))(Englander, Joseph) Modified text to correct who this complaint is against on 5/7/2025 (jua). (Entered: 05/06/2025)

2025-05-06

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COMPLAINT against J&M Underground Engineering Corp. Filing fees $ 405.00 receipt number AFLSDC-18427071, filed by K.C. COASTAL LLC. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Civil Cover Sheet, # 4 Summon(s))(Englander, Joseph) Modified text to correct who this complaint is against on 5/7/2025 (jua). (Entered: 05/06/2025)

2025-05-06

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COMPLAINT against J&M Underground Engineering Corp. Filing fees $ 405.00 receipt number AFLSDC-18427071, filed by K.C. COASTAL LLC. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Civil Cover Sheet, # 4 Summon(s))(Englander, Joseph) Modified text to correct who this complaint is against on 5/7/2025 (jua). (Entered: 05/06/2025)

2025-05-06

View

COMPLAINT against J&M Underground Engineering Corp. Filing fees $ 405.00 receipt number AFLSDC-18427071, filed by K.C. COASTAL LLC. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Civil Cover Sheet, # 4 Summon(s))(Englander, Joseph) Modified text to correct who this complaint is against on 5/7/2025 (jua). (Entered: 05/06/2025)

2025-05-06

View

K.C. COASTAL LLC v. J&M UNDERGROUND ENGINEERING CORP.

Overview

Parties

Defendant

Lolita Lobue Follow

Represented By

Devin Lobue Follow

Represented By

John Does 1-10 Follow

Represented By

J&M UNDERGROUND ENGINEERING CORP. Follow

Represented By

Plaintiff

K.C. COASTAL LLC Follow

Represented By

Court & Judges

Patents Involved

Docket Entries

Clerk's Notice to Filer re: Electronic Case. Venue on the Civil Cover Sheet does not match the initiating document. The Clerks Office confirmed Miami-Dade (Office - Miami) as the county with the filer. It is not necessary to re-file this document. (ksr) (Entered: 05/07/2025)

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (Attachments: # 1 Complaint) (ksr). (Entered: 05/07/2025)

Summons Issued as to J&M UNDERGROUND ENGINEERING CORP.. (ksr) (Entered: 05/07/2025)

Clerk's Notice to Filer re: Electronic Case. Parties Not Added. The Filer failed to add all parties associated with the case. Filer is instructed to add the additional parties by filing a Notice of Entry of Parties. It is not necessary to re-file this document. (ksr) (Entered: 05/07/2025)

Bar Letter re: Admissions sent to attorney Joshua D. Curry, mailing date May 7, 2025, (pt) (Entered: 05/07/2025)

Clerk's Notice of Docket Correction - ELECTRONIC CASE

Clerk's Notice of Judge Assignment and Optional Consent

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): John Does 1-10. (Englander, Joseph) (Entered: 05/08/2025)

Plaintiff's Corporate Disclosure Statement by K.C. COASTAL LLC (Englander, Joseph) (Entered: 05/08/2025)

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by K.C. COASTAL LLC. J&M UNDERGROUND ENGINEERING CORP. served on 5/9/2025, response/answer due 5/30/2025. (Englander, Joseph) (Entered: 05/14/2025)

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by J&M UNDERGROUND ENGINEERING CORP.. Attorney Oliver Alan Ruiz added to party J&M UNDERGROUND ENGINEERING CORP.(pty:dft). (Attachments: # 1 Text of Proposed Order)(Ruiz, Oliver) (Entered: 05/27/2025)

PAPERLESS ORDER granting 11 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document. Defendant shall file its response to Plaintiff's Complaint on or before June 20, 2025. Signed by Judge Rodney Smith on 5/28/2025. (eps) (Entered: 05/28/2025)

Order on Motion for Extension of Time to File Response/Reply/Answer

ORDER REQUIRING JOINT SCHEDULING REPORT, CERTIFICATES OF INTERESTED PARTIES AND CORPORATE DISCLOSURE STATEMENTS Joint Scheduling Report due by 6/13/2025 Signed by Judge Rodney Smith on 6/4/2025. See attached document for full details. (ksr) (Entered: 06/05/2025)

PAPERLESS ORDER denying 14 Motion for Extension of Time. The Parties must submit a Joint Scheduling Report by June 20, 2025. Signed by Judge Rodney Smith on 6/13/2025. (eps) (Entered: 06/13/2025)

Order on Motion for Extension of Time

Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by J&M UNDERGROUND ENGINEERING CORP. (Ruiz, Oliver) (Entered: 06/20/2025)

NOTICE of Attorney Appearance by Pedro Stefan Quintana on behalf of K.C. COASTAL LLC. Attorney Pedro Stefan Quintana added to party K.C. COASTAL LLC(pty:pla). (Quintana, Pedro) (Entered: 06/20/2025)

Joint SCHEDULING REPORT - Rule 26(f) by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 06/20/2025)

Joint Election to Jurisdiction for Final Disposition of Motions . Filed by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 06/20/2025)

ANSWER and Affirmative Defenses to Complaint with Jury Demand, COUNTERCLAIM against K.C. COASTAL LLC by J&M UNDERGROUND ENGINEERING CORP.. (Attachments: # 1 Exhibit A - Photograph, # 2 Exhibit B - March 6, 2025 Correspondence)(Ruiz, Oliver) (Entered: 06/20/2025)

ORDER OF REFERRAL TO MEDIATION. Mediation Deadline 10/31/2025. Signed by Judge Rodney Smith on 6/23/2025. See attached document for full details. (ksr) (Entered: 06/23/2025)

GENERAL ORDER ON DISCOVERY OBJECTIONS AND PROCEDURES. Signed by Magistrate Judge Patrick M. Hunt on 6/24/2025. See attached document for full details. (mhr) (Entered: 06/24/2025)

Joint MOTION for Protective Order by K.C. COASTAL LLC. (Attachments: # 1 Text of Proposed Order Stipulated Protective Order, # 2 Exhibit Confidentiality Agreement and Undertaking for Receiving Confidential Information)(Quintana, Pedro) (Entered: 06/26/2025)

ORDER granting 24 Joint Motion for Confidentiality Order. Signed by Magistrate Judge Patrick M. Hunt on 6/29/2025. See attached document for full details. (mhr) (Entered: 06/29/2025)

Joint NOTICE of Mediator Selection. Selected/Added Jim Matulis as Mediator. (Quintana, Pedro) (Entered: 07/03/2025)

First AMENDED COMPLAINT against All Defendants, filed by K.C. COASTAL LLC. (Attachments: # 1 Exhibit 1 - '144 Patent, # 2 Exhibit 2 - Cease & Desist)(Quintana, Pedro) (Entered: 07/03/2025)

NOTICE of Filing Proposed Summons(es) Lolita LoBue by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 07/11/2025)

NOTICE of Filing Proposed Summons(es) Devin LoBue by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 07/11/2025)

Summons Issued as to Lolita Lobue. (cqs) (Entered: 07/11/2025)

Summons Issued as to Devin Lobue. (cqs) (Entered: 07/11/2025)

Plaintiff's MOTION TO DISMISS 20 Answer to Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM by K.C. COASTAL LLC. Responses due by 7/25/2025. (Quintana, Pedro) (Entered: 07/11/2025)

NOTICE of Acceptance of Service of Process by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 07/23/2025)

NOTICE of Acceptance of Service of Process by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 07/23/2025)

NOTICE of Attorney Appearance by Oliver Alan Ruiz on behalf of Devin Lobue, Lolita Lobue. Attorney Oliver Alan Ruiz added to party Devin Lobue(pty:dft), Attorney Oliver Alan Ruiz added to party Lolita Lobue(pty:dft). (Ruiz, Oliver) (Entered: 07/24/2025)

NOTICE of Striking 38 MOTION TO DISMISS 33 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM filed by K.C. COASTAL LLC Notice of Striking DE 38 by K.C. COASTAL LLC (Quintana, Pedro) (Entered: 08/08/2025)

PAPERLESS ORDER denying 42 Motion for Extension of Time. Signed by Judge Rodney Smith on 8/12/2025. (eps) (Entered: 08/12/2025)

Order on Motion for Extension of Time

PAPERLESS ORDER denying as moot 32 Motion to Dismiss for Failure to State a Claim. Signed by Judge Rodney Smith on 8/21/2025. (eps) (Entered: 08/21/2025)

PAPERLESS ORDER striking 38 Motion to Dismiss for Failure to State a Claim. Signed by Judge Rodney Smith on 8/21/2025. (eps) (Entered: 08/21/2025)

RESPONSE in Opposition re 39 Corrected MOTION TO DISMISS 33 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM filed by J&M UNDERGROUND ENGINEERING CORP.. Replies due by 8/28/2025. (Matiauda, Maximillian) (Entered: 08/21/2025)

Order on Motion to Dismiss for Failure to State a Claim

RESPONSE in Opposition re 41 MOTION TO DISMISS 27 Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM filed by K.C. COASTAL LLC. Replies due by 8/29/2025. (Quintana, Pedro) (Entered: 08/23/2025)

REPLY to Response to Motion re 41 MOTION TO DISMISS 27 Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM . filed by Devin Lobue, Lolita Lobue. (Matiauda, Maximillian) (Entered: 08/29/2025)

Unopposed MOTION to Seal Exhibits to Defendant/Counter-Plaintiff's Motion to Compel Discovery per Local Rule 5.4 by J&M UNDERGROUND ENGINEERING CORP.. (Attachments: # 1 Text of Proposed Order) (Matiauda, Maximillian) (Entered: 09/03/2025)

Defendant's MOTION to Compel Discovery by J&M UNDERGROUND ENGINEERING CORP.. Responses due by 9/18/2025. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit)(Matiauda, Maximillian) (Entered: 09/04/2025)

ORDER Granting 50 UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL EXHIBITS TO DEFENDANT/COUNTER-PLAINTIFF'S MOTION TO COMPEL DISCOVERY. Signed by Judge Rodney Smith on 9/5/2025. See attached document for full details. (cds) (Entered: 09/05/2025)

Order

SYSTEM ENTRY - Docket Entry 53 [misc] restricted/sealed until further notice. (2199708)

Unopposed MOTION for Extension of Time to file motion to compel discovery from JM by K.C. COASTAL LLC. Responses due by 9/29/2025. (Attachments: # 1 Text of Proposed Order)(Quintana, Pedro) (Entered: 09/15/2025)

Defendant's NOTICE of Partial Resolution of Discovery Dispute by J&M UNDERGROUND ENGINEERING CORP. re 51 Defendant's MOTION to Compel Discovery (Matiauda, Maximillian) (Entered: 09/17/2025)

Order on Motion for Extension of Time

Unopposed MOTION to Seal Certain Exhibits per Local Rule 5.4 by K.C. COASTAL LLC. (Attachments: # 1 Text of Proposed Order Proposed Order) (Quintana, Pedro) (Entered: 09/18/2025)

ORDER Granting 57 MOTION FOR LEAVE TOFILE UNDER SEAL CERTAIN EXHIBITS TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL DISCOVERY. Signed by Judge Rodney Smith on 9/19/2025. See attached document for full details. (cds) (Entered: 09/19/2025)

Order

SYSTEM ENTRY - Docket Entry 61 [misc] restricted/sealed until further notice. (1956175)

Corrected NOTICE of Partial Resolution of Discovery Dispute by J&M UNDERGROUND ENGINEERING CORP. re 56 Notice (Other) (Matiauda, Maximillian) (Entered: 09/23/2025)

Defendant's REPLY to Response to Motion re 51 Defendant's MOTION to Compel Discovery . filed by J&M UNDERGROUND ENGINEERING CORP.. (Attachments: # 1 Exhibit)(Matiauda, Maximillian) (Entered: 09/23/2025)

Joint MOTION for Extension of Time of Discovery Cutoff Deadline by J&M UNDERGROUND ENGINEERING CORP.. (Attachments: # 1 Text of Proposed Order)(Matiauda, Maximillian) (Entered: 10/03/2025)

Reset Deadlines Per DE 65 . Expert Discovery due by 11/21/2025. Fact Discovery due by 11/21/2025. (cqs)

~Util - Set/Reset Deadlines/Hearings

Order on Motion for Extension of Time of Discovery Cutoff Deadline

Lolita Lobue

Devin Lobue

John Does 1-10

J&M UNDERGROUND ENGINEERING CORP.

K.C. COASTAL LLC