Televo LLC v. OnePlus Technology Shenzhen Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (NM)
  • Defendant: OnePlus Technology (Shenzhen) Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00257, E.D. Tex., 03/05/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the District and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that certain of Defendant's products, which are not specified by name, infringe a patent related to a unified text entry system for electronic devices.
• Technical Context: The technology concerns methods for inputting text on devices with limited keyboard space, such as mobile phones, by combining predictive text with direct single-character entry.
• Key Procedural History: The complaint is the initiating document for this litigation. It does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,521,927 - "System and method for text entry," issued August 27, 2013

The Invention Explained

• Problem Addressed: The patent describes a challenge in text entry for compact devices: predictive text systems using reduced keyboards are fast for common words but inefficient for words not in the dictionary, while traditional single-letter entry is precise but can be slow or require larger keyboards (Compl. ¶9; ’927 Patent, col. 5:1-14). The patent notes that switching between these two modes of operation is often "cumbersome and consumes a considerable amount of time" (’927 Patent, col. 5:11-14).
• The Patented Solution: The invention proposes a unified text entry system that eliminates the need for explicit mode switching. It allows a user to input characters on a letter-by-letter basis using either a "letter group" operation (ambiguous, like a standard T9-style key press) or a "single letter" operation (unambiguous, like a swipe gesture on the same key) (’927 Patent, col. 5:36-44, col. 6:1-6). A text prediction subsystem then receives the mixed sequence of ambiguous and unambiguous entries and generates a list of possible words, allowing the user to seamlessly trade speed for precision within the entry of a single word (’927 Patent, Abstract; col. 6:57-64).
• Technical Importance: This approach aimed to combine the speed benefits of predictive text with the accuracy of direct entry into a single, unified user interface, potentially improving typing speed and user comfort on mobile devices (’927 Patent, col. 5:15-21).

Key Claims at a Glance

• The complaint refers to "Exemplary '927 Patent Claims" but does not identify them by number (Compl. ¶11). The analysis below focuses on independent claim 1 as a representative system claim.
• Independent Claim 1:
  • An input subsystem configured to receive user input operations.
  • The input subsystem recognizes letter entry input operations as only keystrokes performed on a plurality of keys.
  • Each letter entry input is a single keystroke on a single key, interpreted as a single letter location entry.
  • Each single letter location entry comprises either a "single letter operation" (selecting any possible letter) or a "letter group operation" (selecting a group of possible letters).
  • The plurality of keys comprises single letter keys and group letter keys.
  • A text prediction subsystem receives a sequence of both single letter and letter group operations.
  • The text prediction subsystem produces a list of possible words by searching a database and resolving the ambiguity of the letter groups.
  • A word processing subsystem displays the list and receives the user's selection.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" and "numerous other devices" made, used, or sold by the Defendant (Compl. ¶11).

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It alleges that the products "practice the technology claimed by the '927 Patent" and that this is detailed in claim charts provided as Exhibit 2 (Compl. ¶16). However, Exhibit 2 was not filed with the complaint. Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts in an attached "Exhibit 2" (Compl. ¶16-17). As this exhibit was not provided with the publicly filed complaint, a detailed claim chart analysis is not possible. The complaint’s narrative allegations state only that the "Exemplary Defendant Products practice the technology claimed by the '927 Patent" and "satisfy all elements of the Exemplary '927 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of specific factual allegations, the primary point of contention will be evidentiary. The Plaintiff will need to produce evidence demonstrating that an accused OnePlus product performs the functions required by the asserted claims. Based on the patent's claims, key technical questions may include:
  • Operational Questions: Does the accused product's keyboard software allow for both a "single letter operation" and a "letter group operation" to be initiated from the same key location through a "single keystroke"?
  • System Questions: Does the accused product's text prediction engine receive and process a mixed sequence of both ambiguous (group) and unambiguous (single letter) inputs to generate a single, unified list of word suggestions, as required by the claim?

V. Key Claim Terms for Construction

• The Term: "a single keystroke performed on a single key" (from Claim 1)

• Context and Importance: This term is fundamental to the invention's core concept of a unified input method. The infringement analysis will depend on whether different user actions on the accused device's keyboard (e.g., a quick tap, a long press, or a directional swipe originating from a key) are construed as different types of a "single keystroke" on a "single key." Practitioners may focus on this term because its breadth will determine whether modern smartphone keyboard gestures fall within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Dependent claim 3 defines "keystroke" to include "touching, pressing, moving, swiping, titling, sliding or performing any other gesture, movement or displacement over a key" (’927 Patent, col. 10:62-65). This language may support a broad definition that covers a wide variety of user interactions.
  • Evidence for a Narrower Interpretation: The primary embodiment distinguishes between a "press" operation for a letter group and a "swipe" operation for a single letter (’927 Patent, col. 5:61-col. 6:6). A party could argue that the "single keystroke" must be one of these specific, discrete actions taught in the specification, rather than any gesture more broadly.

• The Term: "text prediction subsystem ... resolves the ambiguity of letter groups" (from Claim 1)

• Context and Importance: This term defines the function of the software that generates word suggestions. The dispute may turn on whether the accused predictive text engine functions in the manner described by the patent, particularly in its handling of a mixed input stream.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification notes that "Text prediction subsystems 92 are well known in the art," which may suggest the term should be given its ordinary meaning in the field without being limited to the patent's specific embodiments (’927 Patent, col. 6:61-62).
  • Evidence for a Narrower Interpretation: The patent describes the subsystem as processing a "sequence including both of said single letter operations and of said letter groups operations" (’927 Patent, col. 9:42-44). An argument could be made that to "resolve the ambiguity" as claimed, the subsystem must be specifically designed to handle this novel mixed-input sequence, rather than being a standard engine that only processes ambiguous inputs.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14-15).
• Willful Infringement: Willfulness allegations are based on knowledge acquired upon service of the complaint. The complaint asserts that service of the complaint and its attached (but un-filed) claim charts "constitutes actual knowledge" and that any continued infringement thereafter is willful (Compl. ¶13, ¶15).

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

• A central issue will be an evidentiary one: The complaint lacks specific factual allegations tying any particular OnePlus product to the patent claims. A threshold question for the litigation will be whether Plaintiff can produce evidence that an accused product actually implements the dual-mode input system where a single key position can generate both an ambiguous "letter group" input and a specific "single letter" input.
• The case may also turn on a question of definitional scope: can the claim term "single keystroke," which originates from a patent describing early 2000s-era mobile phone interfaces, be construed to read on the complex gestures (e.g., tap, long-press, trace-typing) common in modern smartphone keyboards? The outcome may depend on whether these distinct user actions are considered variants of a "single keystroke" as envisioned by the patent.