Televo LLC v. TCL Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (New Mexico)
  • Defendant: TCL Corporation (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00723, E.D. Tex., 07/17/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation, and further alleges that Defendant has committed acts of infringement and caused harm within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a unified text entry system for electronic devices that combines predictive (letter group) and direct (single letter) input methods.
• Technical Context: The technology addresses methods for entering text on compact electronic devices, a critical function for user interfaces on mobile phones and similar hardware.
• 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.
• The Invention Explained:
  • Problem Addressed: The patent seeks to solve the trade-off between two common text input methods on compact devices. Predictive text systems (using "letter group" operations) are fast for common words but fail when a word is not in the dictionary, degrading the user experience. Conversely, direct single-letter entry is precise but can be slow and require more space or complex finger movements (’927 Patent, col. 1:7-21, col. 5:1-13). The patent notes that switching between these two modes on a single device is often "cumbersome" (’927 Patent, col. 5:11-13).
  • The Patented Solution: The invention proposes a "unified text entry system" that allows a user to select, on a letter-by-letter basis, whether to use a "letter group" operation or a "single letter" operation without changing modes (’927 Patent, col. 5:15-21). For example, as described for the embodiment in Figure 1, a simple press on a key (e.g., key 138 with 't,u,v') is interpreted as a letter group operation for predictive text, while a directional swipe on the same key is interpreted as a single letter operation (e.g., a rightward swipe to select 'v') (’927 Patent, col. 5:61-col. 6:6). This allows the system to receive both ambiguous and unambiguous inputs within the same word entry sequence.
  • Technical Importance: This approach aimed to combine the speed of predictive text for common words with the precision of direct entry for less common words, names, or slang, thereby offering the "best of both worlds" in a single interface (’927 Patent, col. 5:20-21).
• Key Claims at a Glance:
  • The complaint does not identify specific claims but states it accuses "Exemplary '927 Patent Claims" (Compl. ¶11, ¶16). The patent contains two independent claims, Claim 1 (system) and Claim 16 (method).
  • Independent Claim 1 (System) includes these essential elements:
    • An input subsystem configured to receive user input operations as keystrokes on a plurality of keys.
    • Each input operation is a "single keystroke performed on a single key" and is interpreted as a "single letter location entry."
    • A "single letter location entry" can comprise either a "single letter operation" (selecting one letter) or a "letter group operation" (selecting 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 list and receives a user's selection.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" and states they are identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '927 Patent" (Compl. ¶16). However, it provides no specific details about the functionality of any accused product, instead incorporating the unprovided claim charts of Exhibit 2 by reference (Compl. ¶17). 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’s infringement theory is articulated through reference to "charts comparing the Exemplary '927 Patent Claims to the Exemplary Defendant Products" in Exhibit 2 (Compl. ¶16). As this exhibit is not included with the complaint, a detailed element-by-element analysis is not possible. The narrative alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" products that satisfy all elements of the asserted claims (Compl. ¶11). The complaint also alleges infringement occurs through internal testing and use of the products by Defendant's employees (Compl. ¶12).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"a single keystroke performed on a single key" (Claim 1)

• Context and Importance: This term is fundamental to the claimed invention, which unifies two distinct input types ("single letter" and "letter group") based on one action. The case may turn on whether the accused products' input mechanism can be characterized as performing a "single keystroke" that yields these dual potential interpretations. Practitioners may focus on this term to dispute whether different physical user actions (e.g., a tap vs. a swipe) constitute one "keystroke" type or two distinct types of actions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 3, which depends from Claim 2 (and thus Claim 1), defines "keystroke" broadly 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 an argument that various distinct physical gestures can all be considered a "single keystroke."
  • Evidence for a Narrower Interpretation: The detailed description consistently contrasts a "press" operation with a "swipe" operation as two different actions leading to two different outcomes (a letter group vs. a single letter) (’927 Patent, col. 6:1-6). A party could argue that a "press" and a "swipe" are separate types of operations, not two interpretations of a "single keystroke."

"single letter location entry" (Claim 1)

• Context and Importance: This appears to be a patentee-coined term for the output of a keystroke before it is resolved by the prediction subsystem. Its definition is critical because the claim requires that every letter-input keystroke be interpreted as such an "entry," which in turn can be either a single letter or a group. This structure is central to the "unified" system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim itself states that a "single letter location entry" is an umbrella concept "comprising both either (1) single letter operations... or (2) letter group operations" (’927 Patent, col. 10:35-39). This suggests it is a conceptual placeholder for an input that carries one of two meanings.
  • Evidence for a Narrower Interpretation: A defendant might argue this term requires a specific software architecture where a single data packet from the input driver is passed to the prediction subsystem, which then determines its meaning. If an accused system uses, for example, a state change (e.g., toggling a "precision mode" on and off) to differentiate inputs, it might not generate a "single letter location entry" as claimed, even if the user experience is fluid.

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 infringes the ’927 Patent (Compl. ¶14).

Willful Infringement

The complaint does not use the term "willful." However, it asserts that the filing and service of the complaint itself "constitutes actual knowledge of infringement" (Compl. ¶13). This allegation forms a basis for potential post-filing willful infringement and a request for enhanced damages under 35 U.S.C. § 284. There are no allegations of pre-suit knowledge.

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

1. Evidentiary Development: The immediate question is one of basic notice. The complaint lacks any identification of the accused products or a specific infringement theory beyond referencing an unprovided exhibit. A primary issue will be for the Plaintiff to substantiate its claims by identifying the accused instrumentalities and articulating how their specific features map to the patent’s claims.
2. Claim Construction and Scope: A core legal issue will be one of definitional scope: can the term "single keystroke," as defined and used in the patent, be construed to cover the input mechanism of the yet-to-be-identified accused products? The resolution will likely depend on whether distinct user gestures (like a tap versus a slide) are considered one type of "keystroke" or different inputs entirely.
3. Functional Mismatch: Once products are identified, a key evidentiary question will be one of technical operation: do the accused products actually implement the claimed "unified" architecture, where a single input action on a key can be interpreted as either a single letter or a letter group? Or do they achieve a similar user experience through a different, non-infringing method, such as a rapid but explicit mode-switching mechanism that falls outside the patent's claims?