DCT

1:23-cv-01173

Multifold Intl Inc Pte Ltd v. Motorola Mobility LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-01173, D. Del., 10/17/2023
  • Venue Allegations: Venue is alleged as proper based on Motorola's incorporation in Delaware and its commission of infringing acts within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s foldable and non-foldable smartphones infringe sixteen patents related to user interface software and mechanical hinge structures for multi-display devices.
  • Technical Context: The technology domain covers software for managing applications across multiple screens and the mechanical hinges that enable foldable device formats, a key area of competition in the high-end smartphone market.
  • Key Procedural History: The complaint states the Asserted Patents originated from the "Imerj project" developed by Flextronics International Ltd. (Flex), which subsequently assigned the patents to Multifold. Plaintiff alleges it provided Defendant with notice of infringement via a letter dated June 8, 2023. The complaint also alleges Defendant had pre-suit knowledge of the patented technology due to prior business dealings with Flex and citations to related patents during the prosecution of Defendant's own patent applications.

Case Timeline

Date Event
2009-01-01 Flextronics launches its "Imerj project" to design a foldable smartphone
2010-10-01 Earliest Priority Date for multiple Asserted Patents (e.g., ’053, ’577, ’153, ’494, ’335)
2010-11-16 Earliest Priority Date for O'Connor ’834 Patent
2010-11-17 Earliest Priority Date for ’080 Patent
2011-01-01 The Imerj foldable smartphone debuts
2011-09-27 Earliest Priority Date for multiple Asserted Patents (e.g., ’842, Selim '834, ’126)
2014-09-09 U.S. Patent No. 8,832,577 Issues
2014-09-16 U.S. Patent No. 8,836,842 Issues
2014-09-23 U.S. Patent No. 8,842,080 Issues
2014-10-07 U.S. Patent No. 8,854,834 (O'Connor) Issues
2014-10-28 U.S. Patent No. 8,875,050 Issues
2014-11-04 U.S. Patent No. 8,881,053 Issues
2015-06-16 U.S. Patent No. 9,058,153 Issues
2015-09-15 U.S. Patent No. 9,134,756 Issues
2015-09-22 U.S. Patent No. 9,141,135 Issues
2015-09-29 U.S. Patent No. 9,146,589 Issues
2015-10-13 U.S. Patent No. 9,158,494 Issues
2015-11-24 U.S. Patent No. 9,195,335 Issues
2016-04-12 U.S. Patent No. 9,310,834 (Selim) Issues
2017-05-30 U.S. Patent No. 9,665,126 Issues
2017-08-08 U.S. Patent No. 9,727,205 Issues
2017-10-17 U.S. Patent No. 9,792,007 Issues
2019-01-01 Accused Product Motorola Razr (2019) launched
2022-01-01 Accused Products Motorola Edge (2022) and Razr (2022) launched
2023-06-08 Plaintiff sends notice letter to Defendant's parent company, Lenovo
2023-10-17 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,836,842 - “CAPTURE MODE OUTWARD FACING MODES,” Issued 09/16/2014

The Invention Explained

  • Problem Addressed: The patent describes multi-screen handheld devices and notes that the balancing act between providing display content and receiving user commands is "particularly difficult for single display touch screen devices" (Compl. ¶67; '842 Patent, col. 1:42-45). This implies a need for more versatile user interface configurations that leverage multiple screens.
  • The Patented Solution: The invention is a method for a dual-screen device to manage its image capture (camera) function by adapting the display based on the device's physical state ('842 Patent, Abstract). The device determines its configuration (e.g., open, closed, easel), its orientation (e.g., portrait, landscape), and the selected camera settings, and then enters a specific "image capture mode" where the camera application is displayed differently on the first or second screen to suit that context ('842 Patent, col. 6:53-61). This allows, for example, an outward-facing screen to act as a viewfinder when the device is closed, enabling the use of the main camera for self-portraits.
  • Technical Importance: This approach enhances the usability of foldable smartphones by allowing the device's main, typically higher-quality, camera system to be used for self-portraits, utilizing the external screen as a viewfinder—a key functional advantage over single-screen devices (Compl. ¶64, ¶66).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶91).
  • Claim 1 is a method claim comprising the essential elements of:
    • providing a device having at least first and second screens;
    • receiving user interface input to execute an image capture function;
    • determining one or more of an image capture function configuration, a device orientation, and a device state; and
    • based on one or more of those determinations, entering one of one or more image capture modes, wherein in each mode a display on the first or second screen is different.
  • The complaint explicitly reserves the right to assert additional claims (Compl. ¶91, fn. 1).

U.S. Patent No. 8,881,053 - “MODAL LAUNCHING,” Issued 11/04/2014

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of managing user interactions on multi-display devices, particularly when a primary application is running across both screens and a secondary or "modal" window (like a settings menu or a media controller) needs to be displayed without completely disrupting the primary application's context ('053 Patent, col. 1:24-41).
  • The Patented Solution: The invention is a method for handling "modal launching" on a dual-display device. When a multi-screen application is displayed across both screens, and a user provides an input to launch a modal (or child) window, the system displays that modal window on a selected one of the screens. Concurrently, the original multi-screen application's window is automatically "minimized" to be displayed only on the non-selected screen, thereby preserving its context while giving focus to the modal window ('053 Patent, Abstract; col. 2:54-62).
  • Technical Importance: This method provides a more fluid multitasking experience on dual-screen devices by preventing modal dialogs or controls from completely obscuring a parent application, a common issue in single-screen user interfaces (Compl. ¶64, ¶66).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶104).
  • Claim 1 is a method claim comprising the essential elements of:
    • displaying a window of a multi-screen application on at least a portion of a first display and a second display;
    • receiving input that results in launching a modal window;
    • in response, displaying the modal window on a selected one of the first or second displays; and
    • wherein the window of the multi-screen application is minimized to be displayed on the non-selected one of the displays.
  • The complaint explicitly reserves the right to assert additional claims (Compl. ¶104, fn. 2).

U.S. Patent No. 9,134,756 - “DUAL SCREEN APPLICATION VISUAL INDICATOR,” Issued 09/15/2015

  • Patent Identification: 9,134,756, “DUAL SCREEN APPLICATION VISUAL INDICATOR,” Issued 09/15/2015 (Compl. ¶15).
  • Technology Synopsis: The patent addresses the user interface challenge of managing applications on a multi-display device. The invention describes a method where a user can display two separate applications or desktops, one on each screen, and then receive a third input to maximize one of them to span both displays in a "maximized condition" (’756 Patent, Abstract; col. 2:24-34).
  • Asserted Claims: At least Claim 1 (Compl. ¶117).
  • Accused Features: The "split screen" functionality in both Accused Foldable and Flat Smartphone Products that allows displaying two different applications on the device's screen(s) and then maximizing one of them (Compl. ¶119-121).

U.S. Patent No. 9,310,834 - “FULL SCREEN MODE,” Issued 04/12/2016

  • Patent Identification: 9,310,834, “FULL SCREEN MODE,” Issued 04/12/2016 (Compl. ¶18).
  • Technology Synopsis: This invention relates to presenting media on a portable device with two screens. It describes a method to selectively display media along with a status bar and action bar, then dismiss those bars upon a prompt to enter a "full screen mode," and subsequently display an overlay control to re-introduce the bars while the media remains displayed ('Selim '834 Patent, Abstract).
  • Asserted Claims: At least Claim 15 (Compl. ¶131).
  • Accused Features: The functionality in the Accused Foldable Smartphone Products that allows a user to display media (e.g., video), enter a full-screen mode that hides the navigation and status bars, and then tap the screen to bring up overlay controls that re-display those bars (Compl. ¶134).

U.S. Patent No. 8,854,834 - “DUAL SCREEN FOLDING DISPLAY HINGE,” Issued 10/07/2014

  • Patent Identification: 8,854,834, “DUAL SCREEN FOLDING DISPLAY HINGE,” Issued 10/07/2014 (Compl. ¶21).
  • Technology Synopsis: The patent addresses mechanical drawbacks of conventional hinges on folding devices, such as protruding elements and discontinuities between screens (O'Connor '834 Patent, col. 1:23-29). The invention is a device for forming a joined display using a core member, two movable members, and a "detaining member" with an elastic element and cams to selectively hold the movable members at predefined locations, allowing for a continuous display when open (O'Connor '834 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶144).
  • Accused Features: The "teardrop hinge" mechanism in the Accused Foldable Smartphone Products, which is alleged to have a core member, movable members (screens), and a detaining member that allows the screens to be held at specific angles (Compl. ¶147).

U.S. Patent No. 9,665,126 - “DUAL SCREEN FOLDING DISPLAY HINGE,” Issued 05/30/2017

  • Patent Identification: 9,665,126, “DUAL SCREEN FOLDING DISPLAY HINGE,” Issued 05/30/2017 (Compl. ¶24).
  • Technology Synopsis: Similar to the O'Connor '834 patent, this invention describes a method of forming a joined screen display. The method involves forming a body with rotatable members, attaching screens to them, and using a detaining member with an elastic element and cams to selectively hold the screens at predefined locations until they form a substantially continuous display ('126 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶155).
  • Accused Features: The method of manufacturing and operating the hinge in the Accused Foldable Smartphone Products, which allegedly involves forming a body with rotatable members and a detaining mechanism to allow the screens to form a single contiguous display (Compl. ¶158).

U.S. Patent No. 8,842,080 - “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” Issued 09/23/2014

  • Patent Identification: 8,842,080, “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” Issued 09/23/2014 (Compl. ¶27).
  • Technology Synopsis: The patent discloses a method for controlling a handheld device by displaying an application in a first state with a corresponding icon. Upon receiving a gesture, the application's display is modified to a second state, and the icon "morphs" (changes shape and size) to indicate the new state ('080 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶168).
  • Accused Features: Functionality in the Accused Products where an application displayed on a portion of the screen shows an icon (e.g., a maximize icon), and when a user taps it, the application expands to fill more of the screen and the icon changes to indicate the new maximized state (e.g., becomes a minimize icon) (Compl. ¶171-172).

U.S. Patent No. 9,727,205 - “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” Issued 08/08/2017

  • Patent Identification: 9,727,205, “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” Issued 08/08/2017 (Compl. ¶30).
  • Technology Synopsis: This patent describes a method for a handheld device with two viewable displays. An application is shown on the first display with an associated icon. In response to an input, the application is modified to display over both screens, and the size of the icon changes to indicate this modification (’205 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶182).
  • Accused Features: The functionality in Accused Foldable Smartphone Products where tapping an icon on one display maximizes an application to span both displays, which allegedly causes the icon's size to change (Compl. ¶185).

U.S. Patent No. 9,058,153 - “MINIMIZING APPLICATION WINDOWS,” Issued 06/16/2015

  • Patent Identification: 9,058,153, “MINIMIZING APPLICATION WINDOWS,” Issued 06/16/2015 (Compl. ¶33).
  • Technology Synopsis: This invention covers a method for managing two applications on a dual-display device. A first multi-display application is shown on both screens. When an input is received to launch a second application, the second application is displayed on the second display, and the first application is automatically minimized to fit only on the first display ('153 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶195).
  • Accused Features: The "split screen" functionality in the Accused Products, where opening a second application allegedly causes a first, already-open application to be automatically minimized to one display while the second application opens on another (Compl. ¶198-199).

U.S. Patent No. 8,875,050 - “FOCUS CHANGE UPON APPLICATION LAUNCH,” Issued 10/28/2014

  • Patent Identification: 8,875,050, “FOCUS CHANGE UPON APPLICATION LAUNCH,” Issued 10/28/2014 (Compl. ¶36).
  • Technology Synopsis: The patent discloses a method for managing focus between two applications on separate screens. A first application is in focus on a first screen with its input options displayed. Upon receiving an input to launch a second application, the second application is launched and displayed on a second screen, and the "focus" changes to the second application, causing its input options to be displayed while the first application's input options are no longer displayed (’050 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶209).
  • Accused Features: Functionality in Accused Foldable Smartphone Products where launching a second application on a second screen allegedly causes the system to shift focus, displaying input options (e.g., a navigation bar) for the second application while hiding them for the first (Compl. ¶212).

U.S. Patent No. 9,792,007 - “FOCUS CHANGE UPON APPLICATION LAUNCH,” Issued 10/17/2017

  • Patent Identification: 9,792,007, “FOCUS CHANGE UPON APPLICATION LAUNCH,” Issued 10/17/2017 (Compl. ¶39).
  • Technology Synopsis: This patent is related to the '050 patent and describes a similar method of changing focus between two applications on a multi-display device. It adds the limitation that the "configurable areas" displaying input options do not display content from an application (’007 Patent, Claim 1).
  • Asserted Claims: At least Claim 1 (Compl. ¶222).
  • Accused Features: The same focus-shifting functionality accused of infringing the '050 Patent, with the additional allegation that the configurable areas (e.g., navigation bars) do not display application content (Compl. ¶225-226).

U.S. Patent No. 9,141,135 - “FULL-SCREEN ANNUNCIATOR,” Issued 09/22/2015

  • Patent Identification: 9,141,135, “FULL-SCREEN ANNUNCIATOR,” Issued 09/22/2015 (Compl. ¶42).
  • Technology Synopsis: This invention describes a method for displaying an "annunciator window" (e.g., a status bar) across both displays of a multi-display device. The annunciator window shows device status information and is configured to extend across portions of both displays without degrading the applications displayed below it (’135 Patent, Claim 1).
  • Asserted Claims: At least Claim 1 (Compl. ¶236).
  • Accused Features: The status bar or notification bar in the Accused Products that, when two applications are displayed, allegedly extends across the top of both displays to show information like battery life and connectivity status (Compl. ¶239-240).

U.S. Patent No. 8,832,577 - “UNIVERSAL CLIPBOARD,” Issued 09/09/2014

  • Patent Identification: 8,832,577, “UNIVERSAL CLIPBOARD,” Issued 09/09/2014 (Compl. ¶45).
  • Technology Synopsis: The patent discloses a method for a "universal clipboard" on a multi-screen device. Content is copied from a first application, and a clipboard application on a second screen displays the copied item. A user can then select the item from the second screen and paste it into a second application on the first screen ('577 Patent, Claim 1).
  • Asserted Claims: At least Claim 1 (Compl. ¶250).
  • Accused Features: The "Gboard" clipboard application in the Accused Foldable Smartphone Products, which allegedly allows a user to copy content, open the clipboard on a second screen, and paste the content into a different application (Compl. ¶253).

U.S. Patent No. 9,146,589 - “IMAGE CAPTURE DURING DEVICE ROTATION,” Issued 09/29/2015

  • Patent Identification: 9,146,589, “IMAGE CAPTURE DURING DEVICE ROTATION,” Issued 09/29/2015 (Compl. ¶48).
  • Technology Synopsis: This patent describes a method of presenting a display for an image capture function that changes based on the device's physical state, display mode, and orientation. When the device's orientation changes (is rotated), the display for the image capture function changes accordingly (’589 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶263).
  • Accused Features: The camera application in the Accused Foldable Smartphone Products, which allegedly presents different displays based on device state (open/closed), display mode, and orientation (portrait/landscape), and changes the display when the user rotates the device (Compl. ¶266).

U.S. Patent No. 9,158,494 - “MINIMIZING AND MAXIMIZING BETWEEN PORTRAIT DUAL DISPLAY AND PORTRAIT SINGLE DISPLAY,” Issued 10/13/2015

  • Patent Identification: 9,158,494, “MINIMIZING AND MAXIMIZING BETWEEN PORTRAIT DUAL DISPLAY AND PORTRAIT SINGLE DISPLAY,” Issued 10/13/2015 (Compl. ¶51).
  • Technology Synopsis: The invention is a method for controlling a dual-screen device where an application presents a primary page on one screen and an auxiliary (child) page on another. In response to an input to minimize the application, the auxiliary page is dismissed, and only the primary page remains displayed on one of the screens ('494 Patent, Claim 1).
  • Asserted Claims: At least Claim 1 (Compl. ¶276).
  • Accused Features: Functionality in the Accused Foldable Smartphone Products, such as the Gallery app, where a primary page (video) is shown on one screen and an auxiliary page (video controls) is on another. Selecting "split screen" allegedly dismisses the auxiliary page and shows only the primary page (Compl. ¶279).

U.S. Patent No. 9,195,335 - “MODAL LAUNCHING,” Issued 11/24/2015

  • Patent Identification: 9,195,335, “MODAL LAUNCHING,” Issued 11/24/2015 (Compl. ¶54).
  • Technology Synopsis: This patent is a continuation of the '053 patent, covering a similar method for launching a modal window over a multi-display application. When the modal window is opened on one display, the underlying application is minimized to the other display ('335 Patent, Claim 1).
  • Asserted Claims: At least Claim 1 (Compl. ¶289).
  • Accused Features: The same functionality accused of infringing the '053 patent, where opening a modal window (e.g., video controls) on one display minimizes the parent application (e.g., Gallery) to the other display using the "split screen" feature (Compl. ¶292).

III. The Accused Instrumentality

Product Identification

  • The complaint names two categories of accused products:
    • Accused Foldable Smartphone Products: Including the Motorola Razr (2019), Razr 5G, Razr (2022), Razr (2023), and Razr+ (2023) (Compl. ¶70).
    • Accused Flat Smartphone Products: Including the Motorola Edge (2022), Edge+ (2022), Edge 30 Fusion, Edge (2023), Edge+ (2023), and various Moto G models (Compl. ¶71).

Functionality and Market Context

  • The complaint targets core user interface and mechanical functionalities of Motorola's modern smartphones. For the foldable devices, allegations center on both the software that manages applications across internal and external screens and the physical "teardrop hinge" mechanism that enables folding and positioning at various angles (Compl. ¶94, ¶147). For both foldable and flat smartphones, allegations target multitasking software features, commonly marketed as "split screen," which allow for the simultaneous display and management of multiple applications (Compl. ¶107, ¶120-121). The complaint asserts that these features are central to the usability and versatility of the accused devices (Compl. ¶66).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'842 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method, comprising: providing a device having at least first and second screens; The Accused Foldable Smartphone Products are alleged to have a first inner screen and a second outer screen. ¶94 col. 6:49-50
receiving user interface input to execute an image capture function; The device's processor is alleged to receive user input to open the camera application. ¶94 col. 6:51-52
determining one or more of an image capture function configuration, a device orientation, and a device state; and The processor allegedly determines the camera application's configuration, the device's physical orientation (e.g., portrait or landscape), and its physical state (e.g., open, closed, or folded). ¶94 col. 6:53-56
based on one or more of the image capture function configuration, the device orientation, and the device state, entering one of one or more image capture modes, wherein in each image capture mode a display on the first or second screen is different. Based on the determined factors, the device allegedly enters different camera modes, causing the camera application to display differently on the inner or outer screen. ¶94 col. 6:57-61

'053 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method, comprising: displaying a window of a multi-screen application on at least a portion of a first display of a first screen and at least a portion of a second display of a second screen; The Accused Foldable Smartphone Products are alleged to be capable of displaying a multi-screen application, such as the Gallery app, across both a first and second display. ¶107 col. 2:54-57
receiving input that result in launching a modal window; A user can provide input to launch a modal window, such as the video controls for the Gallery application. ¶107 col. 2:58
in response to the input, displaying, on a selected one of the first display or the second display, a modal window; and The device allegedly displays the modal window on either the first or second screen. ¶107 col. 2:59-60
wherein the window of the multi-screen application is minimized to be displayed on the non-selected one of the first display or the second display. The device's "split screen" feature allegedly minimizes the main application window to the screen not occupied by the modal window. ¶107 col. 2:61-64

Identified Points of Contention

  • Scope Questions: Several claims, such as Claim 1 of the '053 Patent, recite a "multi-screen application." The complaint alleges infringement by features of the operating system (e.g., "split screen") acting on standard applications (e.g., "Gallery application") (Compl. ¶107). This raises the question of whether the claimed "multi-screen application" is a single, specially-coded piece of software, or if it can be read to cover the combination of a standard application and system-level window management features.
  • Technical Questions: For the '842 Patent, the complaint alleges infringement based on the camera application displaying "differently" based on device state (Compl. ¶94). The central technical question will be whether the alleged differences in the accused products' camera UI meet the specific "different" display requirements for each "image capture mode" as defined and enabled by the patent's specification.

V. Key Claim Terms for Construction

For the ’842 Patent

  • The Term: "device state"
  • Context and Importance: This term is central to Claim 1, as the entry into different image capture modes is conditioned upon it. The complaint alleges states such as "open, closed, or folded" (Compl. ¶94). The patent specification illustrates numerous states, including "easel" and "modified easel" ('842 Patent, FIG. 3A). The construction of this term will determine whether the full range of physical configurations of the accused foldable phones, including partially open or "tent" modes, are covered by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of potential states in a state model diagram (FIG. 3A), suggesting that "device state" is a general concept referring to the device's physical configuration, which could support a broad reading.
    • Evidence for a Narrower Interpretation: The detailed description links specific states to specific functionalities (e.g., "The 'closed' position can also be a preferred position for utilizing the device 100 as a mobile phone.") ('842 Patent, col. 8:64-67). This may support an argument that only the explicitly described states with associated functions fall within the term's intended scope.

For the ’053 Patent

  • The Term: "modal window"
  • Context and Importance: The claim requires launching a "modal window" which then causes the parent application to be minimized. The complaint identifies "the video controls of the Gallery application" as an example of an accused "modal window" (Compl. ¶107). Practitioners may focus on whether these integrated controls, which appear as an overlay within the same application, meet the definition of a distinct "window" that is "launched" as required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent defines a "modal window" as a "child (secondary window) to a parent window" that "usurps the parent's control" ('053 Patent, col. 5:32-35). This functional definition could be argued to cover any user interface element, like on-screen controls, that temporarily takes user focus from the main application view.
    • Evidence for a Narrower Interpretation: The term "window" itself, in the context of operating systems, often implies a distinct, separately managed graphical container. A defendant might argue that simple overlay controls are not a "window" in this technical sense and that the claim requires launching a more formally distinct UI element, such as a system-level pop-up dialog.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges inducement of infringement against users of the Accused Products. The basis for this allegation is that Motorola provides instructions, directions, and marketing materials through its websites and user support channels that allegedly encourage and instruct users to operate the products in an infringing manner (Compl. ¶98, ¶111).

Willful Infringement

  • Willfulness is alleged based on both pre- and post-suit knowledge. Pre-suit knowledge is alleged to stem from a notice letter sent to Motorola's parent company on June 8, 2023, as well as Motorola's alleged awareness of the originating "Imerj project" and the citation of related patents during the prosecution of Motorola's own patents (Compl. ¶79-86). Post-suit willfulness is alleged based on continued infringement after the filing of the complaint (Compl. ¶89).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can terms rooted in traditional graphical user interfaces, such as "modal window" ('053 Patent) and "multi-screen application" ('153 Patent), be construed to cover the integrated, feature-based functionalities of a modern mobile operating system, such as overlay media controls or native split-screen capabilities?
  • A key evidentiary question for the hardware-focused patents will be one of mechanical operation: what evidence will be presented to show that the internal components of Motorola's "teardrop hinge" function as the specific "core member", "cams", and "elastic element" described in the O'Connor '834 patent, versus operating as a mechanically distinct, non-infringing alternative?
  • A central question for willfulness and damages will be one of imputed knowledge: can Plaintiff demonstrate that Defendant's general awareness of a patent portfolio and citation of related patents during its own prosecution constitutes the specific, pre-suit knowledge of the sixteen Asserted Patents required to establish willful infringement prior to the date of the formal notice letter?