Lynk Labs, Inc. v. Home Depot USA, Inc., 1:21-cv-05021

Lynk Labs, Inc. sued Home Depot entities alleging infringement of eight patents related to lighting products; later amended to add a ninth patent.
Case was transferred to the Northern District of Georgia from the Western District of Texas.
Litigation was stayed to allow inter partes review (IPR) and post-grant review (PGR) of the asserted patents.
All asserted claims from the patents-in-suit were either invalidated or disposed of by the IPR/PGR process.
Lynk Labs sought to amend its infringement contentions to assert new claims not previously at issue.
The court evaluated whether such amendment, after completion of lengthy discovery and review, was timely under federal procedure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiff may supplement/amend infringement contentions to assert new patent claims after IPR/PGR and close of discovery	Lynk Labs argued supplementation was permitted, referencing local rules and differences between districts	Home Depot argued supplementation was untimely and improper given the stage of litigation and full disposition of all asserted claims	The Court held Plaintiff’s proposed supplement was untimely and exclusion of the new claims was required
Whether exclusion of Plaintiff's supplemental contentions mandates summary judgment for Defendants	N/A (Plaintiff focused on allowing amendment)	Defendants asserted exclusion resolved all pending claims and entitled them to summary judgment	The Court signaled summary judgment was likely unless Plaintiff could show cause otherwise

Rigby v. Philip Morris USA Inc., 717 F. App’x 834 (11th Cir. 2017) (supplements after discovery close are generally untimely)
Jama v. City & Cty. of Denver, 304 F.R.D. 289 (D. Colo. 2014) (duty to supplement when responses become incomplete)
L.A. v. Riverside Mil. Acad. Found., Inc., 2:18-CV-00215-RWS (N.D. Ga. 2021) (timeliness depends on circumstances and policy of meaningful discovery)