Televo LLC v. Acer Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (NM)
  • Defendant: Acer Inc. (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00719, E.D. Tex., 07/16/2025
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a unified text entry system for electronic devices that combines predictive and single-character input methods.
• Technical Context: The technology addresses methods for entering text on compact devices, such as mobile phones, where combining the speed of predictive text with the precision of direct letter entry is a key usability challenge.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 8,521,927, “System and method for text entry,” issued August 27, 2013 (’927 Patent).

• The Invention Explained:

  • Problem Addressed: The patent describes a trade-off in mobile text entry systems. "Predictive-text" systems using reduced keypads are fast for common words but suffer "considerable degradation in typing speed and comfort" when a word is not in the dictionary. (’927 Patent, col. 1:17-21). Conversely, traditional "single-letter" entry is precise but slower and requires more space or finger movement. The patent notes that switching between these two modes is often "cumbersome." (’927 Patent, col. 5:11-14).
  • The Patented Solution: The invention proposes a "unified text entry system" that allows a user to choose between a "letter group" operation (ambiguous, for predictive text) and a "single letter" operation (unambiguous) for each character entered, without changing modes. (’927 Patent, col. 5:15-21). For example, on a single multi-letter key, a simple press could input the letter group (e.g., 'd,e,f'), while a directional swipe starting on the same key could input a specific single letter (e.g., 'e'). (’927 Patent, col. 5:61-col. 6:6). A text prediction engine then processes this mixed sequence of ambiguous and unambiguous entries to generate a word list. (’927 Patent, Abstract).
  • Technical Importance: This approach sought to merge two distinct text-entry paradigms into a single, seamless user action, giving users letter-by-letter control over the trade-off between speed and ambiguity. (’927 Patent, col. 5:36-44).

• Key Claims at a Glance:

  • The complaint asserts infringement of "Exemplary '927 Patent Claims" without identifying specific claims (Compl. ¶11). Independent claim 1 is a representative system claim.
  • Independent Claim 1, key elements:
    • An input subsystem that receives user input operations as "letter entry input operations" from a plurality of keys, where each operation is a "single keystroke performed on a single key."
    • Each "letter entry input operation" is interpreted as a "single letter location entry."
    • Each "single letter location entry" comprises either a "single letter operation" that selects a specific letter or a "letter group operation" that selects a group of letters.
    • A text prediction subsystem that receives a sequence of both single letter and letter group operations and produces a list of possible words from a database.
    • A word processing subsystem that displays the word list to the user for selection.
  • The complaint does not explicitly reserve the right to assert dependent claims, but the prayer for relief requests judgment of infringement for "one or more claims." (Compl. p. 4, ¶B).

III. The Accused Instrumentality

• Product Identification: The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2, which was not publicly filed with the complaint. (Compl. ¶¶11, 16).

• Functionality and Market Context: The complaint alleges that the accused products "practice the technology claimed by the '927 Patent." (Compl. ¶16). This suggests the accused products are electronic devices (e.g., smartphones, tablets, or laptops) that incorporate a text entry system. The complaint does not provide sufficient detail for analysis of the specific functionality or market context of any Acer product.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts in an "Exhibit 2" that purportedly compare the asserted patent claims to the accused products (Compl. ¶16). In the absence of these charts or any specific factual allegations in the complaint body, the infringement theory is stated in a conclusory manner. Plaintiff alleges that "the Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '927 Patent Claims." (Compl. ¶16). The complaint alleges direct infringement by Defendant and its employees, as well as induced infringement through the sale of products and distribution of user-facing materials (Compl. ¶¶11, 12, 14, 15).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "single keystroke"

• Context and Importance: This term defines the fundamental user action ("letter entry input operation") that the system interprets. Its construction is critical because the accused products are likely modern touch-screen devices. Whether a complex gesture like a swipe or a touch-and-hold on a screen constitutes a "single keystroke" will be a central point of dispute.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Dependent claim 3 explicitly defines "keystroke" as comprising "touching, pressing, moving, swiping, titling, sliding or performing any other gesture, movement or displacement over a key." (’927 Patent, col. 10:62-66). The specification also repeatedly describes embodiments where a "press" is a group operation and a "swipe" is a single letter operation, treating both as valid inputs. (’927 Patent, col. 5:61-col. 6:6).
  • Evidence for a Narrower Interpretation: A defendant may argue that in the context of independent claim 1, the plain and ordinary meaning of "keystroke" at the time of invention implied a traditional button press, and that the broader definition in dependent claim 3 should not be imported into the independent claim.

• The Term: "single letter location entry"

• Context and Importance: This term appears to be a neologism created by the patentee to describe the conceptual input that results from a "single keystroke." Practitioners may focus on this term because its definition is central to the core inventive concept: that a single physical location (e.g., one virtual key) can generate two different types of input (a single letter or a group of letters). How this "location entry" is defined will determine whether the accused systems, which may use different methods for disambiguation, fall within the claim scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes embodiments where different actions on the same key area produce different results. For example, "key 132 press corresponds to the letter group 'a' 'b' and 'c'," while a "swipe to the left starting over key area 132 is interpreted as typing the letter 'a'." (’927 Patent, col. 5:63-col. 6:3). This suggests a "location entry" is a flexible concept tied to a key's spatial area, capable of generating different outputs based on the gesture performed within that area.
  • Evidence for a Narrower Interpretation: The phrasing "a single letter location is entered by one and only one said letter entry input operation" could be argued to imply a more rigid, one-to-one relationship between a keystroke and the resulting "location entry" that an accused system may not possess. (’927 Patent, col. 9:32-34).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users to use the products in an infringing manner. (Compl. ¶14).
• Willful Infringement: The complaint alleges that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement." (Compl. ¶13). The allegations appear to establish a basis for post-filing willfulness, as there is no mention of pre-suit notice or knowledge. (Compl. ¶15).

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

• A central issue will be one of claim scope: can the term “single keystroke,” as used in the independent claims, be construed broadly enough to encompass the variety of user inputs on modern touch interfaces (e.g., taps, long presses, swipes), as strongly suggested by the patent’s specification and dependent claims?

• A key evidentiary question will be one of factual correspondence: assuming the complaint is amended to identify specific products, does the text entry software on Acer’s devices actually practice the claimed method? Specifically, does it interpret a user action at a single key "location" as either a "single letter operation" or a "letter group operation" that are both fed into a text prediction engine, or does it use a fundamentally different architecture for text prediction and disambiguation?

• A primary procedural question will be the sufficiency of the pleadings: the complaint’s failure to identify any specific accused product or provide any factual basis for infringement beyond referencing an unfiled exhibit raises questions about whether it meets the plausibility standards required by federal pleading rules.