DCT
2:20-cv-00284
Japan Display Inc v. Tianma Microelectronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Japan Display Inc. (Japan)
- Defendant: Tianma Microelectronics Co. Ltd. (China)
- Plaintiff’s Counsel: Vinson & Elkins L.L.P.
- Case Identification: 2:20-cv-00284, E.D. Tex., 08/31/2020
- Venue Allegations: Plaintiff alleges venue is proper as Defendant is a foreign corporation not resident in the U.S. and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s thin-film transistor (TFT) liquid crystal display (LCD) panels, incorporated into various consumer electronics, infringe three U.S. patents related to specific LCD structural designs for improving visual performance and durability.
- Technical Context: The technology at issue concerns the micro-architectural design of high-resolution LCD panels, a foundational component for the global smartphone, tablet, and consumer electronics markets.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the asserted patents.
Case Timeline
| Date | Event |
|---|---|
| 2006-12-27 | '409 Patent Priority Date |
| 2008-03-06 | '654 Patent Priority Date |
| 2013-12-09 | '288 Patent Priority Date |
| 2014-09-09 | '409 Patent Issue Date |
| 2016-04-12 | '654 Patent Issue Date |
| 2017-11-14 | '288 Patent Issue Date |
| 2020-08-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,310,654 - "Liquid Crystal Device and Electronic Apparatus," issued April 12, 2016
The Invention Explained
- Problem Addressed: The patent describes a problem in multi-domain LCDs where achieving a wide viewing angle through bent electrode structures can create "dead spaces" along the data and scan lines, which reduces the pixel aperture ratio and, consequently, lowers the display's brightness ('654 Patent, col. 2:11-21).
- The Patented Solution: The invention proposes a specific pixel architecture where not only are the linear electrodes within a sub-pixel bent (to create the multi-domain effect), but the data lines are also bent to conform to the shape of the electrodes. By shaping the data lines to follow the electrode contours, the design minimizes the non-contributing "dead space," allowing the display to maintain a high aperture ratio and high luminance while still providing a wide viewing angle ('654 Patent, Abstract; col. 3:17-24; Fig. 2).
- Technical Importance: This design addresses a fundamental trade-off between viewing angle and brightness, enabling the production of displays that perform well on both metrics, a key requirement for mobile devices ('654 Patent, col. 2:49-52).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('Compl. ¶35).
- The essential elements of independent claim 1 include a liquid crystal device with first and second substrates, data and scan lines, and multiple electrode and insulating layers, wherein:
- The second electrode comprises multiple linear electrodes with gaps between them.
- These linear electrodes have at least one "bent portion" in a central area of the sub-pixel.
- Crucially, the "data lines or the scan lines are bent in an extending direction of the linear electrodes having the bent portion."
- A light shielding film on the second substrate is also bent to overlap with the bent data or scan lines.
- The complaint reserves the right to assert infringement of additional claims (Compl. ¶34).
U.S. Patent No. 8,830,409 - "Liquid Crystal Display Device Having Improved Electrostatic Discharge Resistance," issued September 9, 2014
The Invention Explained
- Problem Addressed: The patent notes that modern, thin LCD panels are vulnerable to electrostatic discharge (ESD), which can disrupt the electric fields controlling the liquid crystals and cause visual artifacts or damage to the device ('409 Patent, col. 1:32-49).
- The Patented Solution: The invention discloses a protective "dummy wiring" located on the first substrate, at the outermost periphery of the panel, positioned between the active peripheral circuit and the physical edge. This dummy wiring is made of a continuous metal layer, is not electrically connected to the peripheral circuit, and is connected to an external ground potential. It functions as a dedicated shield to intercept and dissipate ESD before it can reach and damage the sensitive internal circuitry ('409 Patent, Abstract; col. 2:1-14; Fig. 3).
- Technical Importance: This architecture provides a robust, isolated path for ESD protection, enhancing the reliability of LCD panels without interfering with the complex signaling of the primary display circuitry ('409 Patent, col. 7:6-14).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶50).
- The essential elements of independent claim 1 include a liquid crystal display device with a peripheral circuit and a "dummy wiring," wherein:
- The dummy wiring is located outside the pixel area and is separate from the peripheral circuit's common wiring.
- It is located "between the peripheral circuit and the outermost edge" of the substrate.
- It is "not electrically connected to the peripheral circuit."
- It "surrounds the peripheral circuit on at least three sides."
- It is "connected to a ground potential outside the first substrate" to discharge static electricity.
- The complaint reserves the right to assert infringement of additional claims (Compl. ¶48).
U.S. Patent No. 9,817,288 - "Liquid Crystal Display Device," issued November 14, 2017
- Patent Identification: U.S. Patent No. 9,817,288, "Liquid Crystal Display Device," issued November 14, 2017 (Compl. ¶25).
- Technology Synopsis: This patent addresses defects in high-definition screens that arise from the difficulty of properly coating alignment film inside deep, steep-walled "through-holes," which are structures that connect different conductive layers ('288 Patent, col. 2:11-25). The invention specifies a structure where the pixel electrode is formed to cover only a part of the through-hole's side wall, leaving the remaining part uncovered. This partial coverage is alleged to facilitate the uniform flow of alignment film material into the through-hole, preventing thickness unevenness and associated display defects ('288 Patent, Abstract; col. 12:47-51).
- Asserted Claims: The complaint asserts at least claim 1 (Compl. ¶68).
- Accused Features: The complaint alleges that the layered structure of the accused panels, specifically the configuration of the transistor substrate, insulating films, electrodes, and the through-hole connection between the source and pixel electrodes, infringes the '288 Patent (Compl. ¶¶ 70-77).
III. The Accused Instrumentality
Product Identification
The complaint identifies specific TFT LCD panels manufactured by Defendant Tianma, including models TL079QDXP02, TL062FVMC70, and NL1294A5ANA0125439391221, which are referred to as the "Accused Panel(s)" (Compl. ¶¶ 28, 35, 50, 68).
Functionality and Market Context
The Accused Panels are components used in widely distributed consumer electronic devices, including the Motorola Moto G7 smartphone, the Asus ZenFone 6 smartphone, and the Asus ZenPad S 8.0 tablet (Compl. ¶¶ 9, 28). Plaintiff alleges that Tianma holds a "leading position among the global panel factories" for small and medium-sized modules (Compl. ¶27). The complaint provides extensive visual evidence, including optical and scanning electron microscope (SEM) images, to detail the micro-architectural features of the Accused Panels alleged to infringe the patents-in-suit (Compl. pp. 16-18, 22-27, 31-34). For example, a photograph of a disassembled Motorola Moto G7 smartphone identifies the accused Tianma panel by its model number, TL062FVMC70 (Compl. p. 6).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,310,654 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first substrate and a second substrate... the first substrate including a plurality of data lines and a plurality of scan lines which intersect each other | The accused panel TL079QDXP02 is alleged to be a liquid crystal device with a first and second substrate, with the first substrate including intersecting data and scan lines that form sub-pixels. | ¶38 | col. 5:28-34 |
| a second electrode has a plurality of linear electrodes that are disposed with gaps therebetween | The accused panel's second electrode is identified as a pixel electrode composed of multiple linear electrodes separated by gaps, as shown in microscope images. An SEM image shows the distinct linear electrodes and gaps (Compl. p. 17). | ¶39 | col. 6:58-60 |
| each of the plurality of linear electrodes extends in a long-axis direction of the sub-pixels, and... has at least one bent portion, the bent portion provided in a central portion of the... sub-pixels | The linear electrodes in the accused panel are alleged to be bent in the central portion of the sub-pixels, with a shape where both sides are inclined in opposite directions relative to the sub-pixel's long axis. | ¶40 | col. 6:40-54 |
| the data lines or the scan lines are bent in an extending direction of the linear electrodes having the bent portion | The complaint alleges that the data lines in the accused panel are also bent to follow the direction of the bent linear electrodes. An overlaid microscope image shows the bent data line running parallel to the contours of the bent electrodes (Compl. p. 18). | ¶40 | col. 7:11-17 |
| a light shielding film configured to overlap with... the data lines or... the scan lines which is at least bent in plan view... provided on the second substrate | The accused panel is alleged to have a light shielding film on the second substrate that overlaps with the bent data lines and the bent second electrode. | ¶¶38, 40 | col. 13:35-40 |
Identified Points of Contention
- Scope Questions: A central issue may be the construction of the phrase "bent in an extending direction of the linear electrodes." The court will need to determine how closely the bend in the data/scan line must conform to the bend in the electrode to meet this limitation.
- Technical Questions: The complaint provides strong visual evidence, including an overlaid image showing the bent data line following the electrode shape (Compl. p. 18). The factual dispute will likely focus on whether this visual correspondence satisfies the specific geometric relationship required by the claim language as construed by the court.
U.S. Patent No. 8,830,409 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first substrate having... a peripheral circuit... and a dummy wiring, the peripheral circuit and the dummy wiring being provided outside a pixel area | The accused panel TL062FVMC70 is alleged to have a first substrate with a pixel area, and outside of it, a peripheral circuit and a separate dummy wiring. An optical microscope image identifies these distinct regions (Compl. p. 22). | ¶53 | col. 2:1-6 |
| the dummy wiring is located between the peripheral circuit and the outermost edge of the side at which the peripheral circuit is positioned and is not electrically connected... | The complaint alleges the dummy wiring is located at the panel's edge, outside the peripheral circuit, and is not electrically connected to it. An image is provided to show the physical separation between the common wiring and the dummy wiring (Compl. p. 25). | ¶59 | col. 10:56-11:1 |
| the dummy wiring is connected to a ground potential outside the first substrate and the dummy wiring surrounds the peripheral circuit on at least three sides of the first substrate | The complaint alleges the dummy wiring surrounds the circuit on at least three sides and is grounded. It supports the grounding allegation with a photograph of a multimeter measuring a near-zero resistance between the dummy wiring and ground (Compl. p. 27). | ¶59 | col. 10:65-11:1 |
| wherein the dummy wiring is provided to discharge electric potential rise on the first substrate... | Based on its alleged structure and grounding, the complaint asserts the dummy wiring is provided to discharge potential rise from the substrate, protecting the internal circuitry. | ¶60 | col. 12:49-54 |
Identified Points of Contention
- Scope Questions: The negative limitation "not electrically connected to the peripheral circuit" will be a key point of dispute. The case will turn on the factual evidence presented to prove or disprove any such connection.
- Technical Questions: The complaint's use of a multimeter measurement to show the dummy wiring is grounded (Compl. p. 27) is a strong piece of factual evidence. A dispute may arise over whether this static measurement proves the claimed function of discharging a dynamic ESD event. The geometric requirement of surrounding the circuit on "at least three sides" will depend on a factual analysis of the accused panel's layout.
V. Key Claim Terms for Construction
From the '654 Patent
- The Term: "bent in an extending direction of the linear electrodes"
- Context and Importance: This term defines the critical relationship between two key structures: the data/scan lines and the electrodes. Infringement hinges on whether the accused panel's geometry meets this specific relational requirement. Practitioners may focus on this term because it is not a standard term of art and its meaning will depend heavily on the patent's specification and figures.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the data line is "formed to be bent along the same direction as the extending direction of the linear electrode" ('654 Patent, col. 7:11-14). A party could argue this only requires general conformity or parallelism, not a precise tracing of the electrode's contour.
- Evidence for a Narrower Interpretation: The patent figures, particularly Figure 2, depict a very specific configuration where the bent data line closely follows the outer border of the bent electrode. A party could argue that the claims should be limited to this depicted embodiment, requiring a close, parallel, and conformal relationship.
From the '409 Patent
- The Term: "dummy wiring"
- Context and Importance: The "dummy wiring" is the core of the invention. Its definition—particularly its physical and electrical separation from the main circuitry—is what distinguishes it. The entire infringement and validity analysis for this patent will likely revolve around how this term is construed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define the term by its location (between the peripheral circuit and the edge), its electrical state (not connected to the circuit, connected to an external ground), and its function (to ground static electricity). A party may argue that any structure meeting these functional and relational requirements is a "dummy wiring," regardless of its exact form ('409 Patent, col. 12:30-48).
- Evidence for a Narrower Interpretation: The specification describes the dummy wiring as being "provided independently of the peripheral circuit... in terms of circuit" and shows it in figures as a distinct trace (168) that is pulled out to an FPC ('409 Patent, col. 2:11-14; Fig. 3). A party could argue the term is limited to such an independent, externally-grounded trace, and does not cover other potential ESD structures like a grounded plane.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Tianma induces infringement by manufacturing the Accused Panels and selling them to downstream customers (e.g., Motorola, Asus) with the knowledge and intent that they will be incorporated into products sold in the U.S. Affirmative steps alleged include creating distribution channels and providing technical support and instructions (Compl. ¶¶ 42, 61, 79).
- Willful Infringement: Willfulness is alleged for all three patents. The complaint bases the knowledge prong of willfulness on Defendant having notice of the patents "at least as early as the filing date of the complaint," indicating a theory based on post-filing conduct (Compl. ¶¶ 41, 49, 78).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue for the '654 patent will be one of geometric scope: does the accused panel's bent data line, which appears to run parallel to the bent electrode, satisfy the claim requirement of being "bent in an extending direction of the linear electrodes," or does the claim, in light of the specification, require a more specific conformal relationship?
- A primary question for the '409 patent will be one of structural and electrical definition: can Plaintiff prove the accused "dummy wiring" is both physically and electrically separate from the peripheral circuit, while simultaneously being connected to an external ground and surrounding the circuit on at least three sides, as required by the claims?
- A key evidentiary question for the '288 patent will be one of microscopic factual correspondence: does analysis of the accused device's through-holes show that the pixel electrode covers only "part of a side wall," leaving a "remaining part" uncovered, as narrowly defined by the claim language?