Onscreen Dynamics LLC v. Lithia Motors Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Onscreen Dynamics, LLC (Delaware)
  • Defendant: Lithia Motors Inc. (Oregon)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:25-cv-00536, E.D. Tex., 05/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that touchscreen displays in vehicles sold by Defendant infringe two patents related to user interfaces that employ a "virtual bezel."
• Technical Context: The technology addresses the design of touchscreens on electronic devices, aiming to maximize usable screen area while preventing accidental inputs from a user's hand holding the device.
• Key Procedural History: The U.S. Patent No. 9,645,663 is a continuation of the application that issued as U.S. Patent No. 9,395,917. The complaint alleges that the patents-in-suit have been cited as references over 20 times by technology companies and the USPTO.

Case Timeline

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

U.S. Patent No. 9,395,917 - Electronic Display with a Virtual Bezel

• Patent Identification: U.S. Patent No. 9,395,917, "Electronic Display with a Virtual Bezel," issued July 19, 2016.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a conflict in the design of touchscreen devices: physical bezels are necessary to prevent unintended touches from a user's hand, but they take up space that could otherwise be used for a larger display (’917 Patent, col. 1:31-49).
• The Patented Solution: The invention proposes replacing the physical bezel with a "virtual bezel"—a portion of the touchscreen display itself, typically along the edges, that is programmed to have a different and more limited response to touch inputs compared to the primary, central "active touchscreen region" (’917 Patent, col. 2:6-21, Fig. 2). This allows the display to extend to the physical edges of the device while the virtual bezel area serves as a safe place for a user to grip the device without causing an "unexpected interaction" (’917 Patent, col. 1:33-35).
• Technical Importance: This approach is described as enabling a "bezel-free or bezel-less touchscreen display" that provides a larger display area and "striking improvement in terms of aesthetic appeal" (’917 Patent, col. 1:47-49).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶51).
• Independent Claim 1 of the ’917 Patent recites:
  • A virtual bezel display screen comprising a virtual bezel area and an active touchscreen region.
  • The virtual bezel area has a touchscreen layer with a first mode of response and displays a first portion of content.
  • The active touchscreen region is substantially disposed within the virtual bezel area, has a touchscreen layer with a second mode of response, and displays a second portion of content.
  • A gestural software application produces the first mode of response in the virtual bezel area, where that response is configured to "selectively interpret touch-based inputs as intentional user input."

U.S. Patent No. 9,645,663 - Electronic Display with a Virtual Bezel

• Patent Identification: U.S. Patent No. 9,645,663, "Electronic Display with a Virtual Bezel," issued May 9, 2017.

The Invention Explained

• Problem Addressed: As a continuation of the ’917 Patent’s application, the ’663 Patent addresses the same technical problem of balancing maximum screen size with the need to prevent inadvertent touch inputs on handheld devices (’663 Patent, col. 1:33-51).
• The Patented Solution: The ’663 Patent similarly describes a display system with distinct regions: an "active touchscreen region" with a standard mode of response and an adjacent "virtual bezel region" with a second, different mode of response (’663 Patent, Abstract). The solution is again implemented via a "gestural software application" that differentiates between intentional and unintentional touches, particularly in the bezel region (’663 Patent, col. 4:27-30).
• Technical Importance: The invention is presented as an improvement that provides the benefits of a physical bezel (preventing unintended interaction) without its physical limitations, thereby allowing for larger, edge-to-edge displays (’663 Patent, col. 1:46-59).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶55).
• Independent Claim 1 of the ’663 Patent recites:
  • A display system with a touch-sensitive display screen.
  • An active touchscreen region of the display with a first mode of response to a first set of touch-based inputs.
  • A virtual bezel region along one or more edges, adjacent to the active region, with a second mode of response to a second set of touch-based inputs.
  • Non-transitory memory storing a gestural software application that is configured to produce the second mode of response in the virtual bezel region.
  • The second mode of response is configured to "selectively interpret touch-based inputs as intentional user input" intended to affect the content in the active region.

III. The Accused Instrumentality

Product Identification

The complaint accuses "unlicensed vehicles that include electronic devices with touchscreens" that are made, used, sold, or imported by the Defendant (Compl. ¶51, ¶55). The Defendant, Lithia Motors Inc., is an automotive retailer.

Functionality and Market Context

The accused instrumentalities are the in-vehicle infotainment and control systems featuring touchscreen displays. The complaint alleges these systems provide the "claimed features" of the patents-in-suit (Compl. ¶51, ¶55). The specific operational details of these systems are not described in the body of the complaint, but are instead incorporated by reference to external exhibits not provided with the complaint (Compl. ¶51, ¶55). The complaint alleges that Defendant advertises these vehicles for sale on its website, which aids and abets the alleged infringement (Compl. ¶52, ¶56).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of both the ’917 and ’663 patents but incorporates its specific infringement contentions by reference to a series of preliminary claim charts (Exhibits C-L), which were not filed with the complaint itself (Compl. ¶51, ¶55). Therefore, a detailed element-by-element analysis is not possible from the provided documents.

The narrative infringement theory is that the touchscreen systems in vehicles sold by Defendant practice the patented inventions. This suggests the complaint will argue that these vehicle touchscreens are designed with a primary interactive area (the "active touchscreen region") and peripheral areas that respond differently to touch, thereby functioning as the claimed "virtual bezel area/region." The complaint does not specify which vehicle makes, models, or infotainment system suppliers are implicated. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A potential dispute may arise over whether the patent claims, which describe the invention heavily in the context of handheld electronic devices like phones and tablets (’917 Patent, Fig. 1; col. 4:8-10), can be read to cover in-vehicle displays that are typically fixed in a dashboard and not held by the user.
  • Technical Questions: The claims of both patents require a "gestural software application" or its equivalent that produces a specific mode of response. A central technical question will be whether the accused vehicle systems contain such a specific software component or merely implement a generic form of edge-touch rejection that does not meet the claim limitations as construed.

V. Key Claim Terms for Construction

For U.S. Patent No. 9,395,917 and U.S. Patent No. 9,645,663

• The Term: "virtual bezel area" / "virtual bezel region"

• Context and Importance: This term is the core of the invention. Its definition will determine whether the accused vehicle touchscreens, which may have some form of edge-touch differentiation, fall within the scope of the claims. Practitioners may focus on whether the term requires a region that is consciously designed and designated as a "bezel" for gripping, or if any screen area with a different touch-response profile qualifies.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims define the area functionally by its "mode of response" to touch inputs, which could be argued to cover any technically distinct touch zone, regardless of its purpose (’917 Patent, cl. 1). The specification also notes the virtual bezel can be a "pre-defined area" or personalized by the user, suggesting flexibility (’917 Patent, col. 2:21-26).
  • Evidence for a Narrower Interpretation: The term "bezel" itself carries connotations of a frame. The specification repeatedly states the function is to "prevent any unintended touch of a user's hand with the touchscreen display" when holding the device (’917 Patent, col. 1:32-35; col. 4:63-65). This could support a narrower construction tied to solving the problem of gripping a handheld device, potentially excluding fixed in-dash automotive displays.

• The Term: "gestural software application"

• Context and Importance: This term appears in claim 1 of the ’917 patent and is functionally equivalent to the software described in claim 1 of the ’663 patent. The construction of this term is critical because it links the claimed structure (the screen regions) to a specific functional component. The dispute will likely center on how sophisticated this "software application" must be.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the software's function as determining operating characteristics of the virtual bezel and modifying output based on touch location, which could be argued to cover any driver or firmware that manages touch input differentiation (’917 Patent, col. 4:23-30; Fig. 4).
  • Evidence for a Narrower Interpretation: The patent provides a detailed software interaction diagram (Fig. 5) and lists specific rules and gesture types (Fig. 10), which could be argued to limit the term to a software module that performs these or similar complex logical steps, rather than a simple, low-level touch filter (’917 Patent, col. 5:4-32).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b) (Compl. ¶51, ¶55). The factual basis asserted is that Defendant, with specific intent or willful blindness, aids and abets infringement by "advertising vehicles for sale on Defendant's website" and by making, using, selling, or importing the vehicles containing the accused touchscreen devices (Compl. ¶51-52, ¶55-56).
• Willful Infringement: The complaint alleges Defendant had knowledge of the patents and their infringement "no later than the service of this complaint" (Compl. ¶51, ¶55). This allegation appears to form a basis for post-filing willfulness and enhanced damages, but does not assert pre-suit knowledge of the patents.

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

1. A core issue will be one of definitional scope: can the term "virtual bezel," described in the patents primarily to solve the problem of gripping a handheld device, be construed to cover the peripheral areas of a fixed, in-dash automotive touchscreen that is not held by the user?
2. A second key issue will be one of causation and intent: as the complaint is filed against a vehicle retailer rather than a manufacturer, a central question for the inducement claim will be whether Plaintiff can produce evidence that Lithia Motors acted with the specific intent required under § 271(b) to encourage its customers to infringe the patents, beyond merely advertising and selling vehicles.
3. A key evidentiary question will be one of technical implementation: assuming the claim terms are construed broadly enough to cover automotive displays, does the software in the accused systems perform the specific function of "selectively interpret[ing] touch-based inputs as intentional user input" as required by the claims, or does it use a more generic form of touch rejection that falls outside the patented invention?