Defendant's motion to dismiss for lack of standing was denied notwithstanding an error in the assignment of the patent rights -- "the correct officer signed the . . . Assignment on behalf of the incorrect entity" -- that was not corrected until after suit was filed. "[T]he correct officer who signed the . . . Assignment, who was at the time an officer of [two companies], signed the assignment on behalf of the wrong entity, thereby creating a clerical error in the . . . Assignment. . . . The Court finds that [plaintiff] did have enforceable rights to the patents-in-suit when it brought this lawsuit. The Court finds that this ownership vested [plaintiff] with constitutional standing to bring this lawsuit."
Southwest Efuel Network, L.L.C. v. Transaction Tracking Technologies, Inc., 2-07-cv-00311
(TXED December 7, 2009, Memorandum Opinion & Order) (Ward, J.)