DCT

1:23-cv-01323

Multifold Intl Inc Pte Ltd v. Google LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-01323, D. Del., 11/17/2023
  • Venue Allegations: Venue is alleged in the District of Delaware because Google is a Delaware corporation that resides in the district and has allegedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s foldable and non-foldable smartphones, including the Pixel Fold and Pixel 5 through 8 series, infringe sixteen patents related to user interfaces and hardware for multi-screen and foldable devices.
  • Technical Context: The technology at issue addresses user interface and mechanical challenges in multi-screen and foldable smartphones, a growing segment of the mobile device market focused on increasing screen real estate and multitasking capabilities.
  • Key Procedural History: The asserted patents are alleged to have originated from the "Imerj project," an early foldable smartphone initiative launched in 2009. The complaint alleges that Plaintiff sent a letter to Defendant on June 8, 2023, providing pre-suit notice of infringement by the Google Pixel Fold product, specifically identifying at least claim 1 of each of the sixteen Asserted Patents.

Case Timeline

Date Event
2009-01-01 Flextronics launches the Imerj project to design a foldable smartphone
2010-10-01 Earliest Priority Date ('577, '080, '205, Selim '834 Patents)
2010-11-16 Priority Date ('O'Connor '834, '126 Patents)
2011-01-01 Imerj foldable smartphone debut
2011-09-27 Priority Date ('842 Patent)
2011-09-28 Priority Date ('756, '153, '135 Patents)
2011-09-29 Priority Date ('050, '007, '335 Patents)
2012-02-06 Priority Date ('494 Patent)
2012-09-26 Priority Date ('589 Patent)
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
2023-06-08 Plaintiff sends pre-suit notice letter to Defendant
2023-11-17 Complaint Filing Date

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

U.S. Patent No. 8,836,842 - CAPTURE MODE OUTWARD FACING MODES

  • Patent Identification: U.S. Patent No. 8,836,842, “CAPTURE MODE OUTWARD FACING MODES,” issued September 16, 2014.

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of designing user interfaces for handheld computing devices, noting that the "small form factor" creates "a careful balancing between the displayed graphics and the area provided for receiving inputs" (’842 Patent, col. 1:24-28). This problem is particularly acute for single-display devices (’842 Patent, col. 1:33-35).
  • The Patented Solution: The invention is a method for a dual-screen device to manage its camera functions by automatically entering different image capture modes. The mode is selected based on a determination of the device’s physical state (e.g., open or closed), its orientation (e.g., portrait or landscape), and the camera's configuration, which results in a different display being presented on the first or second screen for each mode (’842 Patent, Abstract; col. 2:6-14).
  • Technical Importance: This technology allows for more versatile camera use on dual-screen devices, enabling distinct user interfaces tailored for different photographic scenarios, such as self-portraits versus standard picture-taking (Compl. ¶66-67).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶87).
  • Essential elements of Claim 1:
    • A method, comprising:
    • 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 the determined factors, entering an image capture mode where the display on the first or second screen is different.
  • The complaint reserves the right to assert additional claims (Compl. p. 14, n.1).

U.S. Patent No. 8,881,053 - MODAL LAUNCHING

  • Patent Identification: U.S. Patent No. 8,881,053, “MODAL LAUNCHING,” issued November 4, 2014.

The Invention Explained

  • Problem Addressed: The complaint does not provide sufficient detail for analysis of the problem addressed in the patent's background.
  • The Patented Solution: The invention is a method for managing application windows on a multi-screen device. When a "multi-screen application" is displayed across two screens, an input can launch a "modal window" (e.g., a child window). In response, the modal window is displayed on one of the screens, while the original multi-screen application window is automatically minimized to be displayed on the non-selected screen (Compl. ¶101, 103).
  • Technical Importance: This approach improves multitasking on dual-screen devices by allowing a user to interact with a focused, temporary sub-window (a modal window) without completely losing the context of the main application, which remains visible on the other screen (Compl. ¶64-65).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶100).
  • Essential elements of Claim 1:
    • A method, comprising:
    • 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 to the input, displaying the modal window on a selected one of the displays; and
    • wherein the multi-screen application window is minimized to be displayed on the non-selected display.
  • The complaint reserves the right to assert additional claims (Compl. p. 18, n.2).

Multi-Patent Capsule: U.S. Patent No. 9,134,756

  • Patent Identification: U.S. Patent No. 9,134,756, “DUAL SCREEN APPLICATION VISUAL INDICATOR,” issued September 15, 2015 (Compl. ¶15).
  • Technology Synopsis: The patent describes a method for managing applications on a multi-display device. It involves receiving separate inputs to select and display applications on first and second displays, and then receiving a third input to maximize one of the applications to be displayed across both screens (Compl. ¶114).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶113).
  • Accused Features: The accused functionality includes displaying different applications on separate displays of a multi-display device and then maximizing a selected application to span both displays in response to user input (Compl. ¶116-117).

Multi-Patent Capsule: U.S. Patent No. 9,310,834 (Selim '834 Patent)

  • Patent Identification: U.S. Patent No. 9,310,834, “FULL SCREEN MODE,” issued April 12, 2016 (Compl. ¶18).
  • Technology Synopsis: The patent claims a method of presenting media on a portable device with two screens. The method involves dismissing a status bar and action bar to display media in a full-screen mode, and then displaying an overlay control that, when actuated, re-introduces the status and action bars (Compl. ¶128).
  • Asserted Claims: At least independent claim 15 is asserted (Compl. ¶127).
  • Accused Features: The accused functionality involves the ability to enter a full-screen mode for media (e.g., video), which dismisses status and navigation bars, and then to re-display those bars by providing input, such as tapping the screen to bring up an overlay control (Compl. ¶130).

Multi-Patent Capsule: U.S. Patent No. 8,854,834 (O'Connor '834 Patent)

  • Patent Identification: U.S. Patent No. 8,854,834, “DUAL SCREEN FOLDING DISPLAY HINGE,” issued October 7, 2014 (Compl. ¶21).
  • Technology Synopsis: This patent is directed to the mechanical structure of a foldable device. It claims a device with a core member (hinge), first and second movable members (screens), and a detaining member with an elastic element and cams that can hold the movable members at pre-defined locations, forming a single continuous display when fully opened (Compl. ¶141).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶140).
  • Accused Features: The accused instrumentality is the hinge mechanism of the Accused Foldable Smartphone Products, which allegedly includes a core member, two movable members with screens, and a detaining mechanism with a spring and cam that allows the device to be held in various positions (e.g., fully open, fully closed, partially folded) (Compl. ¶143).

Multi-Patent Capsule: U.S. Patent No. 9,665,126

  • Patent Identification: U.S. Patent No. 9,665,126, “DUAL SCREEN FOLDING DISPLAY HINGE,” issued May 30, 2017 (Compl. ¶24).
  • Technology Synopsis: This patent claims a method of forming a joined screen display. The method involves forming a body with rotatable members that have screens, and a detaining member with an elastic element and cams to selectively hold the rotatable members at pre-defined locations to form a substantially continuous display (Compl. ¶152).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶151).
  • Accused Features: The accused act is the method of forming the joined screen display in the Accused Foldable Smartphone Products by rotatably moving two screens around an inner hinge, using a detaining member with a spring and cam to hold the screens at specific angles (Compl. ¶154).

Multi-Patent Capsule: U.S. Patent No. 8,842,080

  • Patent Identification: U.S. Patent No. 8,842,080, “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” issued September 23, 2014 (Compl. ¶27).
  • Technology Synopsis: The patent describes a method for controlling a handheld device where an application is displayed in a first condition with a corresponding icon. Upon receiving a gesture, the application changes to a second display condition, and the icon "morphs" (changes shape and size) to indicate the new state (Compl. ¶165).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶164).
  • Accused Features: The accused functionality is the icon behavior when an application's display state changes, for example, an icon for maximizing an application changes to an icon for minimizing it after the application is maximized (Compl. ¶167-168).

Multi-Patent Capsule: U.S. Patent No. 9,727,205

  • Patent Identification: U.S. Patent No. 9,727,205, “USER INTERFACE WITH SCREEN SPANNING ICON MORPHING,” issued August 8, 2017 (Compl. ¶30).
  • Technology Synopsis: This patent claims a method for a handheld device in an open state where an application is displayed on a first display with an associated icon. In response to an input, the application is modified to display over first and second displays, and the size of the icon is changed to indicate this modification (Compl. ¶179).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶178).
  • Accused Features: The accused functionality involves displaying an application and an icon on one screen, and upon user input (e.g., tapping an icon), expanding the application across both displays and changing the size of the associated icon to indicate the new maximized state (Compl. ¶181).

Multi-Patent Capsule: U.S. Patent No. 9,058,153

  • Patent Identification: U.S. Patent No. 9,058,153, “MINIMIZING APPLICATION WINDOWS,” issued June 16, 2015 (Compl. ¶33).
  • Technology Synopsis: The patent describes a method for multitasking on a dual-display device. A first multi-display application is shown on both displays. Upon receiving an input to launch a second application, the second application's window is displayed on the second display, and the first application's window is automatically minimized to fit the first display (Compl. ¶192).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶191).
  • Accused Features: The accused functionality is the "split screen" feature where opening a second application on one display causes a first, full-screen application to automatically minimize to the other display (Compl. ¶194-195).

Multi-Patent Capsule: U.S. Patent No. 8,875,050

  • Patent Identification: U.S. Patent No. 8,875,050, “FOCUS CHANGE UPON APPLICATION LAUNCH,” issued October 28, 2014 (Compl. ¶36).
  • Technology Synopsis: The patent claims a method where a first application is in focus on a first display. Upon receiving an input to launch a second application, the second application is launched and displayed on a second screen, and the "focus" is changed from the first application's image to the second, altering which input options are available for each (Compl. ¶206).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶205).
  • Accused Features: The accused functionality involves displaying two applications on two screens; when a user launches the second application, the focus shifts to it, causing its input options (e.g., navigation bar) to be displayed while the first application's input options are no longer shown (Compl. ¶208).

Multi-Patent Capsule: U.S. Patent No. 9,792,007

  • Patent Identification: U.S. Patent No. 9,792,007, “FOCUS CHANGE UPON APPLICATION LAUNCH,” issued October 17, 2017 (Compl. ¶39).
  • Technology Synopsis: This patent is similar to the '050 Patent, claiming a method of changing focus between two applications on two displays. It specifies that input options for the first application are displayed in a first "configurable area" that does not display application content, and upon launch of the second application, its input options are displayed in a second configurable area (Compl. ¶219).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶218).
  • Accused Features: The accused functionality is the management of focus and input options (e.g., navigation bars in configurable areas) when launching a second application while a first is already displayed and in focus on a dual-screen device (Compl. ¶221-222).

Multi-Patent Capsule: U.S. Patent No. 9,141,135

  • Patent Identification: U.S. Patent No. 9,141,135, “FULL-SCREEN ANNUNCIATOR,” issued September 22, 2015 (Compl. ¶42).
  • Technology Synopsis: The patent claims a method of displaying a pre-configured "annunciator window" (e.g., a status bar) that extends across a first portion of a first display and a second portion of a second display without degrading the information shown by applications on those displays. The annunciator window's display is modified in response to changes in device, connectivity, or messaging status (Compl. ¶233).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶232).
  • Accused Features: The accused functionality is the status or notification bar that allegedly spans across both displays of the accused products, displaying information such as battery life, connectivity, and messages without obscuring the underlying applications (Compl. ¶235-236).

Multi-Patent Capsule: U.S. Patent No. 8,832,577

  • Patent Identification: U.S. Patent No. 8,832,577, “UNIVERSAL CLIPBOARD,” issued September 9, 2014 (Compl. ¶45).
  • Technology Synopsis: The patent describes a method of operating a multi-screen device with a "universal clipboard." Content is copied from a first application, a universal clipboard application is displayed on a second screen showing the copied item, and inputs on the second screen select the item to be pasted into a second application on the first screen (Compl. ¶247).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶246).
  • Accused Features: The accused functionality is the clipboard feature (e.g., Gboard's clipboard) on the Accused Foldable Smartphone Products, which allows a user to copy content from one app, open the clipboard on a second screen, select the content, and paste it into a different app on the first screen (Compl. ¶249).

Multi-Patent Capsule: U.S. Patent No. 9,146,589

  • Patent Identification: U.S. Patent No. 9,146,589, “IMAGE CAPTURE DURING DEVICE ROTATION,” issued September 29, 2015 (Compl. ¶48).
  • Technology Synopsis: The patent claims a method for an image capture function on a dual-screen device. It involves presenting a first display based on physical device state, display mode, and orientation. Upon receiving a device rotation, a second, different display is presented for the image capture function (Compl. ¶260).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶259).
  • Accused Features: The accused functionality is the camera application on the Accused Foldable Smartphone Products, which allegedly changes its display on the first and second screens when the user rotates the device (Compl. ¶262).

Multi-Patent Capsule: U.S. Patent No. 9,158,494

  • Patent Identification: U.S. Patent No. 9,158,494, “MINIMIZING AND MAXIMIZING BETWEEN PORTRAIT DUAL DISPLAY AND PORTRAIT SINGLE DISPLAY,” issued October 13, 2015 (Compl. ¶51).
  • Technology Synopsis: The patent claims a method where an application presents an "auxiliary page" on a first display and a "primary page" on a second display. Upon receiving an input to minimize the application to one display, the auxiliary page is dismissed and only the primary page is displayed (Compl. ¶273).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶272).
  • Accused Features: The accused functionality is exemplified by the YouTube app, where a primary page (the video) is on one display and an auxiliary page (video controls) is on another. Upon a "split screen" input, the auxiliary controls are allegedly dismissed, and only the primary video page is displayed on one screen (Compl. ¶275).

Multi-Patent Capsule: U.S. Patent No. 9,195,335

  • Patent Identification: U.S. Patent No. 9,195,335, “MODAL LAUNCHING,” issued November 24, 2015 (Compl. ¶54).
  • Technology Synopsis: This patent claims a method for managing a multi-display application that is nearly identical to the '053 Patent. When an input launches a modal window, the modal window is displayed on a selected screen, and the main application window is minimized to the non-selected screen (Compl. ¶286).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶285).
  • Accused Features: The accused functionality is the same as for the '053 patent: launching a modal window (e.g., video controls in YouTube) on one screen causes the main application to be automatically minimized to the other screen (Compl. ¶288).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two categories of accused products: "Accused Foldable Smartphone Products," including the Google Pixel Fold, and "Accused Flat Smartphone Products," including the Google Pixel 8, Pixel 8 Pro, Pixel 7, Pixel 7 Pro, Pixel 7a, Pixel 6, Pixel 6 Pro, Pixel 6a, Pixel 5, and Pixel 5a (Compl. ¶70-71).

Functionality and Market Context

  • The relevant functionality of the Accused Foldable Smartphone Products includes having at least a first inner screen and a second outer screen, with the ability to operate in different physical states such as open, closed, or partially folded (Compl. ¶90, 143). The complaint alleges these devices can run applications across both screens simultaneously, minimize applications to a single screen, and change display modes based on physical orientation and state (Compl. ¶90, 103, 116). A visual provided in the complaint shows the Pixel Fold displaying different applications on its two inner screens when open (Compl. ¶116, 235).
  • The Accused Products are alleged to be developed, manufactured, and sold by Google in the United States and incorporate user interfaces and structures that enable benefits of multi-screen and foldable devices, such as improved multitasking (Compl. ¶64-66, 69).

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,836,842 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 have a first inner screen and a second outer screen. ¶90 col. 5:50-52
receiving user interface input to execute an image capture function; A user provides input to open the camera application on the device. ¶90 col. 2:7-8
determining one or more of an image capture function configuration, a device orientation, and a device state; The device's processor determines the camera application's configuration, the device's physical orientation (e.g., landscape or portrait), and its physical state (e.g., open, closed, or folded). ¶90 col. 2:8-10
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 enters different camera modes where the camera application displays differently on the first or second screen. A visual cited in the complaint depicts the camera application displaying differently based on device state (Compl. ¶90). ¶90 col. 2:10-14
  • Identified Points of Contention:
    • Scope Questions: A central question may be the scope of "device state." While the complaint alleges this includes "open, closed, or folded," a court would need to construe this term based on the patent's specification, which focuses on "open" and "closed" but also describes an "easel" position (’842 Patent, col. 7:1-4).
    • Technical Questions: The claim requires "entering" a mode "based on" the "determining" step. A technical question will be what evidence demonstrates that the accused device performs this specific sequence of logical operations, rather than simply having pre-programmed displays for different physical configurations that are triggered directly by sensor input without a separate "determining" step as claimed.

U.S. Patent No. 8,881,053 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 can display a window of a multi-screen application, such as YouTube, across both of its screens. ¶103 Not Provided
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 YouTube application. ¶103 Not Provided
in response to the input, displaying, on a selected one of the first display or the second display, a modal window; When the modal window is opened, it is displayed on either the first or second screen. ¶103 Not Provided
and 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 automatically minimizes the main multi-screen application window to the screen not occupied by the modal window. ¶103 Not Provided
The complaint does not provide sufficient detail for analysis of patent citations.
  • Identified Points of Contention:
    • Scope Questions: A key claim construction issue will be the definition of "modal window." The complaint provides "a child window" and "the video controls of the YouTube application" as examples (Compl. ¶103). A potential dispute is whether the accused video controls meet the technical definition of a "modal" window, which typically implies a window that requires user interaction before they can return to the parent application.
    • Technical Questions: Does the accused functionality "automatically minimize" the main application window to the other screen, or does it perform a different UI operation, such as resizing or shifting focus, that falls outside the scope of the claim term "minimized"?

V. Key Claim Terms for Construction

  • The Term: "device state" (from '842 Patent, Claim 1)
  • Context and Importance: This term is critical for the infringement analysis of the ’842 Patent, as the claimed method requires "determining" the "device state" to select an image capture mode. The complaint alleges this covers "open, closed, or folded" (Compl. ¶90), and the breadth of this term's construction will directly impact the scope of infringement. Practitioners may focus on this term because the patent's examples could be argued to support either a narrow or broad definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes multiple physical positions beyond simple open/closed, including an "easel" position and a "modified easel" position, which could support a construction that includes various folded or intermediate states (’842 Patent, col. 7:1-40).
    • Evidence for a Narrower Interpretation: The detailed description of device operation primarily contrasts the "open" position with the "closed" position, and a defendant may argue that the term should be limited to these explicitly and repeatedly described binary states (’842 Patent, col. 6:46-67).
  • The Term: "modal window" (from '053 Patent, Claim 1)
  • Context and Importance: The infringement theory for the ’053 Patent hinges on whether the accused functionality, such as displaying "the video controls of the YouTube application," constitutes "launching a modal window" (Compl. ¶101, 103). The definition of this term is central, as a defendant could argue that its UI elements are not "modal" in the technical sense required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent itself does not appear to be provided, but the complaint's allegation that a "modal window" is "a child window" (Compl. ¶103) suggests an argument that any sub-window related to the parent application could qualify.
    • Evidence for a Narrower Interpretation: The complaint does not provide sufficient detail for analysis of intrinsic evidence that may support a narrower interpretation. A defendant may argue from extrinsic evidence that "modal window" has a specific technical meaning in the art (e.g., a window that disables the parent window until it is closed) that the accused video controls do not meet.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Google induces infringement by providing user instructions and marketing materials that encourage users to perform the claimed methods on the Accused Products (Compl. ¶94, 107). It also alleges contributory infringement, stating that Google provides components of the accused systems with knowledge that they are especially adapted for infringing the patents and are not suitable for substantial non-infringing use (Compl. ¶96, 109).
  • Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged to stem from a specific notice letter sent on June 8, 2023, which identified the Accused Products and the Asserted Patents (Compl. ¶79). It is also alleged based on Google's awareness of the Imerj project and its routine monitoring of patents in the foldable smartphone field (Compl. ¶80-82).

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

  • A core issue will be one of definitional scope: The case involves sixteen patents with numerous technical terms such as "modal window," "focus change," "minimized," and "morphing." The outcome will substantially depend on whether the specific user interface behaviors implemented in Google's Android operating system on the accused devices can be construed to meet the technical definitions of these claim terms.
  • A second central question will be one of mechanics and methods: For the patents directed to mechanical hinges, a key issue will be whether the specific components of the Google Pixel Fold's hinge mechanism read on the claimed elements of a "core member," "movable members," and a "detaining member" with "cams." For the numerous method patents, a key evidentiary question will be whether Plaintiff can prove that the accused devices perform every claimed step in the required sequence, particularly the causal "based on" relationships between determining a device state and entering a new mode.
  • A final key question relates to willfulness and damages: Given the complaint’s allegation of a pre-suit notice letter that specifically identified the asserted patents and the accused Pixel Fold product, a critical issue for trial will be whether Google’s alleged continued infringement after that date was objectively reckless, potentially exposing it to enhanced damages.