Tau Ceti Ventures LLC v. LG Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Tau Ceti Ventures LLC (Texas)
  • Defendant: LG Electronics, Inc. (Republic of Korea) and LG Electronics U.S.A., Inc. (Delaware)
  • Plaintiff’s Counsel: Cherry Johnson Siegmund James PLLC; Lee Sullivan Shea & Smith LLP
• Case Identification: 2:26-cv-00089, E.D. Tex., 02/03/2026
• Venue Allegations: Venue is alleged to be proper for LG Electronics, Inc. as a foreign corporation. Venue for LG Electronics U.S.A., Inc. is based on allegations of regular and established places of business within the Eastern District of Texas, specifically citing two facilities in Fort Worth, Texas, and a prior admission of leasing property in the district.
• Core Dispute: Plaintiff alleges that Defendant’s display products, including televisions, monitors, and laptops, infringe nine U.S. patents related to light-emitting diode (LED) device structure, manufacturing, and operation.
• Technical Context: The patents concern various methods of improving the efficiency, cost, and performance of LEDs, a foundational technology for modern electronic displays and lighting.
• Key Procedural History: The asserted patents are part of extensive continuation families. The complaint does not mention any prior litigation concerning these specific patents or any associated administrative proceedings such as inter partes reviews.

Case Timeline

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

U.S. Patent No. 8,089,218 - Lighting devices, issued January 3, 2012

The Invention Explained

• Problem Addressed: The patent recognizes that conventional LED light sources cannot be powered directly by an alternating current (AC) source and require an AC/DC converter, which increases product cost, size, weight, and power consumption, making them inconvenient for portable devices (218 Patent, col. 1:22-28).
• The Patented Solution: The invention describes a lighting device with a lighting module containing micro-diodes on a substrate connected by a conductive wire pattern (218 Patent, col. 1:35-38). This pattern has at least three "voltage feed points," and a "selection unit" is coupled to a power source to select at least two of these points, creating a circuit loop that activates a portion of the micro-diodes (218 Patent, col. 1:38-43). This architecture is disclosed as enabling the device to be powered by both AC and DC sources without an external converter (218 Patent, col. 1:28-31).
• Technical Importance: This approach aimed to create more versatile and efficient LED lighting systems by building power-source flexibility directly into the diode array's wiring, potentially reducing the need for bulky external power conversion components (218 Patent, col. 1:28-31).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶83
• Claim 1 requires:
  • A lighting module comprising a plurality of micro-diodes formed on a substrate.
  • A conductive wire pattern connecting to the micro-diodes, with the pattern having at least three voltage feed points.
  • A selection unit coupled to a power source that selects at least two voltage feed points.
  • The selection forms at least one loop with a portion of the micro-diodes and the power source, thereby turning on the micro-diodes in the loop.
• The complaint reserves the right to assert additional claims Compl. ¶88

U.S. Patent No. 8,101,959 - Light emitting device, issued January 24, 2012

The Invention Explained

• Problem Addressed: Traditional LED manufacturing requires dicing a completed wafer into individual chips, which are then arranged and individually wired to a circuit board using wire-bonding techniques (959 Patent, col. 1:38-42). This process is described as complicated, susceptible to breakage, and resulting in low production yield and high cost (959 Patent, col. 1:42-46).
• The Patented Solution: The patent discloses a light-emitting device where the wiring process is integrated into the wafer fabrication itself (959 Patent, col. 1:53-57). This "wafer level" wiring connects a plurality of light-emitting diode structures in series or parallel, aiming to improve yield and reduce manufacturing cost by avoiding individual chip dicing and wire bonding (959 Patent, col. 1:53-57).
• Technical Importance: This technology represents a shift towards more integrated, wafer-scale manufacturing for LEDs, a key step in reducing fabrication complexity and cost for mass-market devices (959 Patent, col. 1:47-49).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶99
• Claim 1 requires:
  • A first part epitaxial layer with a first upmost top surface and a first width.
  • One or more second part epitaxial layers, laterally separated from the first, capable of emitting light under a forward bias, and having a second upmost top surface and a second width.
  • An underlayer below both the first and second upmost top layers, electrically connecting the first and second part epitaxial layers.
  • The first upmost top layer has an elevation "substantially equal" to the second upmost top surface.
  • The first width is "substantially equal" to the second width.
• The complaint reserves the right to assert additional claims Compl. ¶105

Multi-Patent Capsule

• U.S. Patent No. 8,492,780, Light-emitting device and manufacturing method thereof, issued July 23, 2013

  • Technology Synopsis: The patent addresses the problem of total internal reflection (TIR) in conventional LEDs, which reduces light extraction efficiency Compl. ¶¶34-35 The proposed solution is a light-emitting device with a substrate sidewall that has both a substantially flat area and a substantially textured area, a discontinuous structure intended to enhance light extraction Compl. ¶36
  • Asserted Claims: At least claim 1 is asserted Compl. ¶116
  • Accused Features: The complaint alleges that the LED components within the LG Gram Laptop 15U50T, among other products, embody this textured sidewall structure Compl. ¶¶116-120

• U.S. Patent No. 8,766,309, Omnidirectional reflector, issued July 1, 2014

  • Technology Synopsis: The patent seeks to solve the problem of conventional Distributed Bragg Reflectors (DBRs) in LEDs not being omnidirectional, as their reflectivity drops at higher angles of light incidence Compl. ¶42 The invention discloses an omnidirectional reflector for an LED to achieve greater efficiency over a larger range of incident angles Compl. ¶43
  • Asserted Claims: At least claim 1 is asserted Compl. ¶133
  • Accused Features: The LED components in the LG 32MR50C Monitor are alleged to infringe by incorporating a substrate, a light-reflective layer, and a photonic crystal layer configured to reflect light in a plane parallel with the substrate while allowing other light to pass through perpendicularly Compl. ¶¶134-136

• U.S. Patent No. 9,257,604, Light-emitting device having a patterned surface, issued February 9, 2016

  • Technology Synopsis: The patent identifies issues with prior art surface roughening techniques, which can leave portions of the substrate surface parallel to the active layer, causing TIR, or create high-aspect-ratio patterns that hinder epitaxial growth Compl. ¶¶49-50 The solution is a device with a patterned unit on the substrate that has a non-polygon shape in top view and specific inclined side surfaces in cross-sectional view to improve light extraction and epitaxial quality Compl. ¶51
  • Asserted Claims: At least claim 1 is asserted Compl. ¶149
  • Accused Features: The LG 32MR50C Monitor is accused of infringing with its LED components that allegedly have a substrate with a bulged, patterned unit of a non-polygon shape Compl. ¶¶150-152

• U.S. Patent No. 9,847,460, Light emitting device with reflective electrode, issued December 19, 2017

  • Technology Synopsis: The patent addresses the degradation of LED electrodes, where material from the mirror layer can migrate under high electrical current, and barrier layers used to prevent this can be destroyed Compl. ¶¶57-58 The invention is a device with an electrode structure comprising a mirror layer, an adhesion layer, a bonding layer, and a plurality of pits between the bonding layer and the semiconductor stack, where at least one pit is not filled by the adhesion layer Compl. ¶59
  • Asserted Claims: At least claim 1 is asserted Compl. ¶165
  • Accused Features: The complaint alleges the LG 32MR50C Monitor infringes by using an electrode structure with the claimed layers and unfilled pits between the bonding layer and semiconductor stack Compl. ¶¶166-170

• U.S. Patent No. 10,038,116, Light-emitting device having a patterned substrate and the method thereof, issued July 31, 2018

  • Technology Synopsis: This patent addresses surface damage and lattice distortion resulting from conventional surface roughening processes used to enhance light extraction Compl. ¶65 The solution is a device with a textured sapphire substrate comprising structures with a specific asymmetric geometry, where the distance from a projection of the top portion to the bottom portion differs on two sides Compl. ¶66
  • Asserted Claims: At least claim 1 is asserted Compl. ¶183
  • Accused Features: The LED components in the LG 32MR50C Monitor are alleged to infringe by having a textured sapphire substrate with the claimed asymmetric structural features Compl. ¶¶184-186

• U.S. Patent No. 10,411,177, Light emitting device, issued September 10, 2019

  • Technology Synopsis: The patent addresses light being blocked or absorbed by the electrode, degrading efficiency, even when a mirror layer is present Compl. ¶72 The invention claims a device with an "excellent electrode structure" to improve reliability, involving a specific arrangement and composition of conductive, bonding, and barrier layers Compl. ¶73
  • Asserted Claims: At least claim 1 is asserted Compl. ¶199
  • Accused Features: The LG Gram Laptop 15U50T is alleged to infringe with an electrode structure comprising a plurality of conductive layers (e.g., nickel) and a bonding layer (e.g., gold) where the second metal has a higher standard oxidation potential than the first Compl. ¶¶200-204

• U.S. Patent No. 10,439,108, LED light emitting device for display device, and display device, issued October 8, 2019

  • Technology Synopsis: The patent addresses inefficient blue light utilization in quantum dot films, where too much blue light passes through gaps in the film, resulting in a bluish white light and low efficiency Compl. ¶79 The solution is an LED device with a quantum dot film, a blue LED emitter, and a dichroic layer configured to reflect a portion of the blue light back into the quantum dot film while transmitting the rest, improving color balance and efficiency Compl. ¶¶80, 221-222
  • Asserted Claims: At least claim 1 is asserted Compl. ¶217
  • Accused Features: The LG 65QNED92A TV is alleged to infringe by using a blue LED emitter, a quantum dot film, and a dichroic layer positioned between the emitter and the film to selectively reflect a preset spectral band of blue light Compl. ¶¶218-221

III. The Accused Instrumentality

• Product Identification: The complaint names a range of LG products, with specific infringement allegations focused on the LG 65QNED92A Mini LED 4K Smart TV (for the 218 and 108 patents), the LG 55QNED85A 4K Smart TV (for the 959 patent), the LG Gram Laptop 15U50T (for the 780 and 177 patents), and the LG 32MR50C Monitor (for the 309, 604, 460, and 116 patents) (Compl. ¶¶82; Compl. ¶98; Compl. ¶115; Compl. ¶132; Compl. ¶148; Compl. ¶164; Compl. ¶182; Compl. ¶198; Compl. ¶216).
• Functionality and Market Context: The accused instrumentalities are commercial electronic display products. The complaint alleges these products incorporate infringing LED components that form the basis of their display backlights Compl. ¶2 The infringement allegations are supported by teardown photographs and scanning electron microscope (SEM) images of the internal components of these products, purporting to show the claimed device structures (e.g., Compl. pp. 18-23; Compl. pp. 27-31). For example, Figure 1A-1 shows a panel from an accused television, illustrating a substrate with what the complaint identifies as a plurality of micro-diodes Compl. ¶84

IV. Analysis of Infringement Allegations

8,089,218 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: A potential point of contention is whether the accused circuit board (Compl. ¶86, Fig. 1A-8) performs the function of "selecting" voltage feed points as required by the claim. The dispute may focus on whether the board dynamically selects different points to form different loops, or if it provides fixed connections, which may raise the question of whether it truly "selects" in the manner contemplated by the patent.
  • Technical Question: The complaint identifies the light-emitting components as "micro-diodes" (Compl. ¶84, Fig. 1A-3). The construction of this term and whether the accused components meet its definition will be a central technical question. Evidence regarding the size, structure, and manufacturing process of the accused diodes will be relevant.

8,101,959 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: The claim requires the first and second widths, as well as their top surface elevations, to be "substantially equal." This term of degree is a classic subject for claim construction. The parties will likely dispute the permissible range of deviation. The complaint's SEM images (e.g., Compl. ¶103, Fig. 1B-9) will be central evidence, but their interpretation may be contested.
  • Technical Question: A key technical question will be whether the layer identified as the "underlayer" (Compl. ¶102, Fig. 1B-8) actually performs the claimed function of electrically connecting the first and second epitaxial parts in the manner described by the patent.

V. Key Claim Terms for Construction

For U.S. Patent No. 8,089,218:

• The Term: "selection unit"
• Context and Importance: This term is the active component of the claim, responsible for choosing which diodes to activate. Its construction is critical because the infringement allegation hinges on the accused circuit board performing this "selecting" function. Practitioners may focus on whether the term implies dynamic, reconfigurable selection or if it can also read on a static configuration that is "selected" at the time of manufacture.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the selection unit "selects at least two of the voltage feed points" (218 Patent, col. 1:39-41), language that does not explicitly require the selection to be dynamic or changeable after manufacturing.
  • Evidence for a Narrower Interpretation: The specification discusses powering the device from AC and DC sources and solving variations in withstand voltage, which may suggest a need for a unit capable of making different selections depending on the power source or device characteristics (218 Patent, col. 4:1-17), potentially supporting a narrower, more active definition.

For U.S. Patent No. 8,101,959:

• The Term: "substantially equal"
• Context and Importance: This term applies to both the elevation and width of the epitaxial layers and is central to the geometric requirements of the claim. Infringement will depend on whether the physical dimensions of the accused device, as measured from SEM images, fall within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit numerical range for "substantially equal," which may support an argument that it should be given its plain and ordinary meaning, allowing for some reasonable, non-trivial variation as understood by a person of ordinary skill in the art.
  • Evidence for a Narrower Interpretation: The figures in the patent (e.g., 959 Patent, FIG. 9A) depict the structures as having very similar, if not identical, dimensions. A party might argue that these embodiments define the scope of "substantially equal" narrowly, implying only minor manufacturing tolerances are permitted.

VI. Other Allegations

• Indirect Infringement: For all asserted patents, the complaint alleges induced infringement, stating that Defendants promote, advertise, and instruct customers on the use of the Accused Products (e.g., Compl. ¶¶89, 106). It is alleged these actions encourage direct infringement by end-users. The complaint also alleges contributory infringement, stating that the accused components are not staple articles of commerce and were especially made or adapted for use in an infringing manner (e.g., Compl. ¶¶91, 108).
• Willful Infringement: The complaint alleges that Defendants' infringement was and continues to be willful and deliberate, based on knowledge of the patents "at least as early as the filing and/or service of the Complaint" (e.g., Compl. ¶¶92, 109). This asserts willfulness based on post-suit conduct.

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

This case presents a broad challenge to LG’s LED technologies across a range of products. The resolution will likely depend on the following central questions:

1. A core issue will be one of definitional scope: Can terms of degree like "substantially equal" (from the 959 patent) and functional terms like "selection unit" (from the 218 patent) be construed to cover the specific structures and operations depicted in the complaint's teardown evidence? The case may turn on whether LG's designs fall within the boundaries of these claim terms.

2. A second issue will be one of evidentiary proof: The complaint's infringement theories rely heavily on annotated photographs and SEM images. A key question for the court will be whether this visual evidence, once subjected to discovery and competing expert analyses, definitively shows that the accused LG products meet every limitation of the asserted claims, or if there are material mismatches in their technical structure and operation.

3. Finally, given the assertion of nine distinct patents against a wide array of products, a key strategic question will be one of case management and focus: The parties and the court will need to determine whether the case proceeds on all asserted claims and patents or is narrowed to focus on representative patents and products to efficiently resolve the core of the dispute.