DCT

2:25-cv-00310

Bishop Display Tech LLC v. BOE Technology Group Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00310, E.D. Tex., 08/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign entity, which may be sued in any judicial district pursuant to 28 U.S.C. § 1391(c). The complaint also asserts personal jurisdiction based on Defendant’s alleged business activities in Texas and the placement of accused products into the stream of commerce with the knowledge they would be sold in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s thin-film transistor liquid crystal displays (TFT-LCDs) and liquid crystal modules (LCMs) infringe four U.S. patents related to the physical structure of display panels and the electronic circuitry used to drive them.
  • Technical Context: The technology at issue concerns liquid crystal displays, which are foundational components for screens used in a vast array of consumer and industrial electronics, including smartphones, notebooks, monitors, and televisions.
  • Key Procedural History: The complaint alleges that Defendant has had knowledge of the asserted patents since at least July 29, 2020, based on notice letters sent by a prior patent owner, Parkside IP LLC. It further alleges that Parkside's predecessor, IP Bridge, Inc., had also previously provided notice. The complaint also suggests Defendant was aware of the patents through its own patent prosecution activities.

Case Timeline

Date Event
2000-07-31 Earliest Priority Date for ’347 Patent and ’682 Patent
2006-12-13 Priority Date for ’047 Patent
2008-07-03 Priority Date for ’830 Patent
2008-08-19 ’682 Patent Issues
2009-09-01 ’347 Patent Issues
2011-08-09 ’047 Patent Issues
2012-01-10 ’830 Patent Issues
2020-07-29 Alleged notice of infringement sent to Defendant
2025-08-26 Complaint Filed

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

U.S. Patent No. 7,583,347 - "Liquid Crystal Display Having Electrodes Constituted by a Transparent Electric Conductor"

The Invention Explained

  • Problem Addressed: The patent's background describes a trade-off in In-Plane-Switching (IPS) liquid crystal displays. While using transparent electrodes can increase brightness (luminance) compared to opaque ones that block light, their electrical field properties can create "disclination areas"—regions of misaligned liquid crystals—that degrade image contrast. (’347 Patent, col. 1:11-2:45).
  • The Patented Solution: The invention proposes a specific layered structure for the display's electrodes. It separates an electrode into a "wiring portion" and an "electrode portion." The electrode portion, which is made of a transparent conductor to let light pass, is formed in a different layer than the scanning signal line, separated by an insulator. The wiring portion remains in the same layer as the scanning signal line. This layered design aims to maximize light transmission while preventing electrical short-circuits between the different components. (’347 Patent, Abstract; col. 5:11-30).
  • Technical Importance: This design attempts to resolve a fundamental performance compromise in LCD technology by using a multi-layer architecture to manage light paths and electrical signals independently, thereby seeking to improve both luminance and reliability. (Compl. ¶43).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶44).
  • The essential elements of claim 1 include:
    • A liquid crystal panel with an array substrate, an opposing substrate, and a liquid crystal layer.
    • A reflecting face below the panel for recycling light.
    • At least one electrode (common or pixel) that is constituted by an "electrode portion" and a "wiring portion."
    • The electrode portion is at least partially made of a transparent electric conductor.
    • The electrode portion is in a layer separated by an insulator from the layer containing the scanning signal line.
    • The wiring portion is in the same layer as the scanning signal line.
  • The complaint generally alleges infringement of "one or more claims," which may suggest an intent to assert dependent claims later. (Compl. ¶42).

U.S. Patent No. 7,414,682 - "Liquid Crystal Display Unit and Production Method Thereof"

The Invention Explained

  • Problem Addressed: The patent identifies the same core problem as the ’347 patent: in transversal electric field type displays, electrodes can block light, reducing luminance, while efforts to make them transparent can create low-contrast regions. (’682 Patent, col. 1:11-2:22).
  • The Patented Solution: The invention proposes constituting at least one of the electrodes or signal lines from two different materials: a light-transmitting conductive layer and a light-non-transmitting conductive layer. The opaque, non-transmitting portion is strategically placed to block the low-contrast boundary areas from view, while the transparent portion allows light to pass through in the high-performance areas of the pixel. This composite structure is designed to improve both overall brightness and contrast. (’682 Patent, Abstract; col. 2:36-54).
  • Technical Importance: This approach offers a method to engineer the electrode structure itself to selectively manage light, simultaneously masking undesirable optical artifacts while maximizing light throughput. (Compl. ¶61).

Key Claims at a Glance

  • The complaint asserts independent claim 7. (Compl. ¶62).
  • The essential elements of claim 7 include:
    • A liquid crystal display of transversal electric field type with a panel, substrates, and signal/video lines defining pixels.
    • A pixel electrode and a common electrode opposite each other in each pixel.
    • At least one of the signal lines or electrodes is "at least partially constituted by a light-transmitting conductive layer and a light-non-transmitting conductive layer."
    • A "width of the light-transmitting conductive layer is wider than a width of the light-non-transmitting layer."
  • The complaint generally alleges infringement of "one or more claims," which may suggest an intent to assert dependent claims later. (Compl. ¶60).

U.S. Patent No. 7,995,047 - "Current Driving Device"

  • Technology Synopsis: The patent addresses non-uniformity in display image quality caused by variations between the output currents of different driver terminals. (’047 Patent, col. 1:10-25). The patented solution is a current driving device with three distinct operation modes—a voltage supply mode, a current supply mode, and a current output mode—which together allow for a high-speed calibration process that ensures uniform current output across all terminals. (’047 Patent, Abstract).
  • Asserted Claims: Independent claim 1. (Compl. ¶81).
  • Accused Features: The current driving device is alleged to be embodied in the power supply board and associated chipsets (e.g., BOE B802-1R) within BOE's LCM model no. NE135FBM-N41. (Compl. ¶81). The complaint provides an image of the BOE B802-1R chipset and alleges it performs the claimed functionality by analogy to a publicly documented MP3378 chipset. (Compl. p. 41, ¶86).

U.S. Patent No. 8,093,830 - "Semiconductor Light Source Driving Apparatus and Semiconductor Light Source Driving Method"

  • Technology Synopsis: The patent describes a solution to the problem of unstable performance in drivers for semiconductor light sources (like LED backlights), which occurs because the light source's electrical impedance and gain change depending on the drive current. (’830 Patent, col. 3:5-4:4). The invention is a driving apparatus that includes an impedance detecting circuit to monitor the light source's characteristics and an output voltage controlling circuit that uses this impedance information to adjust the control loop, thereby maintaining stable performance across different brightness levels. (’830 Patent, Abstract).
  • Asserted Claims: Independent claim 1. (Compl. ¶104, ¶113).
  • Accused Features: The semiconductor light source driving apparatus is allegedly found in BOE's LCMs, such as model no. NE135FBM-N41 (using a BOE B802-1R chipset) and model no. NV156QUM-N72 (using a TI TPS61185 chipset). (Compl. ¶104, ¶113). A photograph shows the semiconductor light source within a BOE LCM. (Compl. p. 56, ¶104).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are BOE's liquid crystal modules (LCMs), thin-film transistor liquid crystal displays (TFT-LCDs), components thereof, and downstream products incorporating them. (Compl. ¶3). The complaint identifies specific BOE models, including NV156FHM-N3D (found in a Dell P89F laptop), NE135FBM-N41 (found in an Acer Swift 3 laptop), and NV156QUM-N72 (found in an HP Spectra x360 laptop), as exemplary accused products. (Compl. ¶18, ¶44, ¶81, ¶113).

Functionality and Market Context

  • The accused products are display screens used in consumer electronics. The complaint's technical allegations focus on two aspects: (1) the micro-scale physical construction of the pixel array, including the materials and layered arrangement of electrodes and signal lines, and (2) the electronic driver circuitry on the display's power supply board, particularly the chipsets that control the current for the display's LED backlight. (Compl. ¶45-49, ¶81-91). The complaint alleges BOE is a dominant global supplier, stating that "one out of four display products in the world comes from BOE" and that it supplies major device manufacturers such as Dell, HP, and Lenovo. (Compl. ¶4, ¶18). An image of a product label from a BOE LCM model NV156FHM-N3D shows a UL Solutions mark, which the complaint alleges indicates compliance with U.S. regulations and knowledge that the products are destined for the U.S. market. (Compl. p. 6, ¶18).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,583,347 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a liquid crystal panel including an array substrate...an opposing substrate...and a liquid crystal layer... The accused BOE LCM/LCD model no. NV156FHM-N3D comprises these fundamental components of a liquid crystal display. ¶44, ¶45 col. 5:11-18
a reflecting face formed below the liquid crystal panel, wherein a light reflected on the reflecting face is transmitted through the liquid crystal panel... The accused product includes a backlight unit with a diffuser covering a reflecting face located beneath the liquid crystal panel. ¶46 col. 5:18-20
at least one electrode...is constituted by an electrode portion and a wiring portion, The pixel electrode in the accused product is alleged to be composed of a distinct "electrode portion" and "wiring portion." ¶47 col. 5:21-23
the electrode portion is at least partially constituted by a transparent electric conductor, The pixel electrode portion in the accused product is allegedly made of a transparent electric conductor. ¶48 col. 5:24-25
the electrode portion is formed in a layer separated by an insulating layer from a layer in which the scanning signal line is formed, The accused product's pixel electrode portion is allegedly formed in a layer physically separated by an insulating layer from the layer containing the scanning signal line. ¶49 col. 5:25-28
and the wiring portion is formed in the layer in which the scanning signal line is formed. The accused product's pixel wiring portion is allegedly formed in the same layer as the scanning signal line. ¶49 col. 5:28-30

Identified Points of Contention:

  • Scope Questions: A central question for claim construction may be the precise definition of "electrode portion" and "wiring portion." The dispute may focus on whether these terms require distinct structural forms (e.g., comb-shape vs. bus-line) or if a functional distinction suffices.
  • Technical Questions: The infringement analysis will depend on the interpretation of the physical evidence, such as the micrographs provided in the complaint. (Compl. p. 17, 19, 20). A key factual question will be whether the layered structure of the accused device, as determined through technical analysis, aligns with the specific layered arrangement required by the claim, particularly the relative positions of the electrode portion, wiring portion, insulating layer, and scanning signal line.

U.S. Patent No. 7,414,682 Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
A liquid crystal display of transversal electric field type comprises a liquid crystal panel in which liquid crystal is retained between a pair of substrates... The accused BOE LCM/LCD model no. NV156FHM-N3D is alleged to be a transversal electric field type display panel with these components. ¶62, ¶63 col. 4:40-43
a plurality of scanning signal lines and a plurality of video signal lines formed so as to define a plurality of pixels... The accused product's array substrate contains a matrix of scanning and video signal lines that define pixels. ¶64 col. 4:43-47
a pixel electrode and a common electrode formed opposite to each other in each pixel in a plan view... The accused product contains pixel and common electrodes arranged opposite each other within each pixel. ¶65 col. 4:47-48
at least one of the scanning signal lines, the video signal lines, the pixel electrode, or the common electrode is at least partially constituted by a light-transmitting conductive layer and a light-non-transmitting conductive layer The pixel electrode of the accused product is alleged to be a composite structure made of both a light-transmitting conductive layer and a light-non-transmitting conductive layer. ¶67 col. 4:51-55
and wherein a width of the light-transmitting conductive layer is wider than a width of the light-non-transmitting layer. The complaint alleges that the light-transmitting layer of the accused product's pixel electrode is physically wider than its light-non-transmitting layer. ¶68 col. 4:56-58

Identified Points of Contention:

  • Scope Questions: The interpretation of the phrase "partially constituted by" may be a point of contention. The question will be whether a layered structure, where one material overlies another, satisfies this limitation, or if it requires a different arrangement, such as a co-planar or core-cladding structure.
  • Technical Questions: The case may turn on a factual dispute over the physical construction and dimensions of the accused electrodes. A key evidentiary question will be whether the "width" of the light-transmitting layer is demonstrably "wider" than the light-non-transmitting layer, as required by the final limitation of the claim. The complaint’s annotated micrograph will be a primary piece of evidence on this point. (Compl. p. 31, ¶68).

V. Key Claim Terms for Construction

  • For the ’347 Patent:

    • The Term: "electrode portion" / "wiring portion"
    • Context and Importance: Claim 1 requires these two components to be in different physical layers relative to the scanning signal line. The infringement theory depends on mapping the accused product's physical structures to these distinct claim terms. Practitioners may focus on this distinction because it is the central structural novelty alleged to be infringed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the electrode portion functionally, stating its purpose is to ensure "liquid crystal molecules above an electrode portion...can be modulated." (’347 Patent, col. 5:51-55). This could support a definition based on function rather than a specific shape.
      • Evidence for a Narrower Interpretation: The detailed description and figures show the electrode portion as a "comb-shaped electrode portion" and the wiring portion as the structure connecting them. (’347 Patent, col. 5:32-37). This could support an argument that the terms are limited to these specific disclosed structures.

  • For the ’682 Patent:

    • The Term: "width"
    • Context and Importance: Claim 7 requires a direct comparison: the "width of the light-transmitting conductive layer" must be "wider than a width of the light-non-transmitting layer." The definition of "width" for these potentially complex, layered structures is therefore critical to the infringement analysis.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "width." A party could argue it should be given its plain and ordinary meaning as a measurement of the extent of something from side to side, which could be applied to the overall footprint of each layer as seen in a plan view.
      • Evidence for a Narrower Interpretation: Figure 17 and the accompanying text discuss "line width" (w1, w2) in the context of the electrodes. (’682 Patent, col. 24:35-45). This might suggest that "width" should be interpreted as a specific line-width measurement rather than a more general area or footprint, potentially narrowing the scope of the claim.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all four patents. The basis for inducement is Defendant's alleged knowledge of the patents (from notice letters and its own patent prosecution) combined with affirmative acts intended to cause infringement by its customers (e.g., Dell, Acer) and end-users. These acts are alleged to include designing and selling the accused LCMs for incorporation into products destined for the U.S., and marking the products with UL Solutions labels, which allegedly facilitates their integration into products for the U.S. market. (Compl. ¶51, ¶70, ¶93, ¶123).
  • Willful Infringement: Willfulness is alleged for all four patents. The allegations are based on Defendant's alleged pre-suit knowledge of the patents and infringement, stemming from notice letters sent on or before July 29, 2020. The complaint asserts that Defendant's continued infringing conduct despite this knowledge constitutes willful, wanton, and deliberate infringement. (Compl. ¶53, ¶72, ¶95, ¶125).

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

  • A core issue will be one of structural interpretation: Do the layered electrode configurations in BOE's accused displays, as depicted in the complaint's micrographs, satisfy the specific structural and positional limitations of the asserted claims, particularly the distinction between an "electrode portion" and "wiring portion" in separate layers (’347 Patent) and the relative "width" of the light-transmitting and non-transmitting layers (’682 Patent)?
  • A key evidentiary question will be one of technical correspondence: The infringement theories for the driver-circuitry patents (’047 and ’830) rely on allegations that BOE’s proprietary chipsets perform the same functions as commercially-known chipsets. The case will likely require a detailed technical comparison to determine if the accused chipsets actually contain the specific multi-mode calibration process (’047 Patent) and impedance-based feedback control loop (’830 Patent) required by the claims.
  • The viability of the willfulness and inducement claims will likely depend on the sufficiency of pre-suit knowledge: The case will explore whether the 2020 notice letters provided BOE with knowledge of infringement that was specific and clear enough to establish the requisite intent for indirect infringement and the egregious conduct typically required for a finding of willfulness.