Televo LLC v. Sony Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (New Mexico)
  • Defendant: Sony Electronics Inc. (Japan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01199, E.D. Tex., 12/09/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a unified text entry system for electronic devices.
• Technical Context: The technology concerns methods for improving text input speed and accuracy on devices with limited keypads by combining predictive text with single-character entry.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2007-07-07	’927 Patent Priority Date
2013-08-27	’927 Patent Issue Date
2025-12-09	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 addresses the inefficiency of text entry on compact devices where users must switch between a "predictive-text" mode (for common words) and a "single-letter" mode (for uncommon words, names, or slang) (Compl., Ex. 1, ’927 Patent, col. 5:7-14). This mode-switching is described as "cumbersome" and time-consuming, and predictive systems fail when a word is not in the device's dictionary (’927 Patent, col. 5:26-30).
• The Patented Solution: The invention proposes a unified text entry system that allows a user to choose, on a letter-by-letter basis, between a "letter group operation" (selecting a group of possible letters, like pressing '2' for 'a,b,c') and a "single letter operation" (selecting a specific, unambiguous letter) without changing the overall operating mode (’927 Patent, col. 5:15-21). The system comprises an input subsystem to interpret these dual-function inputs, a text prediction subsystem to generate a word list from the mixed sequence of ambiguous and unambiguous entries, and a word processing subsystem to display the results (’927 Patent, Abstract; Fig. 2).
• Technical Importance: This approach sought to merge the speed of predictive text for common words with the precision of direct entry for less common words, thereby improving the overall user experience on devices like cellular phones (’927 Patent, col. 1:5-10; col. 5:36-44).

Key Claims at a Glance

• The complaint asserts infringement of one or more "Exemplary '927 Patent Claims" but does not identify them specifically (Compl. ¶11). Independent claim 1 is representative of the core invention.
• Essential Elements of Independent Claim 1:
  • A text entry system comprising an input subsystem, a text prediction subsystem, and a word processing subsystem.
  • The input subsystem recognizes "only keystrokes performed on a plurality of keys" as letter entry operations.
  • Each letter entry is a "single keystroke performed on a single key" and is interpreted as a "single letter location entry."
  • The system accommodates, for each letter entry, both "single letter operations" (selecting one specific letter) and "letter group operations" (selecting a group of letters).
  • A text prediction subsystem receives a sequence of both single letter and letter group operations to produce a list of possible words.
  • A word processing subsystem displays the list and processes the user's selection.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring to them only as "Exemplary Defendant Products" (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality, features, or market position. It alleges only that the products "practice the technology claimed by the '927 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an exhibit that was not attached to the publicly filed document (Compl. ¶17). The body of the complaint itself does not contain a narrative description of how the "Exemplary Defendant Products" are alleged to meet the limitations of the asserted claims. The infringement allegations are conclusory, stating that the accused products "satisfy all elements of the Exemplary '927 Patent Claims" (Compl. ¶16). Without the claim charts or a more detailed narrative, analysis of the specific infringement theory is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "single letter location entry"

  • Context and Importance: This term appears to be a neologism created by the patentee to define the fundamental unit of user input that the system processes (Compl., Ex. 1, ’927 Patent, col. 9:32-35). Its construction is critical because it must be broad enough to encompass both a "single letter operation" and a "letter group operation," which are functionally distinct inputs. The dispute may turn on whether a standard key press on an accused device can be interpreted as this specific type of "entry."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 states that the "single letter location entry" comprises either a single letter or letter group operation, suggesting it is a conceptual container for either type of input, not a specific action itself (’927 Patent, col. 9:35-42).
    • Evidence for a Narrower Interpretation: The repeated and specific use of this phrase throughout the claims, distinct from the well-understood "keystroke," may suggest the patentee intended it to have a specific technical meaning tied to the system's unique architecture rather than being a generic term for any user input.

• The Term: "single keystroke"

  • Context and Importance: Claim 1 requires that each "letter entry input operation" be a "single keystroke" (’927 Patent, col. 9:29-30). The specification, however, describes embodiments where a "letter group" is selected by a "press" operation, while a "single letter" is selected by a "swipe" operation—two physically different user actions (’927 Patent, col. 5:61-64; col. 6:1-6). Practitioners may focus on whether both a simple press and a more complex gesture like a swipe can be considered a "single keystroke" under the claim's language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "keystroke" could be argued to encompass any single, discrete user interaction with a key, including a press, a touch, or a swipe gesture that begins and ends on that key.
    • Evidence for a Narrower Interpretation: The term "keystroke" traditionally implies a press-and-release action. A defendant may argue that multi-part actions like a "swipe" or "directional gesture" (’927 Patent, col. 10:32-34) are not "single keystrokes," potentially placing some of the patent's own disclosed embodiments outside the scope of this claim language.

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 an infringing manner (Compl. ¶14). The complaint also alleges Defendant sells the products "for use in end-user products in a manner that infringes" (’927 Patent, Compl. ¶15).
• Willful Infringement: Willfulness is alleged based on knowledge of the ’927 Patent obtained "at least since being served by this Complaint" (Compl. ¶15). The complaint also asserts that the service of the complaint itself "constitutes actual knowledge of infringement" (Compl. ¶13).

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

Given the limited detail in the initial pleading, the litigation will likely focus on the following fundamental questions:

1. A primary evidentiary question will be whether discovery shows that the accused products, once identified, actually implement a unified text entry system that allows for the selection of both ambiguous "letter groups" and unambiguous "single letters" without a formal mode switch, as required by the claims.
2. A central legal issue will be one of definitional scope: how will the court construe the patent’s unique terminology, such as "single letter location entry"? The outcome of claim construction will determine whether the patent covers a broad category of modern text-entry systems or is limited to the specific architecture described in the specification.