DCT

2:20-cv-00283

Japan Display Inc v. Tianma Microelectronics Co Ltd

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Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:20-cv-00283, E.D. Tex., 08/31/2020
  • Venue Allegations: Plaintiffs allege that venue is proper because Defendant is not a resident of the United States and therefore may be sued in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiffs allege that Defendant’s Thin Film Transistor (TFT) Liquid Crystal Displays (LCDs), which are incorporated into various consumer electronics, infringe nine U.S. patents related to the fundamental structure, components, and manufacturing of LCD panels.
  • Technical Context: The dispute centers on the micro-architecture of TFT LCD panels, a core technology for displays used in ubiquitous devices like smartphones and tablets, where improvements in brightness, viewing angle, and power efficiency are critical.
  • Key Procedural History: The complaint alleges that Plaintiff Japan Display Inc. ("JDI") put Defendant on notice of infringement of at least U.S. Patent No. 8,218,119 by sending detailed claim charts on June 17, 2015. This pre-suit notice is asserted as a basis for willful infringement allegations.

Case Timeline

Date Event
1999-09-07 Priority Date for U.S. Patent 8,218,119
1999-09-07 Priority Date for U.S. Patent 10,139,687
1999-09-07 Priority Date for U.S. Patent 8,218,118
1999-09-07 Priority Date for U.S. Patent 7,936,429
2000-12-18 Priority Date for U.S. Patent 9,715,132
2000-12-18 Priority Date for U.S. Patent 10,018,859
2001-10-15 Priority Date for U.S. Patent 10,330,989
2005-12-26 Priority Date for U.S. Patent 9,793,299
2008-02-26 Priority Date for U.S. Patent 10,423,034
2011-05-03 Issue Date for U.S. Patent 7,936,429
2012-07-10 Issue Date for U.S. Patent 8,218,118
2012-07-10 Issue Date for U.S. Patent 8,218,119
2015-06-17 JDI sends claim charts to Tianma regarding the '119 patent
2017-07-25 Issue Date for U.S. Patent 9,715,132
2017-10-17 Issue Date for U.S. Patent 9,793,299
2018-07-10 Issue Date for U.S. Patent 10,018,859
2018-11-27 Issue Date for U.S. Patent 10,139,687
2019-06-25 Issue Date for U.S. Patent 10,330,989
2019-09-24 Issue Date for U.S. Patent 10,423,034
2020-08-31 Complaint Filing Date

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

U.S. Patent No. 8,218,119 - “Liquid Crystal Display Device,” issued July 10, 2012

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of increasing the numerical aperture (the light-transmitting area) of In-Plane Switching (IPS) type LCDs without compromising their wide viewing angle characteristics (Compl. ¶24; ’119 Patent, col. 13:50-56). Conventional structures often sacrificed brightness because opaque electrodes and signal lines blocked light.
  • The Patented Solution: The invention proposes a specific electrode structure where a second, transparent electrode (a counter-electrode) is positioned between the first, transparent pixel electrode and the substrate. This second electrode is also arranged to overlap with the gate signal line and connect to the second electrode of an adjacent pixel, thereby managing the electric fields to allow more light to pass through the pixel region (’119 Patent, Abstract, col. 2:26-39).
  • Technical Importance: This electrode architecture represents an advancement in fringe-field switching (FFS) technology, which was critical for developing brighter, more power-efficient high-resolution displays for mobile devices (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶50).
  • Claim 1 recites a liquid crystal display with elements including:
    • A pair of transparent substrates with liquid crystal between them.
    • One substrate having drain and gate signal lines defining pixel regions.
    • Each pixel region having a TFT element, a first transparent electrode with slits, a connection area to the TFT, and a second transparent electrode.
    • The second electrode is disposed between the first electrode and the substrate.
    • The second electrode connects to the second electrode of an adjacent pixel.
    • The connected second electrode is arranged at a position overlapping the gate signal line.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,139,687 - “Liquid Crystal Display Device,” issued November 27, 2018

The Invention Explained

  • Problem Addressed: Similar to the ’119 Patent, this invention aims to enhance the numerical aperture and maintain wide viewing angles in an LCD (Compl. ¶26). It focuses on optimizing the electrode structure to improve light transmittance (’687 Patent, col. 1:44-53).
  • The Patented Solution: The patent describes an LCD structure where a planar counter electrode is disposed on the first substrate, interposed between the gate signal lines and the liquid crystal layer. The invention specifies that this counter electrode overlaps with both the slits of the pixel electrode and the gate signal lines, and that the pixel electrode connects to the TFT through a contact hole in an insulating layer, creating a specific multi-layer arrangement (’687 Patent, Abstract).
  • Technical Importance: This claimed structure represents a specific implementation of FFS technology designed to maximize the light-transmissive area of each pixel by carefully layering and overlapping the conductive and insulating components of the display (’687 Patent, col. 13:46-54).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶65).
  • Claim 1 recites a liquid crystal display with elements including:
    • A first and second substrate with a liquid crystal layer between them.
    • The first substrate having drain and gate signal lines and a TFT element.
    • A pixel electrode with a slit, connected to the TFT.
    • A planar counter electrode on the first substrate.
    • An insulating layer between the counter electrode and pixel electrode.
    • The claim further requires that the counter electrode is interposed between the gate lines and the liquid crystal, overlaps with the pixel electrode's slit, overlaps with the gate lines, and that the insulating layer has a contact hole for the pixel electrode's connection to the TFT.
  • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 9,715,132 - “Liquid Crystal Display Device,” issued July 25, 2017

  • Technology Synopsis: The patent is directed to the structure of an LCD designed to prevent light leaks near spacers, which are microscopic components used to maintain a uniform gap between the display's glass substrates (Compl. ¶28). The invention claims a specific arrangement of electrodes, spacers, and material layers to control light transmission in these critical areas (’132 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶80).
  • Accused Features: The complaint alleges that the accused TL062FVMC70 panel infringes by having a structure where spacers overlap gate signal lines and a reference electrode, and by employing specific inorganic and organic material layers between the gate line and reference electrode (Compl. ¶83-85).

Multi-Patent Capsule: U.S. Patent No. 9,793,299 - “Display Device and Hand-Held Electronic Device,” issued October 17, 2017

  • Technology Synopsis: The patent is directed to the overall layered assembly of a display device intended for hand-held electronics, focusing on the integration of a protective member (i.e., a cover glass or protective layer) with the underlying display stack (Compl. ¶30). The claims define the relationships and properties of various components, including the TFT substrate, polarizing plate, adhesive, and a protective member of a specific thickness (’299 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶95).
  • Accused Features: The complaint alleges infringement based on the entire layered structure of the accused TL062FVMC70 panel as integrated into the Motorola Moto G7, including its multi-thin film layer, seal member, polarizing plate, adhesive, and a protective cover with a measured thickness of 0.55 mm (Compl. ¶98-103).

Multi-Patent Capsule: U.S. Patent No. 10,018,859 - “Liquid Crystal Display Device,” issued July 10, 2018

  • Technology Synopsis: The patent, like the ’132 Patent, is directed at preventing light leaks around spacers by claiming a specific structural arrangement of the display's components (Compl. ¶32). The claims detail the relative positions of the spacer, gate signal line, reference electrode, and an organic material layer, including a "non-formation region" of the organic layer outside the display area (’859 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶111).
  • Accused Features: The complaint alleges the accused TL062FVMC70 panel infringes by incorporating an organic material layer between the gate signal line and reference electrode, and by having a spacer that overlaps the gate signal line, among other structural features (Compl. ¶114-118).

III. The Accused Instrumentality

Product Identification

The primary accused products are TFT LCD panels designed, manufactured, and sold by Defendant Tianma, specifically including models TL062FVMC70, TM062JDSC03, and TL079QDXP02 (Compl. ¶42-43). The complaint's detailed infringement allegations focus on panel model TL062FVMC70, which is incorporated into consumer devices such as the Motorola Moto G7 and Moto G7 Power smartphones (Compl. ¶14, 43). Panel model TL079QDXP02 is identified as being used in the Asus ZenPad S 8.0 tablet (Compl. ¶17, 44).

Functionality and Market Context

The accused panels are core components that provide the visual display for consumer electronics (Compl. ¶42). Plaintiffs allege that Defendant markets these panels for a wide range of devices, including smartphones, tablets, and automotive instrumentation (Compl. ¶42). The complaint cites Defendant’s statements that its "shipments of small and medium size modules kept the leading position among the global panel factories" to establish the products' commercial importance (Compl. ¶41). A photograph in the complaint shows the model number TL062FVMC70 printed on the back of the panel used in the Motorola Moto G7 smartphone (Compl. p. 6).

IV. Analysis of Infringement Allegations

U.S. Patent 8,218,119 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A liquid crystal display comprising: a pair of transparent substrates opposed to each other with liquid crystal therebetween The accused panel has two transparent substrates with a liquid crystal layer between them. An optical microscope image shows this layered structure (Compl. p. 20). ¶53 col. 2:26-28
one of the pair of transparent substrates having a plurality of drain signal lines and a plurality of gate signal lines, and a plurality of pixel regions defined by the drain signal lines and the gate signal lines The accused panel has a grid of drain and gate signal lines that define the individual red, green, and blue pixel regions. Optical microscope images show these line structures (Compl. p. 19-20). ¶53 col. 2:29-32
wherein the pixel region has: a TFT element; a first electrode formed of a transparent electrode having a plurality of slits; a connection area that connects the first electrode to the TFT element Each pixel region in the accused panel contains a TFT, a transparent first electrode with slits, and a connection area between them. A scanning electron microscope image details the slitted electrode structure (Compl. p. 20). ¶54 col. 2:33-37
a second electrode formed of a transparent electrode; wherein the second electrode is disposed between the first electrode and the one of the pair of transparent substrates The accused panel has a second transparent electrode located underneath the slitted first electrode. A scanning electron microscope analysis cross-section shows the relative positions of the first electrode, second electrode, and substrate (Compl. p. 21). ¶55 col. 2:38-41
the second electrode is connected with the second electrode of an adjacent pixel region, and the connected second electrode is arranged at a position overlapping with the gate signal line The second electrode of one pixel is alleged to be connected to that of an adjacent pixel, with the connection overlapping a gate signal line. A microscope and SEM analysis image illustrates the overlap of the second electrode and the gate signal line (Compl. p. 22). ¶56 col. 2:41-44
  • Identified Points of Contention:
    • Scope Questions: The analysis may focus on the term "connected", questioning whether the electrical and physical linkage between the second electrodes of adjacent pixels in the accused device meets the specific connection method required by the claim language and described in the patent's specification.
    • Technical Questions: A key question may be how the "second electrode" is "arranged at a position overlapping with the gate signal line." The degree and nature of this overlap in the accused device will be compared against the patent's teachings to determine if this structural limitation is met.

U.S. Patent 10,139,687 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first substrate and a second substrate opposed to each other with liquid crystal layer therebetween, the first substrate having drain signal lines and gate signal lines The accused panel contains two substrates with a liquid crystal layer and a grid of drain and gate signal lines on the first substrate. Optical microscope images show this structure (Compl. p. 26). ¶68 col. 13:9-14
a pixel electrode formed of a transparent conducting layer having a slit, the pixel electrode being connected to the TFT element The accused panel's pixel region has a slitted pixel electrode made of a transparent conductor, which is connected to a TFT element. A scanning electron microscope image shows the slitted structure of the pixel electrode (Compl. p. 27). ¶69 col. 13:18-21
a counter electrode formed of a planar transparent conducting layer...and an insulating layer interposed between the counter electrode and the pixel electrode The accused panel has a counter electrode made of a planar transparent conductor, with an insulating layer separating it from the pixel electrode. A scanning electron microscope cross-section shows the pixel electrode, insulating layer, and counter electrode (Compl. p. 28). ¶70 col. 13:22-26
wherein the counter electrode is interposed between the gate signal lines and the liquid crystal layer In the accused panel, the counter electrode is positioned between the gate signal line and the liquid crystal layer. A scanning electron microscope cross-section image illustrates this layered arrangement (Compl. p. 28). ¶71 col. 13:27-29
the counter electrode is overlapped with the slit of the pixel electrode, the counter electrode is overlapped with the gate signal lines, and the insulating layer has a contact hole, and the pixel electrode is connected to the TFT element through the contact hole The accused panel’s counter electrode allegedly overlaps the pixel electrode slit and gate lines, and its insulating layer has a contact hole for the TFT connection. A scanning electron microscope cross-section shows the contact hole and TFT element connection (Compl. p. 29). ¶72 col. 13:29-34
  • Identified Points of Contention:
    • Scope Questions: A central point of contention may be the term "planar" as applied to the counter electrode. The defense may argue that microscopic variations and topography inherent in the manufacturing process mean the layer is not "planar" as required by the claim.
    • Technical Questions: Infringement analysis will likely scrutinize whether the connection of the pixel electrode to the TFT occurs "through the contact hole" in the specific manner claimed. The complaint's SEM cross-section at paragraph 72, which depicts the TFT element connection through the contact hole, will be a key piece of evidence in this dispute.

V. Key Claim Terms for Construction

For U.S. Patent 8,218,119:

  • The Term: "connection area"
  • Context and Importance: This term defines the physical and electrical link between the pixel electrode and the TFT. Its construction is critical because the infringement allegation depends on the accused panel having a structure that performs this specific connection in the manner required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification may describe the connection in general functional terms, such as an area that "electrically connects" the components, which could support a construction not limited to a single physical layout (’119 Patent, col. 2:36-37).
    • Evidence for a Narrower Interpretation: The figures and detailed description may depict the "connection area" as a specific, delineated structure with a particular shape or formed from a particular layer, potentially limiting the term's scope to the depicted embodiments (’119 Patent, Fig. 1, element 111).

For U.S. Patent 10,139,687:

  • The Term: "planar transparent conducting layer"
  • Context and Importance: Claim 1 requires the counter electrode to be formed of a "planar" layer. Given that manufactured microstructures are rarely perfectly flat, the definition of "planar" will be central to determining infringement. Practitioners may focus on this term because SEM images of the accused device show some topography (Compl. p. 28).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent may use "planar" to distinguish this electrode from other known electrode types, such as those with slits or comb-like shapes. This context suggests "planar" means generally flat and continuous, rather than optically flat (’687 Patent, col. 13:22-23).
    • Evidence for a Narrower Interpretation: The patent's summary or abstract might emphasize the planarity of the layer as a key inventive feature for achieving uniform electric fields, suggesting a stricter interpretation that excludes layers with significant topographical features.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement under 35 U.S.C. § 271(b). The factual basis includes Defendant’s alleged creation of advertisements, establishment of distribution channels for the accused panels in the U.S., and provision of technical support and manuals that instruct and encourage infringing uses by distributors and customers (Compl. ¶57, 73, 87, 104).
  • Willful Infringement: For the ’119 Patent, willfulness allegations are based on pre-suit knowledge, stemming from detailed claim charts JDI allegedly sent to Tianma on June 17, 2015 (Compl. ¶49, 58). For the ’687, ’132, ’299, and ’859 patents, the complaint alleges knowledge at least as of the filing of the complaint, forming a basis for potential post-suit willfulness (Compl. ¶64, 74, 86, 88, 94, 105).

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

  • A core issue will be one of definitional scope: can terms rooted in idealized patent drawings, such as a "planar" counter electrode, be construed to cover the real-world micro-topography of a mass-produced LCD panel? The outcome of claim construction for this and other structural terms will be critical.
  • A key evidentiary question will be one of structural correspondence: while the complaint's electron microscope imagery provides a detailed view of the accused panel's architecture, the case will require proof that this structure precisely maps to every element of the asserted claims. The dispute may turn on subtle differences in the layering, connection, and overlapping of the device's conductive and insulating films compared to the specific arrangements recited in the patent claims.
  • A central question for damages will be willfulness: did the Defendant act with objective recklessness by continuing to sell the accused products after allegedly receiving detailed infringement charts for the ’119 Patent in 2015? The answer will determine the potential for enhanced damages.