Televo LLC v. Cipherlab USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (New Mexico)
  • Defendant: CipherLab USA, Inc. (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00720, E.D. Tex., 07/16/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business in the district and committing alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s text entry systems infringe a patent related to a unified method for inputting text using both specific single-letter selections and ambiguous letter-group selections.
• Technical Context: The technology concerns text input methods for electronic devices, a field critical for user experience on compact devices like smartphones and data terminals where full-sized physical keyboards are impractical.
• 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

Date	Event
2007-07-07	’927 Patent Application Filing Date
2013-08-27	’927 Patent Issue Date
2025-07-16	Complaint Filing Date

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

U.S. Patent No. 8,521,927 - System and method for text entry

The Invention Explained

• Problem Addressed: The patent describes a challenge with text entry on compact devices. Traditional predictive text systems (e.g., T9) that group letters on keys are efficient for common words but become slow and cumbersome if a user needs to enter a word not in the device's dictionary. The patent notes that switching between a predictive mode and a single-letter entry mode is often inefficient. (Compl. ¶ 9; ’927 Patent, col. 1:5-21, 5:11-14).
• The Patented Solution: The invention proposes a "unified text entry system" that allows a user to choose, on a letter-by-letter basis, whether to input an ambiguous "letter group" (e.g., pressing '2' for the group 'a,b,c') or a specific "single letter" (e.g., performing a specific gesture on the '2' key to select only 'b'). A text prediction subsystem then processes this mixed sequence of ambiguous and unambiguous inputs to generate a list of suggested words. (’927 Patent, Abstract; col. 5:40-6:6). This architecture is depicted in the system block diagram of Figure 2. (’927 Patent, Fig. 2).
• Technical Importance: This approach aimed to combine the speed of predictive text for common words with the precision of single-character entry for uncommon words or names, without requiring the user to explicitly switch system-wide modes. (’927 Patent, col. 1:36-41).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring generally to the "Exemplary '927 Patent Claims." (Compl. ¶ 11). Independent claim 1 is representative of the patented system.
• The essential elements of independent claim 1 include:
  • An input subsystem that interprets a "single keystroke on a single key" as a "single letter location entry."
  • The input subsystem is configured to handle input operations comprising both "single letter operations" (selecting one specific letter) and "letter group operations" (selecting a group of possible letters).
  • A text prediction subsystem that receives a sequence containing both types of operations and produces a word list from a database.
  • A word processing subsystem that displays the word list and processes the user's selection.
• The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers to "Exemplary Defendant Products" that are detailed in charts within an "Exhibit 2." (Compl. ¶¶ 11, 16). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint alleges that the unspecified "Exemplary Defendant Products" practice the technology claimed in the ’927 Patent. (Compl. ¶ 16). Based on the patent's subject matter, these products are presumed to be electronic devices that include a text entry system, such as mobile computers or data terminals. The complaint provides no specific details regarding the functionality or market position of any accused product.

Visual Evidence

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations in its body, instead incorporating by reference an unprovided "Exhibit 2." (Compl. ¶¶ 16-17). The narrative infringement theory is that the "Exemplary Defendant Products" incorporate technology that "satisfy all elements of the Exemplary '927 Patent Claims," including systems for text entry that receive user inputs and generate predicted words. (Compl. ¶ 16). Without the specific product details or claim charts from Exhibit 2, a detailed element-by-element analysis is not possible.

Identified Points of Contention

• Scope Questions: A primary question may be whether a modern predictive keyboard performs a "letter group operation" as the patent contemplates. The patent appears to describe an operation that creates ambiguity for the system to resolve (e.g., T9 style), whereas many modern keyboards register distinct, unambiguous single-letter inputs and use prediction algorithms based on that stream. The case may turn on whether the term "letter group operation" can be construed to read on the predictive functionality of modern keyboards.
• Technical Questions: The complaint lacks factual allegations explaining how the accused products meet the core limitation of allowing a user to perform both a "single letter operation" and a "letter group operation" with a "single keystroke." A key technical question will be what specific user action on an accused device constitutes a "letter group operation" distinct from a "single letter operation," and what evidence demonstrates that the underlying system processes these inputs differently as required by the claim.

V. Key Claim Terms for Construction

"letter group operation"

• Context and Importance: This term is at the heart of the invention, which distinguishes itself by combining these ambiguous inputs with unambiguous "single letter operations." The viability of the infringement claim may depend on whether the accused products' functionality can be characterized as performing "letter group operations."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the concept generally as an input that "select[s] groups of letters form the alphabet in each input operation step," which is characteristic of a "reduced keyboard arrangement." (’927 Patent, col. 5:1-6). This could support an argument that any predictive system that considers multiple letter possibilities based on a key press performs a "letter group operation."
  • Evidence for a Narrower Interpretation: The patent's primary example of a "letter group operation" is a press on a multi-letter numeric key, such as pressing the '8' key to input the group {'t', 'u', 'v'}, which the prediction subsystem must then disambiguate. (’927 Patent, col. 6:14-22). This could support a narrower construction requiring an input that is inherently ambiguous at the time of entry.

"single keystroke"

• Context and Importance: Claim 1 requires that the system interpret a "single keystroke" to perform either a single letter or letter group operation. How broadly "single keystroke" is defined will be critical to determining whether the complex interactions with modern touchscreens (e.g., tap, long-press, swipe-from-key) fall within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims state a "keystroke" can comprise "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 suggests a broad definition that is not limited to a simple mechanical press.
  • Evidence for a Narrower Interpretation: The patent's description of the preferred embodiment in Figure 1 focuses on "push button keys" on a "numeric keypad" (130) and distinguishes between a "press" operation (for a letter group) and a "swipe" operation (for a single letter). (’927 Patent, col. 6:49-62). A defendant might argue this context limits "keystroke" to a single, continuous user action on a defined key area.

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 a manner that allegedly infringes the ’927 Patent. (Compl. ¶ 14).

Willful Infringement

The complaint asserts that Defendant has had "actual knowledge" of its alleged infringement since, at least, the service of the complaint and associated claim charts. The allegation of ongoing infringement after receiving this notice forms the basis for the willfulness claim. (Compl. ¶¶ 13, 15).

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

1. A central issue will be one of definitional scope: can the term "letter group operation," which the patent illustrates with T9-style ambiguous inputs, be construed to cover modern predictive text systems that primarily operate on a stream of unambiguous single-letter inputs from a QWERTY-style soft keyboard?
2. A key evidentiary question will be one of technical implementation: given the complaint's lack of specifics, Plaintiff will need to present evidence of what specific user actions on the accused products constitute a "single keystroke" that the system can interpret as either a "single letter operation" or a "letter group operation," as required by the patent's claims.