On Monday, I wrote about how the Court had refused to entertain a stipulated dismissal until the plaintiff's attorney filed a pro hac motion.
I wanted to provide an update. From the docket, it looks like the case has resolved. On Friday, the plaintiff filed an ordinary pro hac motion. The Court granted it this morning (Tuesday), without any issue, and then granted the stipulated dismissal. See Secure Matrix LLC v. Dress Barn Omni, Inc., C.A. No. 25-1530-CFC, D.I. 15 (D. Del. Feb. 4, 2026).
The Court did not require the parties to file a new stipulation, or to take any action beyond the filing of the pro hac motion.
On Friday, in Secure Matrix LLC v. Dress Barn Omni, Inc., C.A. No. 25-1530-CFC (D. Del.), Chief Judge Connolly ordered that the Court will not be considering a stipulated dismissal with prejudice of a patent action until the plaintiff files, and the Court rules on, a pro hac motion for the plaintiff's attorney:
ORAL ORDER: The Court is not willing to entertain the parties' proposed stipulation before [plaintiff's attorney]'s "forthcoming" pro hac vice motion is filed and ruled upon. Ordered by Judge Colm F. Connolly on 1/30/2026. (mws) (Entered: 01/30/2026)
Writing a blog can be a bit like real journalism. More often it's a tedious exercise in easy jokes that amuse only the author, but, sometimes, there's a bit of sneaky sleuthing involved.
You tell me why he has human hands.AI-Generated, displayed with permission
For those who don't click links, the pro hac at issue was for an attorney involved in several of the infamous Mavexar cases. Judge Connolly issued sua sponte orders setting a hearing on the pro hac motion and requiring the attorney in question to submit "a sworn declaration in which he (1) …
This was meant to be more "Jaws" and less "get off my lawn you dang kids" but I can't be bothered to mess with the prompt anymore. A reminder that we are currently accepting applications for the official IP/DE cartoonistAI-Generated, displayed with permission
Today's strand in the tale is an abject lesson in the way certain cases can follow you around for years after they've ostensibly died. It comes to us by way of a pro hac motion, of all things. Filed without fanfare and totally unopposed, one would have expected it to be granted within a day or so.
Things went a little differently in WirelessWerx IP, LLC v. Tracki Inc., C.A. No. 25-799-CFC (D. Del. Oct. 17, 2025) where an unopposed pro hac motion sat dormant for a full 11 days until the Court issued this ominous Oral Order:
So that the Court may properly consider Plaintiff's application for the pro hac admission of William Ramey, it is HEREBY ORDERED that Mr. Ramey shall file with the Court no later than October 31, 2025 a sworn declaration in which he (1) identifies all the cases he has participated in or is currently participating in as counsel of record in this District and (2) avers whether he has ever been found by a court or state bar disciplinary body to have violated a rule, order, code, or norm of professional conduct. If Mr. Ramey has been found by a court or state bar disciplinary body to have violated a rule, order, code, or norm of professional conduct, he shall identify in the declaration the court or disciplinary body as the case may be and the date and nature of the finding and he shall submit with the declaration a copy of any order, opinion, or other document issued by the court or state bar disciplinary body in connection with that finding.
This is the first time I've seen an order like this. Me being a reporter (sorta), I looked to see what the lawyer's history was in the district. Unsurprisingly, an old Mavexar case popped up.
Counsel in question represented plaintiffs in a series of cases around the time of the Mavexar hearings, including Missed Call, LLC v. Freshworks Inc., C.A. No. 22-739-CFC. In that case, counsel failed to attend a scheduled in-person hearing. This led Chief Judge Connolly to order ...
One of the better known quirks of Delaware practice is the requirement of association with "Delaware Counsel." This requirement is more stringent than any other jurisdiction that I know of, requiring a Delaware lawyer to sign and file all papers in the action:
Association with Delaware counsel required. Unless otherwise ordered, an attorney not admitted to practice by the Supreme Court of the State of Delaware may not be admitted pro hac vice in this Court unless associated with an attorney who is a member of the Bar of this Court and who maintains an office in the District of Delaware for the regular transaction of business (“Delaware counsel”). Consistent with CM/ECF Procedures, Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Unless otherwise ordered, Delaware counsel shall attend proceedings before the Court.
Last month, we wrote about out-of-town co-counsel who the Court suggested may have mis-handled confidential information. The out-of-town counsel failed to appear for a hearing about the incident back in May.
Afterwards, opposing counsel requested sanctions including revocation of his pro hac admission, the out-of-town counsel withdrew hispro hac appearance. Since his withdrawal in May, the case has been re-assigned to Judge Williams, and Court had been quiet on this issue—suggesting perhaps he had successfully skirted any sanctions by mooting the relief.
Shortly after the withdrawal, the party got new Delaware counsel, and the previous Delaware counsel (who had to defend the failure to appear) withdrew. …
This blog is for general informational purposes. It is not an offer to perform legal services, and should not be considered a substitute for legal advice. Nothing in this blog should be construed as forming an attorney-client relationship. If you have legal questions, please consult counsel in your jurisdiction.
