Entelekon LLC v. OnePlus Technology Shenzhen Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Entelekon LLC (New Mexico)
  • Defendant: OnePlus Technology (Shenzhen) Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00806, E.D. Tex., 08/18/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the District and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s portable electronic devices with multiple displays infringe a patent related to the mechanical and user-interface systems for managing content across two screens.
• Technical Context: The technology addresses methods for integrating a secondary display into a portable device in a way that enhances multitasking capabilities without compromising portability, a key design challenge in the smartphone market.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 10,620,663 - "Multiple displays for a portable electronic device and a method of use"

• Patent Identification: U.S. Patent No. 10,620,663, "Multiple displays for a portable electronic device and a method of use," issued April 14, 2020.

The Invention Explained

• Problem Addressed: The patent’s background section identifies the trade-off between portability and screen real estate in mobile devices, noting that the small size of a single display limits the ability to run or view multiple applications simultaneously. Previous attempts at dual-display devices were described as bulky, and they lacked sophisticated software integration for automatically launching applications on the second screen. (Compl. ¶9; ’663 Patent, col. 2:6-31).
• The Patented Solution: The invention proposes a portable device with a primary display and a secondary display that can be mechanically moved between a "stowed" position, where it is out of the way, and a "deployed" position, where it is typically coplanar with the first screen. The system is designed so that a user action on the first display (e.g., selecting a link) can automatically launch a second, related application on the second display, thereby providing a more integrated multitasking experience. (’663 Patent, Abstract; col. 3:32-41; Figs. 1A-1D).
• Technical Importance: The described technology aims to provide desktop-like multitasking functionality on a portable device by combining a novel mechanical arrangement with a coordinated software user interface. (’663 Patent, col. 2:11-16).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’663 Patent, including "at least the exemplary claims...identified in the charts" (Compl. ¶11). Claim 1 is the patent's first independent claim.
• Essential elements of Claim 1 include:
  • A portable device with a primary and a secondary display.
  • The secondary display is "physically protected when stowed."
  • The secondary display runs a second application while the primary runs a first application.
  • A user action selecting "first information" on the primary display "causes the secondary display to display second information" related to the first.
  • A user action selecting "third information" on the secondary display "causes the primary display to display fourth information" related to the third.
• The complaint’s reference to "exemplary claims" suggests it reserves the right to assert additional claims, including dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name, referring to them generally as "Exemplary Defendant Products." (Compl. ¶11).

Functionality and Market Context

• The complaint alleges these products practice the technology claimed by the ’663 Patent. (Compl. ¶16). Based on the patent’s subject matter, the accused products are presumably portable electronic devices, such as foldable smartphones, that feature more than one display.
• The complaint provides no specific details regarding the functionality or operation of the accused products, instead incorporating by reference claim charts from Exhibit 2, which was not publicly filed with the complaint. (Compl. ¶17).
• The complaint does not provide sufficient detail for analysis of the products' commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges infringement through claim charts provided in an associated Exhibit 2, which was not included in the public filing. (Compl. ¶¶16-17). The core of the infringement allegation is that the "Exemplary Defendant Products practice the technology claimed by the ’663 Patent" by satisfying all elements of the asserted claims. (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern the meaning of "physically protected when stowed." The analysis could turn on whether the accused device's closed configuration provides the type and degree of protection contemplated by the patent specification.
  • Technical Questions: A key evidentiary question may be whether the software on the accused products operates in the manner required by the claims. Specifically, what evidence will show that a user's selection on the primary display "causes" the secondary display to show related information, and that this interaction is reciprocal, as recited in Claim 1 of the ’663 Patent?

V. Key Claim Terms for Construction

• The Term: "physically protected when stowed"

  • Context and Importance: This limitation defines a key structural characteristic of the claimed device. Its construction will be critical to determining whether the physical design of the accused products falls within the claim scope. Practitioners may focus on whether an exposed outer screen on a folded device meets this requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses protection against general harms like "impact, abrasion, scratches, [and] liquids," which could support a construction that does not require complete hermetic sealing. (’663 Patent, col. 7:37-39).
    • Evidence for a Narrower Interpretation: The patent analogizes the invention to a "traditional clamshell laptop" where the screen is fully enclosed when closed, potentially supporting a narrower construction that requires the stowed display to be completely covered. (’663 Patent, col. 7:27-28).

• The Term: "causes the secondary display to display second information"

  • Context and Importance: This functional limitation is central to the claimed software-based interaction between the two displays. The dispute will likely focus on the directness of the causal link between a user's action and the system's response.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides numerous examples of this functionality, such as selecting a link in an email to open a web page on the other screen, suggesting the term covers a wide range of common multitasking actions. (’663 Patent, col. 15:1-5).
    • Evidence for a Narrower Interpretation: Language describing the launch of an "appropriate second application" could be argued to require the initiation of a distinct software process, potentially excluding scenarios where an existing application merely extends its view to the second screen. (’663 Patent, col. 5:51-53).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner. (Compl. ¶14).
• Willful Infringement: Willfulness is alleged on the basis of Defendant's knowledge of the ’663 Patent obtained via service of the complaint and its continued alleged infringement thereafter. (Compl. ¶¶13, 14).

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

• A core issue will be one of structural scope: Does the physical configuration of the accused products in their closed state provide "physical protection" to the secondary display in the manner required by the claim term "stowed," or does the design fall outside this claimed feature?
• A key evidentiary question will be one of functional operation: Does the software on the accused devices create the specific, reciprocal causal link claimed in the patent—where an action on the first screen triggers a related display on the second, and vice versa—or is there a material difference in the technical implementation of the user interface?