Ibanez

I. BACKGROUND

18 Mr. Ibanez filed this case on August 16, 2024, alleging infringement of U.S. Patent 19 Application 18/761,178 (“’178 Application”). See ECF No. 1 (“Compl.”). The ’178 Application 20 allegedly describes an apparatus for producing “Commercial Power and Commercial Water from 21 oceanwater using Electrolysis, Steam Boilers, Desalination and Distillation” in which the 22 apparatus is powered by “HUNDRED PLUS BIKES TO ROTATE 1000megawatt Dynamo.” 23 Compl. at 3–4. Mr. Ibanez alleges that this Court has subject matter jurisdiction under 35 U.S.C. 24 § 261, which “protects an inventor’s right to assign his Patent Application, even before [the] 25 patent is granted.” Compl. at 4. Mr. Ibanez further alleges Defendants Electric Hydrogen Co. and 26 Electric Hydrogen Manufacturing have “mechanical facilities” in this district “that closely 27 resemble the mechanical operations that are CLAIMS in Plaintiff’s . . . on-going and abandoned patent applications.” Compl. at 2. More specifically, Plaintiff alleges that “Defendants have copied [] Claim One, Claim Two and Claim Three” of the ’178 Application. Id. at 3. The ’178 Application is not publicly…