2:22-cv-00385
Bishop Display Tech LLC v. Innolux Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bishop Display Tech LLC (Texas)
- Defendant: Innolux Corporation (Republic of China (Taiwan))
- Plaintiff’s Counsel: Nelson Bumgardner Conroy PC
- Case Identification: [Bishop Display Tech LLC](https://ai-lab.exparte.com/party/bishop-display-tech-llc) v. Innolux Corporation, 2:22-cv-00385, E.D. Tex., 10/03/2022
- Venue Allegations: Venue is asserted on the basis that Defendant is a foreign entity and may be sued in any judicial district under 28 U.S.C. § 1391(c)(3).
- Core Dispute: Plaintiff alleges that Defendant’s thin-film transistor liquid crystal display (TFT-LCD) panels, modules, and associated power supply boards infringe six U.S. patents related to LCD structure, component shielding, electrode design, and backlight driver circuitry.
- Technical Context: The patents address fundamental aspects of modern flat-panel display manufacturing, including methods for protecting sensitive electronics from light, designing efficient pixel electrodes, and driving LED backlights.
- Key Procedural History: The complaint alleges that Defendant received notice of infringement for four of the asserted patents ('706, '347, '830, '682) from a former patent owner, Godo Kaisha IP Bridge 1, on multiple occasions beginning in February 2017, which may be relevant to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 1997-05-23 | Priority Date for ’377 and ’706 Patents |
| 2000-07-31 | Priority Date for ’347 and ’682 Patents |
| 2004-11-16 | Issue Date for U.S. Patent No. 6,819,377 |
| 2004-11-23 | Issue Date for U.S. Patent No. 6,822,706 |
| 2006-12-13 | Priority Date for ’047 Patent |
| 2008-07-03 | Priority Date for ’830 Patent |
| 2008-08-19 | Issue Date for U.S. Patent No. 7,414,682 |
| 2009-09-01 | Issue Date for U.S. Patent No. 7,583,347 |
| 2011-08-09 | Issue Date for U.S. Patent No. 7,995,047 |
| 2012-01-10 | Issue Date for U.S. Patent No. 8,093,830 |
| 2017-02-08 | Alleged notice of infringement for ’706, ’347, ’830, ’682 Patents |
| 2017-04-18 | Alleged additional notice of infringement for ’706, ’347, ’830, ’682 Patents |
| 2020-07-29 | Alleged additional notice of infringement for ’706, ’347, ’830, ’682 Patents |
| 2022-10-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,819,377 - "Liquid Crystal Display Device"
Issued November 16, 2004
The Invention Explained
- Problem Addressed: The patent addresses the problem of bare-chip liquid crystal drivers being susceptible to ambient light, which can induce a photoelectric effect and cause display errors. Traditional packaging to shield the chip hinders the trend toward smaller and thinner electronic devices (’377 Patent, col. 1:21-41).
- The Patented Solution: The invention proposes mounting the bare driver chip directly onto the liquid crystal display panel and using a light-shielding material, such as a black-colored resin or film, to cover the driver and prevent extraneous light from reaching it (’377 Patent, Abstract; col. 3:28-36). This method provides light protection without the bulk of a traditional package.
- Technical Importance: This technique supported the miniaturization of consumer electronics by enabling the use of unpackaged driver ICs in thinner display modules, a critical step for devices like early portable phones (’377 Patent, col. 1:12-17).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶35).
- Essential elements of claim 1 include:
- A liquid crystal panel with liquid crystal cells between first and second plates.
- A liquid crystal driver electrically connected to the panel via a circuit pattern.
- A light shielding material adjacent to the driver to prevent outer light from being incident on the driver.
- A film carrier comprising the circuit pattern on a resin film.
- The driver is mounted on the panel by a light shielding resin that covers one end of the film carrier and a side surface of the driver.
U.S. Patent No. 6,822,706 - "Liquid Crystal Display Device"
Issued November 23, 2004
The Invention Explained
- Problem Addressed: Similar to its '377 counterpart, this patent seeks to prevent light-induced errors in bare-chip liquid crystal drivers used in compact electronic devices (’706 Patent, col. 1:21-41).
- The Patented Solution: The solution involves a more comprehensive shielding approach. It claims a first light shielding material on one face of the driver and a second light shielding material on the opposite face to block light from multiple directions (’706 Patent, Claim 1). It also describes a diffusion sheet, placed behind the display panel, that has a light-absorbing area on its periphery specifically to absorb stray light from the backlight system that could otherwise reach the driver (’706 Patent, Abstract).
- Technical Importance: The invention provides a dual-protection mechanism, shielding the driver from both external ambient light and internal stray light from the device's own backlight, thereby enhancing the operational reliability of thin-profile displays (’706 Patent, col. 2:12-23).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶50).
- Essential elements of claim 1 include:
- A liquid crystal panel with cells between first and second plates.
- A liquid crystal driver electrically connected to the panel.
- A first light shielding material adjacent to a face of the driver.
- A second light shielding material adjacent to an opposite face of the driver.
- A diffusion sheet located adjacent to the panel, comprising a light diffusing area and a light absorbing area on its outer periphery.
- The light absorbing area serves to absorb extraneous light incident on the driver.
U.S. Patent No. 7,583,347 - "Liquid Crystal Display Having Electrodes Constituted By A Transparent Electric Conductor"
Issued September 1, 2009
Technology Synopsis
This patent relates to transflective (readable in both bright and dark conditions) liquid crystal displays. The invention describes a pixel structure where at least one of the common and pixel electrodes is composed of both a wiring portion and an electrode portion, with the electrode portion being at least partially made of a transparent electric conductor. This design allows light from a reflecting face below the panel to pass through the transparent part of the electrode, improving the display's brightness (’347 Patent, Abstract; col. 5:10-25).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶69).
Accused Features
The complaint alleges that the layered structure of the common and pixel electrodes in Defendant's TFT-LCD panels, which allegedly include transparent portions, infringes the '347 patent (Compl. ¶70-73).
U.S. Patent No. 7,995,047 - "Current Driving Device"
Issued August 9, 2011
Technology Synopsis
This patent describes a current driving device, such as for an LED backlight, designed for high-speed calibration and stable current output. The invention comprises multiple current output circuits, each capable of operating in three modes: a "voltage supply mode" to quickly pre-charge a holding capacitor to a reference voltage, a "current supply mode" for fine-tuned calibration using a reference current, and a "current output mode" for normal operation. This multi-mode approach is intended to speed up the calibration process, especially when reference currents are small (’047 Patent, Abstract; col. 2:4-10).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶87).
Accused Features
The infringement allegations target Defendant's power supply board (model TPD MT5583T.PA561) and its MPS3398A chipset, which are alleged to operate in the three claimed modes (Compl. ¶87, ¶94).
U.S. Patent No. 8,093,830 - "Semiconductor Light Source Driving Apparatus and Semiconductor Light Source Driving Method"
Issued January 10, 2012
Technology Synopsis
This patent discloses a driving apparatus for a semiconductor light source (e.g., LED) that aims to maintain stable control performance regardless of the drive current. The key feature is an "impedance detecting circuit" that detects the impedance of the light source. The output voltage controlling circuit uses this detected impedance information, along with a comparison of the actual and commanded current, to control the output voltage. This feedback mechanism allows the control loop gain to remain constant even as the light source's electrical characteristics change with drive level (’830 Patent, Abstract).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶110).
Accused Features
The accused instrumentality is again the power supply board and its MPS3398A chipset, which the complaint alleges contains an impedance detecting section and a control logic that uses impedance feedback to control the output voltage (Compl. ¶118-119).
U.S. Patent No. 7,414,682 - "Liquid Crystal Display Unit and Production Method Thereof"
Issued August 19, 2008
Technology Synopsis
This patent is directed to transversal electric field type (e.g., In-Plane Switching or IPS) displays, known for wide viewing angles. The invention describes a pixel structure where at least one of the signal lines, pixel electrode, or common electrode is partially constructed from a light-transmitting conductive layer and a light-non-transmitting conductive layer. By engineering which parts of the pixel are transparent versus reflective or opaque, this design aims to improve both luminance (brightness) and contrast (’682 Patent, Abstract; col. 2:35-50).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶132).
Accused Features
The complaint accuses the physical structure of the pixels in Defendant's TFT-LCD panels, alleging they use a combination of light-transmitting and non-transmitting conductive layers for the electrodes and signal lines (Compl. ¶137).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant’s TFT-LCD panels and modules, exemplified by model V236BJ1-D03, and associated power supply boards, exemplified by model TPD MT5583T.PA561 (Compl. ¶4, ¶35, ¶87). These components are allegedly incorporated into end-user products such as the Vizio TV model D24h-J09 (Compl. ¶35).
Functionality and Market Context
The accused TFT-LCD panels are the core visual components of electronic displays, containing the liquid crystal, electrodes, and driver circuitry necessary to form an image (Compl. ¶36-40). The accused power supply boards contain the circuitry, including chipsets like the MPS3398A, that drives the LED backlight illuminating the LCD panel (Compl. ¶87, ¶91). The complaint alleges Defendant is a "leader in the global TFT-LCD market," with its products used in a wide range of consumer electronics including TVs, monitors, notebooks, and tablets (Compl. ¶22). The complaint provides an annotated photograph showing a power supply board mounted on the back of a television (Compl. p. 33, ¶87).
IV. Analysis of Infringement Allegations
'377 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a liquid crystal panel comprising liquid crystal cells, a first plate disposed on a displaying side of the cells, and a second plate disposed on a reverse side of the cells | The accused TFT-LCD model V236BJ1-D03 comprises a liquid crystal panel with liquid crystal cells between a first plate and a second plate. | ¶36 | col. 2:1-5 |
| a liquid crystal driver electrically connected with the liquid crystal panel through a circuit pattern | The accused product's liquid crystal driver is connected to the panel via a circuit pattern. A photograph depicts the liquid crystal panel, drivers, and circuit pattern (Compl. p. 14, ¶37). | ¶37 | col. 2:6-8 |
| a light shielding material disposed adjacent said liquid crystal driver so as to prevent an outer light from being incident to said liquid crystal driver | The accused product includes a light shielding material placed adjacent to the liquid crystal driver. The complaint provides a photograph identifying this material (Compl. p. 14, ¶38). | ¶38 | col. 2:9-11 |
| a film carrier comprising said circuit pattern formed on a resin film | The accused device comprises a film carrier with a circuit pattern formed on a resin film. A photograph identifies the film carrier and circuit pattern (Compl. p. 15, ¶39). | ¶39 | col. 5:45-47 |
| wherein said liquid crystal driver is mounted on the liquid crystal panel by a light shielding resin disposed on said liquid crystal panel so as to cover one end of the film carrier and a side surface of said liquid crystal driver | The liquid crystal driver is allegedly mounted using a light shielding resin that covers one end of the film carrier and the side of the driver chip. A photograph with annotations illustrates this configuration (Compl. p. 15, ¶40). | ¶40 | col. 5:48-52 |
Identified Points of Contention
- Scope Questions: A central question may be whether the material identified as a "light shielding resin" in the complaint performs the dual functions required by the claim: both mounting the driver and covering the specified surfaces. The construction of "mounted on ... by" could be a focal point, as it suggests the resin is the primary agent of attachment.
- Technical Questions: What evidence does the complaint provide that the material identified is, in fact, a "resin" and that it performs the claimed shielding and mounting functions? The analysis relies on visual inspection from photographs, raising the question of whether physical analysis would confirm the material composition and specific method of attachment.
'706 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a liquid crystal panel comprising liquid crystal cells, a first plate disposed on a displaying side of the cells, and a second plate disposed on a reverse side of the cells | The accused TFT-LCD model V236BJ1-D03 contains a liquid crystal panel with cells between first and second plates. | ¶51 | col. 6:21-25 |
| a liquid crystal driver electrically connected with the liquid crystal panel through a circuit pattern | The liquid crystal driver in the accused product is electrically connected to the panel via a circuit pattern. | ¶52 | col. 6:26-28 |
| a first light shielding material disposed adjacent a face of said liquid crystal driver so as to prevent an outer light from being incident to said liquid crystal driver | The accused product allegedly includes a first light shielding material next to one face of the driver, as identified in a complaint photograph (Compl. p. 19, ¶53). | ¶53 | col. 6:29-32 |
| a second light shielding material disposed adjacent an opposite face of said liquid crystal driver so as to prevent an outer light from being incident to said liquid crystal driver | The accused product allegedly includes a second light shielding material next to the opposite face of the driver, as shown in a complaint photograph (Compl. p. 20, ¶54). | ¶54 | col. 6:33-36 |
| a diffusion sheet located adjacent said liquid crystal display panel, wherein said diffusion sheet comprises a light diffusing area and a light absorbing area located on the outer periphery thereof, the light diffusing area serving to diffuse illumination light from a light source...and the light absorbing area serving to absorb the extraneous light incident on said liquid crystal driver | The accused product contains a diffusion sheet with a light diffusing area and a light absorbing area on its periphery. An annotated photograph identifies these distinct areas and their alleged functions (Compl. p. 21, ¶56). | ¶55-56 | col. 6:37-46 |
Identified Points of Contention
- Scope Questions: Does the accused device contain two distinct components that meet the definitions of a "first light shielding material" and a "second light shielding material"? The complaint identifies materials on opposite sides of the driver, but a potential dispute could arise over whether they are separate and distinct materials as contemplated by the patent.
- Technical Questions: What is the primary technical purpose of the "light absorbing area" on the accused diffusion sheet? The claim requires it to "serv[e] to absorb the extraneous light incident on said liquid crystal driver," raising the evidentiary question of whether this is its intended function or merely an incidental property of a feature designed for another purpose, such as framing or light sealing.
V. Key Claim Terms for Construction
Term: "mounted on the liquid crystal panel by a light shielding resin"
(from ’377 Patent, Claim 1)
Context and Importance
This phrase is central to infringement, as it defines the method of attachment for the liquid crystal driver. The theory of infringement hinges on the allegation that the accused product uses this specific material as the mounting agent. Practitioners may focus on whether "by" implies that the resin is the primary or sole means of attachment.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification describes applying "Silicon resin as a light shielding resin 110...to the bottom surface of the upper panel 101" (’377 Patent, col. 3:31-33). This general description could support an interpretation where any applied shielding resin that contributes to mounting satisfies the limitation.
- Evidence for a Narrower Interpretation: The claim language is highly specific, requiring the resin to be "disposed on said liquid crystal panel so as to cover one end of the film carrier and a side surface of said liquid crystal driver" (’377 Patent, col. 5:49-52). This suggests the resin must have a specific geometry and perform a covering function in addition to mounting, potentially narrowing the term to a specific embodiment.
Term: "light absorbing area"
(from ’706 Patent, Claim 1)
Context and Importance
The infringement case for the ’706 patent depends on mapping this functional limitation to a physical feature of the accused product's diffusion sheet. The dispute will likely center on whether the identified black-colored periphery of the sheet has the primary purpose of absorbing stray light incident on the driver, as claimed.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification states the "light absorption area 402...is colored in black" (’706 Patent, col. 3:48-51). A party could argue that any black-colored area on the periphery, which inherently absorbs light, meets the definition.
- Evidence for a Narrower Interpretation: The claim includes the functional language "serving to absorb the extraneous light incident on said liquid crystal driver" (’706 Patent, col. 6:44-46). A defendant may argue this requires the area to be specifically designed and placed for this purpose, not merely having the incidental property of being light-absorbent.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement for the ’706, ’347, ’047, ’830, and ’682 patents. These allegations are based on Defendant’s alleged knowledge of the patents, stemming from notice letters sent by a prior patent owner beginning in February 2017 (Compl. ¶57, ¶75, ¶98, ¶120, ¶139). The complaint further alleges affirmative acts of inducement, such as creating distribution channels for the accused products in the U.S. and providing instructions or manuals (Compl. ¶58, ¶76, ¶99, ¶121, ¶140).
Willful Infringement
Willfulness is alleged for all asserted patents. For the ’706, ’347, ’830, and ’682 patents, the claim is based on alleged pre-suit knowledge from the 2017 and 2020 notice letters (Compl. ¶60, ¶78, ¶123, ¶142). For the ’377 and ’047 patents, the allegation is based on knowledge obtained "at least as early as the filing date of the original complaint," suggesting a theory of post-suit willfulness (Compl. ¶41, ¶98).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central theme across the structural patents ('377, '706, '347, '682) will be one of structural and functional correspondence: Do the physical materials and layers identified in photographs of the accused Innolux panels—such as the "light shielding resin," the dual "light shielding materials," and the composite "transparent electric conductor"—possess the specific compositions, configurations, and functions required by the asserted claims, or is there a mismatch between the patent's specific requirements and the accused product's actual construction?
- For the driver circuitry patents ('047, '830), a key evidentiary question will be one of operational equivalence: Does the accused MPS3398A chipset, as implemented on the Innolux power supply board, actually perform the specific multi-mode operational sequences and utilize detected impedance in its control loop as claimed, or do the complaint's infringement theories rely on a functional interpretation of the chipset's block diagrams that does not reflect its real-world operation?
- A significant issue for potential damages will be pre-suit knowledge and intent: What is the evidentiary weight of the alleged notice letters from a prior patent owner dating back to 2017, and can the plaintiff establish that Innolux's conduct after receiving these notices demonstrates the specific intent required for inducement and rose to the level of objective recklessness required for willful infringement?