DCT
2:25-cv-01081
Alpha Touch Group LLC v. Lenovo Group Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Alpha Touch Group LLC (Texas)
- Defendant: Lenovo Group Limited, et al (China)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 2:25-cv-01081, E.D. Tex., 10/28/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants do not reside in the United States and may be sued in any judicial district. The complaint also alleges Lenovo maintains regular and established places of business within the district, including authorized service providers and a sales office.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and computers with touch screens infringe four patents related to the physical construction and layered architecture of touch-sensitive displays.
- Technical Context: The patents address methods for manufacturing thinner, more durable, and less complex touch screens, including technologies for foldable displays and "One Glass Solution" (OGS) panels where touch sensors are integrated directly onto the cover glass.
- Key Procedural History: The complaint does not reference prior litigation, licensing history, or post-grant proceedings for the patents-in-suit. It does, however, cite prior rulings from Texas district courts and the Federal Circuit affirming personal jurisdiction over Defendant Lenovo Group Ltd. in other patent cases.
Case Timeline
| Date | Event |
|---|---|
| 2007-12-24 | Earliest Priority Date (’857 Patent, ’542 Patent) |
| 2008-02-18 | Earliest Priority Date (’675 Patent) |
| 2013-07-09 | Issue Date (U.S. Patent No. 8,482,542) |
| 2016-07-19 | Issue Date (U.S. Patent No. 9,395,857) |
| 2017-03-28 | Issue Date (U.S. Patent No. 9,606,675) |
| 2019-01-01 | Alleged Infringement Begins (approx.) |
| 2021-01-11 | Earliest Priority Date (’794 Patent) |
| 2022-11-08 | Issue Date (U.S. Patent No. 11,493,794) |
| 2025-10-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,493,794 - "Electronic Device and Method of Manufacturing the Same," issued Nov. 8, 2022
The Invention Explained
- Problem Addressed: The patent’s background section describes challenges with early foldable screens, which often used plastic films. These films could develop permanent creases after repeated folding due to low stress resistance (a low Young's modulus), degrading optical quality. The patent also notes that using traditional optical clear adhesives (OCA) to bond layers increases thickness and can lead to cracks. (’794 Patent, col. 1:24-41).
- The Patented Solution: The invention proposes a composite cover plate for an electronic device that includes an ultra-thin glass layer directly laminated with transparent covering layers (e.g., polymer films) without a separate adhesive layer. (’794 Patent, Abstract; col. 3:5-8). This direct lamination, as depicted in the layered structure of Figure 2, is intended to create a more durable, thinner, and crease-resistant screen by combining the rigidity of glass with the flexibility of polymer films. (’794 Patent, col. 8:1-14; Fig. 2).
- Technical Importance: This approach seeks to improve the mechanical durability and visual quality of foldable displays by creating a composite structure that better manages the stresses of repeated bending compared to simple plastic films or adhesive-bonded layers. (’794 Patent, col. 8:1-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶55).
- The essential elements of Claim 1 are:
- An electronic device comprising a cover plate, a touch sensing layer, and a display module.
- The cover plate includes a glass layer with a first and second surface.
- The cover plate also includes a first and a second transparent covering layer.
- The covering layers are "disposed on and in contact with" the surfaces of the glass layer and "laminated with" it.
- The glass layer is laminated between the first and second transparent covering layers.
- The complaint notes that infringement of one or more claims is alleged, preserving the right to assert others (Compl. ¶54).
U.S. Patent No. 9,606,675 - "Capacitive Touch Panel," issued Mar. 28, 2017
The Invention Explained
- Problem Addressed: The patent identifies a need for an integrally-formed touch panel with a simplified manufacturing process to lower costs and reduce thickness. Prior art methods often required separate glass substrates for the touch sensor and the protective cover lens, which were then laminated together, adding complexity, thickness, and potential points of failure. (’675 Patent, col. 1:26-41).
- The Patented Solution: The invention describes a "singular lens substrate" where the sensing circuit is integrally formed directly on one of its surfaces. The top surface of this single substrate receives user touch input, while the bottom surface is used for forming the sensing circuitry and a peripheral mask layer to hide traces. This eliminates the need for a second, dedicated substrate for the touch components. (’675 Patent, Abstract; col. 2:50-57).
- Technical Importance: This "One Glass Solution" (OGS) architecture represented a significant step in streamlining touch screen manufacturing, enabling thinner, lighter, and more cost-effective designs for consumer electronics. (Compl. ¶72).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶71).
- The essential elements of Claim 1 are:
- A capacitive touch panel with a substrate (glass or plastic) having a first and second surface.
- A sensing circuit.
- A "physical tactile inputting integration" with a peripheral masking area, where the first surface is for receiving input and the second surface is for forming the sensing circuit.
- A negative limitation: "there is no other substrate made of glass or plastic material laminated or bonded on the first surface of the substrate."
- The complaint preserves the right to assert other claims (Compl. ¶70).
U.S. Patent No. 9,395,857 - "Capacitive Touch Panel," issued July 19, 2016
- Technology Synopsis: The patent addresses simplifying touch panel manufacturing by integrating touch-sensing components with elements of a display module. The claimed solution describes a structure comprising a cover lens, a color filter substrate, and an electrode layer disposed on the color filter substrate to perform touch-sensing operations, with the components bound by an adhesive layer, consistent with "on-cell" or "in-cell" touch screen architectures. (’857 Patent, Claim 15).
- Asserted Claims: At least independent claim 15 (Compl. ¶87).
- Accused Features: The complaint alleges that products like the Motorola Moto G Power, which use LCD screens with on-cell or in-cell technology, infringe by having an electrode layer for touch sensing disposed on the color filter substrate. (Compl. ¶¶90-91).
U.S. Patent No. 8,482,542 - "Capacitive Touch Panel," issued July 9, 2013
- Technology Synopsis: This patent, related to the ’857 patent, also aims to simplify touch panel construction. It describes a different "One Glass Solution" architecture where a first electrode layer, a non-gaseous insulating layer, and a second electrode layer are all successively formed directly on one side of a single cover lens, eliminating the need for any other substrate to support the touch-sensing components. (’542 Patent, Claim 1).
- Asserted Claims: At least independent claim 1 (Compl. ¶105).
- Accused Features: The complaint alleges that products like the Lenovo ThinkPad X1 Yoga Gen 8, which purportedly use an OGS display, infringe by having a touch sensor circuit comprising two electrode layers and an insulating layer fabricated directly on the inner side of the cover glass. (Compl. ¶¶106-110).
III. The Accused Instrumentality
Product Identification
- The complaint names a wide array of Lenovo and Motorola-branded smartphones, tablets, and laptop computers, including foldable devices (e.g., Motorola Razr+ Ultra), tablets (e.g., Yoga Tab series), and laptops (e.g., IdeaPad Flex 5, ThinkPad X1 Yoga) (Compl. ¶48).
Functionality and Market Context
- The accused instrumentalities are consumer electronic devices featuring capacitive touch screens and, in some cases, flexible or foldable displays (Compl. ¶¶49, 50). The complaint alleges that these devices incorporate specific display construction technologies, such as the use of Ultra-Thin Glass (UTG) in foldable phones and "One Glass Solution" (OGS) technology in laptops and tablets, which are central to the infringement allegations (Compl. ¶¶56, 72). The complaint notes Lenovo’s position as a leading global supplier of personal computers and other devices (Compl. ¶3). A screenshot from a teardown video shows the layered construction of an accused device's display (Compl. p. 31).
IV. Analysis of Infringement Allegations
11,493,794 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cover plate comprising: a glass layer having a first surface and a second surface; | The accused Motorola Razr+ Ultra has a display assembly that includes an Ultra-Thin Glass (UTG) layer. | ¶¶56, 57 | col. 2:54-55 |
| and at least one transparent covering layer...comprising a first transparent covering layer and a second transparent covering layer... | The UTG is laminated between two protective transparent layers, such as a resin film on top and another layer on the bottom. | ¶¶56, 57 | col. 2:56-59 |
| and the glass layer is laminated between the first transparent covering layer and the second transparent covering layer; | The complaint alleges the UTG (glass layer) is situated between the two transparent protective layers. The complaint provides a diagram illustrating the lamination of ultra-thin glass with a resin film (Compl. p. 30). | ¶57 | col. 2:58-59 |
| a touch sensing layer disposed under the cover plate; | The touch sensing functionality is included as part of the AMOLED display module, located beneath the UTG and its protective layers. | ¶58 | col. 2:59-60 |
| and a display module disposed under the touch sensing layer. | The AMOLED display serves as the display module and is located under the integrated touch sensing layer. | ¶59 | col. 2:60-61 |
- Identified Points of Contention:
- Scope Questions: A central question may be the construction of "laminated with." The patent specification contrasts the invention with prior art using distinct adhesive layers (’794 Patent, col. 3:5-8). The infringement analysis may turn on whether the term, in the context of this patent, precludes the use of any adhesive material to bond the layers, and what the precise bonding mechanism is in the accused Razr+ Ultra.
- Technical Questions: What is the exact composition and structure of the "transparent covering layer[s]" in the accused device? The analysis will require evidence comparing the physical properties and method of application of these layers to the patent's description of coating and drying a polymer material layer directly on the glass (’794 Patent, col. 6:19-23).
9,606,675 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a substrate made of glass or plastic material having a first surface and a second surface; | The accused IdeaPad Flex 5 Chrome has a cover glass that serves as the substrate for the touch panel. | ¶72 | col. 2:50-51 |
| a sensing circuit; | The device's OGS display includes a touch sensor circuit. | ¶73 | col. 2:54 |
| a physical tactile inputting integration having a peripheral masking area and having the first surface for receiving the physical tactile input and the second surface for forming said sensing circuit... | The OGS architecture itself is alleged to be this integration, where the outer surface of the cover glass is for touch input and the inner surface has the sensor circuitry fabricated on it. The complaint provides a diagram of a "Sensor on Lens" approach to illustrate this concept (Compl. p. 46). | ¶74 | col. 2:52-57 |
| wherein there is no other substrate made of glass or plastic material laminated or bonded on the first surface of the substrate. | The complaint alleges that because the device uses OGS technology, the touch screen is integrated directly with the protective glass, and no additional glass or plastic substrate is bonded to the outer (first) surface. | ¶75 | col. 2:57-60 |
- Identified Points of Contention:
- Scope Questions: The definition of the negative limitation "no other substrate...laminated or bonded on the first surface" will be critical. The dispute may focus on whether functional coatings, such as anti-reflective or oleophobic layers commonly applied to the outer surface of touch screens, qualify as a "substrate" under the patent's claims.
- Technical Questions: What specific layers, if any, exist on the outermost surface of the accused IdeaPad's display? Factual evidence regarding the composition and method of application of any surface coatings will be necessary to determine if they meet the definition of a "substrate...laminated or bonded."
V. Key Claim Terms for Construction
Patent: U.S. 11,493,794
- The Term: "laminated with"
- Context and Importance: This term is central to the asserted claim, defining the relationship between the glass and covering layers. The patent’s main point of novelty appears to be a structure that avoids traditional adhesives. Practitioners may focus on this term because its construction—specifically, whether it permits any form of adhesive bonding—could be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly exclude adhesives. One could argue "laminated with" is a general term for joining layers, and the specification's description of an adhesive-free method is merely a preferred embodiment.
- Evidence for a Narrower Interpretation: The specification explicitly states, "the transparent covering layer and the glass layer are not adhered to each other with adhesive (e.g., OCA)." (’794 Patent, col. 3:5-8). This strongly suggests that "laminated with" in this patent's context means a direct, adhesive-free bond formed, for example, by coating and drying a polymer onto the glass (’794 Patent, col. 6:19-23).
Patent: U.S. 9,606,675
- The Term: "no other substrate...laminated or bonded on the first surface"
- Context and Importance: This negative limitation defines the core of the "One Glass Solution" claimed in the patent. The infringement case hinges on the accused product's outer screen surface being free of any additional "substrate." Practitioners may focus on this term because the classification of modern anti-glare and anti-smudge coatings as a "substrate" will be a key point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (of what is allowed on the surface): The patent's objective is to eliminate the thick, separate glass or plastic substrates used in older touch panel designs (’675 Patent, col. 1:26-31). This context suggests that "substrate" refers to a structural layer, not to thin, non-structural surface coatings that do not serve the function of a substrate.
- Evidence for a Narrower Interpretation (of what is allowed on the surface): The claim uses the absolute phrase "no other substrate." As the patent does not define "substrate," a defendant could argue that any distinct material layer applied to the surface, regardless of thickness or function, qualifies as a "substrate...laminated or bonded," thereby placing modern coated screens outside the claim's scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all four patents, asserting that Defendant’s user manuals and guides instruct customers to use the touch screens (e.g., "Learn gestures," "Use the multi-touch screen"), which constitutes the direct infringing act (Compl. ¶¶ 62, 78, 96, 114). Contributory infringement is also alleged, based on the assertion that the accused display components are material to the inventions, are not staple articles of commerce, and are known to be especially adapted for use in an infringing manner (Compl. ¶¶ 65, 81, 99, 117).
- Willful Infringement: Willfulness is alleged for all patents based on a purported policy of not reviewing the patents of others, which the complaint characterizes as willful blindness (Compl. ¶¶ 61, 77, 95, 113). For the ’857 and ’542 Patents, the complaint further alleges pre-suit knowledge based on citations to the patent families made by one of Lenovo’s alleged display suppliers in its own patent filings (Compl. ¶¶ 93, 111).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Can the term "laminated with" in the ’794 patent, which the specification contrasts with adhesive bonding, be construed to read on the layered assembly of the accused foldable displays? This will require a deep analysis of both the patent's language and the physical construction of the accused product.
- A second key issue will be one of technical scope: Does the negative limitation "no other substrate...laminated or bonded" in the ’675 patent preclude modern anti-glare or oleophobic coatings? The case may turn on the factual question of what layers exist on the accused screens and the legal question of whether those functional coatings constitute a "substrate."
- A third central question will be one of infringement mapping across a product line: Given that the four asserted patents claim distinct touch screen architectures (foldable composite, OGS without an outer substrate, on-cell, and OGS with stacked electrodes), a significant challenge will be whether Plaintiff can demonstrate that Defendant’s diverse and evolving portfolio of devices practices the specific, and different, limitations of each asserted patent.