DCT

6:25-cv-00026

SVV Technology Innovations Inc v. ASUSTeK Computer Inc

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: SVV Technology Innovations Inc. (California)
- Defendant: ASUSTeK Computer Inc. (Taiwan)
- Plaintiff’s Counsel: Katz PLLC
Case Identification: 6:25-cv-00026, W.D. Tex., 04/25/2025
Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that conducts business and sells the accused products in the Western District of Texas through authorized retailers such as Best Buy, Sam's Club, and Walmart, as well as online through Amazon.com.
Core Dispute: Plaintiff alleges that Defendant’s LED-backlit LCD monitors infringe six patents related to backlight illumination systems, light guide technologies, and light-converting films.
Technical Context: The technology at issue concerns methods for improving the efficiency, uniformity, and design of LED backlights, which are fundamental components in a wide range of consumer electronics, including computer monitors, laptops, and televisions.
Key Procedural History: The complaint notes that the asserted ’342 Patent was previously litigated between the same parties in the same court, where claims were construed and a jury rendered a verdict of willful infringement against the Defendant. The ’630 Patent is also currently asserted in another pending case before the same court. This litigation history suggests a high degree of familiarity with the technology and patents by both the parties and the court.

Case Timeline

Date	Event
2010-07-13	’475 Patent Priority Date
2012-02-14	’197 and ’340 Patents Priority Date
2013-02-13	’342 and ’630 Patents Priority Date
2015-08-14	’093 Patent Priority Date
2018-01-30	’342 Patent Issue Date
2020-01-01	Announcement of Accused ROG Zephyrus G14 Laptop
2021-02-25	Plaintiff sent letter to Defendant identifying patents and accused products
2021-03-30	’197 Patent and ’630 Reissue Patent Issue Date
2021-10-26	’340 Patent Issue Date
2022-03-24	Plaintiff filed three prior patent infringement lawsuits against Defendant
2023-01-10	’093 Patent Issue Date
2024-03-05	’475 Patent Issue Date
2024-09-26	Jury verdict of willful infringement against Defendant on ’342 Patent in prior case
2025-04-25	Complaint Filing Date

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

U.S. Patent No. 9,880,342

Patent Identification: U.S. Patent No. 9,880,342, "Collimating Illumination Systems Employing Planar Waveguide," Issued January 30, 2018.
The Invention Explained:
- Problem Addressed: The patent addresses the challenge of efficiently distributing light from a light source, typically LEDs placed at an edge of a panel, uniformly across the entire surface of a thin display backlight (Compl. ¶100; ’342 Patent, col. 2:50-55).
- The Patented Solution: The invention uses a planar waveguide, or light guide plate (LGP), to carry light from edge-mounted LEDs. The LGP's front surface has a three-dimensionally textured structure, such as an array of elongated cylindrical lenses. Its back surface contains a pattern of light-deflecting microstructures. These microstructures are in a "predetermined alignment" with the front lenses and redirect light propagating within the waveguide out through the front surface toward the viewer in a collimated fashion (Compl. ¶100; ’342 Patent, col. 4:39-48). The waveguide and the lens array are described as constituting a "single monolithic structure" (Compl. ¶100).
- Technical Importance: This approach enables the creation of thin, uniformly illuminated backlights, which are critical for the design of modern flat-panel displays with slim profiles and bezels (Compl. ¶53).
Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶97).
- Claim 1 includes the following essential elements:
  - An illumination apparatus comprising a planar waveguide formed by a thin layer of an optically transmissive material.
  - The waveguide has a three-dimensionally textured surface and an opposing planar surface.
  - A light input edge is positioned between the textured and planar surfaces.
  - A light source is optically coupled to the light input edge.
  - The waveguide has a plurality of light-deflecting elements formed in the planar surface.
  - The three-dimensionally textured surface comprises a planar array of elongated cylindrical lenses.
  - The array of cylindrical lenses and the planar waveguide constitute a single monolithic structure.
  - At least one of the light-deflecting elements has a curved surface and is in a predetermined alignment with the elongated cylindrical lenses.
- The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Reissue Patent No. RE49,630

Patent Identification: U.S. Reissue Patent No. RE49,630, "Collimating Illumination Systems Employing a Waveguide," Reissued March 30, 2021.
The Invention Explained:
- Problem Addressed: The patent addresses the issue of non-uniform brightness in edge-lit backlights, where the area closest to the light source is often brighter than the area farther away (Compl. ¶106; RE49,630 Patent, col. 17:39-49).
- The Patented Solution: The invention describes an illumination system with a planar optical waveguide (LGP) that has linear cylindrical lenses on its first surface and a two-dimensional pattern of light extraction elements on its second surface. To counteract brightness fall-off, the "spacing distance between individual ones of said light extraction elements...generally decreases with a distance from the first edge," meaning the light-extracting features become more densely packed farther from the LEDs to create a uniform glow (Compl. ¶106, ¶33; RE49,630 Patent, col. 18:3-8). The patent also specifies a physical relationship where the thickness of the waveguide is greater than the sum of the effective focal length (EFL) and radius of curvature (R) of the cylindrical lenses (Compl. ¶34).
- Technical Importance: This method of graduating the density of light extraction features is a key technique for achieving uniform illumination in thin, edge-lit display backlights (Compl. ¶106).
Key Claims at a Glance:
- The complaint asserts at least independent claim 17 (Compl. ¶103).
- Claim 17 includes the following essential elements:
  - An illumination system comprising a planar optical waveguide of an optically transmissive dielectric material.
  - The waveguide has a first major surface, an opposing second major surface, a light input edge, and an opposing second edge.
  - A plurality of linear cylindrical lenses are formed in the first major surface, oriented perpendicular to the first and second edges.
  - A plurality of LEDs are positioned proximate to the first edge and optically coupled to the waveguide.
  - A two-dimensional pattern of light extraction elements is formed on the second major surface.
  - The spacing distance between the light extraction elements generally decreases with a distance from the first edge.
  - A thickness of the waveguide is greater than EFL+R, where EFL is an effective focal length and R is a radius of curvature of the lenses.
- The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 11,923,475

Patent Identification: U.S. Patent No. 11,923,475, "Method of Making Light Converting Systems Using Thin Light Trapping Structures and Photoabsorptive Films," Issued March 5, 2024.
Technology Synopsis: This patent relates to light converting optical systems, such as those used in QLED displays (Compl. ¶85, ¶113). The described system uses a photoabsorptive film layer, such as a Quantum Dot Enhancement Film (QDEF), which contains semiconductor materials (e.g., red and green quantum dots) that absorb light from a monochromatic source (e.g., a blue LED) and convert it to other colors (Compl. ¶113, ¶39). This film is used in conjunction with other optical layers, like Brightness Enhancement Films (BEFs) with linear grooves, to create a light-trapping structure that improves color and brightness (Compl. ¶113).
Asserted Claims: At least claim 1 (Compl. ¶109).
Accused Features: The accused features are found in the ASUSTeK PG32UQXR monitor, which is identified as a QDEF product containing a QDEF layer to convert blue LED light into red and green, and BEFs for brightness enhancement (Compl. ¶93, ¶113).

Multi-Patent Capsule: U.S. Patent No. 11,156,340

Patent Identification: U.S. Patent No. 11,156,340, "Light Guide Illumination Systems with Enhanced Light Coupling," Issued October 26, 2021.
Technology Synopsis: This patent describes a light guide illumination system for an edge-lit display. It features a strip of heat-conducting printed circuit located near the light input edge of an optically transmissive sheet (LGP) (Compl. ¶119). A linear array of side-emitting LED packages is mounted on this circuit strip and optically coupled to the LGP. To achieve uniform illumination, the density of microscopic light extraction features on the LGP's surface increases with distance from the light coupling area (Compl. ¶119, ¶45).
Asserted Claims: At least claim 1 (Compl. ¶116).
Accused Features: The accused features are embodied in the ASUSTeK MB16ACV and MB16QHG portable monitors, which allegedly use a side-emitting LED array on a printed circuit strip to illuminate a light guide plate (Compl. ¶115, ¶119).

Multi-Patent Capsule: U.S. Patent No. 11,550,093

Patent Identification: U.S. Patent No. 11,550,093, "Backlight Unit for LCD Displays Employing Side-Emitting LEDs and Optical Waveguides," Issued January 10, 2023.
Technology Synopsis: This patent details a backlight unit using a thin and flexible light transmissive sheet (LGP). The design includes a "light mixing area" located between the light input edge (where a flexible side-emitting LED strip is located) and the main "patterned light extraction area" of the LGP (Compl. ¶125). An opaque housing covers the LED strip and a substantial portion of the light mixing area, and a key feature is that a dimension of the light-emitting surface of the LEDs is greater than the thickness of the LGP (Compl. ¶125, ¶50).
Asserted Claims: At least claim 1 (Compl. ¶122).
Accused Features: The ASUSTeK MB16ACV and MB16QHG monitors are accused of infringing. They allegedly contain a backlight with a flexible LGP, a flexible side-emitting LED strip, and an opaque housing covering the light mixing area (Compl. ¶121, ¶125).

Multi-Patent Capsule: U.S. Patent No. 10,962,197

Patent Identification: U.S. Patent No. 10,962,197, "Light Guide Illumination Systems with Enhanced Light Coupling," Issued March 30, 2021.
Technology Synopsis: This patent is directed to an edge-lit illumination system that uses a plurality of "light coupling elements" formed from a transmissive dielectric material on the surface of the planar light guide (LGP). These elements are configured to couple light from side-emitting LED packages—which are mounted on a heat-conducting printed circuit strip—into the LGP (Compl. ¶131). The density of separate light extraction features on the LGP increases with distance from the LEDs to ensure uniform light distribution (Compl. ¶131, ¶55).
Asserted Claims: At least claim 1 (Compl. ¶128).
Accused Features: The ASUSTeK MB16ACV monitor is accused of infringing by allegedly employing light coupling elements on its LGP to guide light from side-emitting LEDs (Compl. ¶127, ¶131).

III. The Accused Instrumentality

Product Identification: The complaint names two categories of accused products: "QDEF Accused Products," which use a Quantum Dot Enhancement Film, and "Non-QDEF Accused Products," which do not (Compl. ¶92). The primary example of a QDEF product is the ASUSTeK PG32UQXR monitor (Compl. ¶93). The Non-QDEF products include monitors such as the XG259Q3A, VG277QY1A, and portable monitors MB16ACV and MB16QHG (Compl. ¶94, ¶96). The image on a product label identifies defendant ASUSTeK as the source of the PG32UQXR monitor (Compl. ¶28).
Functionality and Market Context: The accused products are LED-backlit LCD monitors marketed heavily to the gaming community (Compl. ¶84, ¶86). The QDEF products incorporate a quantum dot film layer to convert light from a blue LED backlight into pure red and green, which is alleged to increase light throughput and provide a better color gamut (Compl. ¶88). The Non-QDEF products are described as using edge-lit backlights where LEDs are placed along an edge of a planar waveguide, which distributes light across the display panel (Compl. ¶100). The financial tables provided in the complaint detail ASUS's significant sales revenue in the Americas, indicating a substantial market presence (Compl. ¶43).

IV. Analysis of Infringement Allegations

’342 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an illumination apparatus, comprising: a planar waveguide formed by a thin layer of an optically transmissive material...said planar waveguide having a three-dimensionally textured surface and an opposing planar surface	The accused products' LCD display incorporates a planar waveguide (LGP) formed by a thin layer of optically transmissive material, with a three-dimensionally textured front surface and a planar back surface.	¶100	col. 4:39-44
a light source optically coupled to said light input edge	The backlight uses multiple LEDs placed along an edge of the display, which are optically coupled to illuminate directly into the light input edge of the LGP.	¶100	col. 4:5-12
a plurality of light deflecting elements formed in said planar surface, said light deflecting elements being configured for redirecting light...	The back surface of the LGP contains a large number of light-deflecting microstructures that redirect light propagating in the waveguide.	¶100	col. 4:45-48
said three-dimensionally textured surface comprises a planar array of elongated cylindrical lenses	The front surface of the LGP contains a planar array of elongated cylindrical lenses extending between opposing edges of the LGP.	¶100	col. 4:55-58
said array of cylindrical lenses and said planar waveguide collectively constituting a single monolithic structure	The cylindrical lenses are formed directly in the front surface of the LGP, constituting a single monolithic structure that transmits light.	¶100	col. 4:63-65
wherein at least one of said light deflecting elements has a curved surface, and...is in a predetermined alignment with said elongated cylindrical lenses	At least one of the microstructures on the back surface has a curved surface and is in a predetermined alignment (relative orientation and/or position) with the cylindrical lenses on the front surface.	¶100	col. 5:1-4

Identified Points of Contention:
- Scope Questions: A primary question may be the construction of "a single monolithic structure." The complaint alleges the accused products meet this limitation because the lenses are "formed directly" in the LGP surface (Compl. ¶100). However, if the lenses are part of a separate film laminated onto the LGP, the court will have to determine if that assembly constitutes a "monolithic" structure as contemplated by the patent.
- Technical Questions: The claim requires a "predetermined alignment" between the back-surface microstructures and the front-surface lenses. The infringement analysis will raise the question of what evidence the complaint provides to show that this specific alignment exists in the accused products, beyond a conclusory allegation.

’630 Patent Infringement Allegations

Claim Element (from Independent Claim 17)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an illumination system, comprising: a planar optical waveguide formed from an optically transmissive dielectric material...	The accused products' backlight assembly incorporates a planar optical waveguide (LGP) made of an optically transmissive dielectric material.	¶106	col. 18:18-20
a plurality of linear cylindrical lenses formed in said first major surface and oriented perpendicular to said first and second edges	The backlight assembly includes a plurality of linear cylindrical lenses disposed on the front surface of the LGP, perpendicular to the light input and opposite edges.	¶106	col. 18:30-33
a plurality of light emitting diodes...positioned proximate to said first edge and optically coupled to said planar optical waveguide	Multiple LEDs are positioned in proximity to the light input edge of the LGP and are optically coupled to it.	¶106	col. 18:23-26
a two-dimensional pattern of light extraction elements formed in or on said second major surface	The back surface of the LGP includes a two-dimensional pattern of microstructures (light extraction elements) distributed over its length and width.	¶106	col. 18:34-36
wherein a spacing distance between individual ones of said light extraction elements...generally decreases with a distance from said first edge	The spacing between the light extraction elements is greater at the light input edge than at the second edge of the LGP.	¶106	col. 18:49-53
wherein a thickness of said planar optical waveguide is greater than EFL+R...	The complaint calculates that for the accused products, the LGP thickness (2 mm) is substantially greater than the calculated EFL+R (0.354 mm).	¶34	col. 18:54-58

Identified Points of Contention:
- Scope Questions: The term "generally decreases" will be a key point of construction. The dispute may focus on how much variation from a strictly decreasing pattern is permissible for the accused products to still fall within the claim's scope.
- Technical Questions: Infringement of the "thickness...is greater than EFL+R" limitation will be a heavily fact-dependent and expert-driven dispute. The complaint offers a calculation to support its allegation (Compl. ¶34), but the defendant will likely contest the values used for the radius of curvature (R) and refractive index (n) for its specific products, raising questions about the actual physical and optical properties of the accused devices.

V. Key Claim Terms for Construction

The Term: "a single monolithic structure" (’342 Patent, Claim 1)
Context and Importance: This term is critical because backlights are often assembled from multiple distinct optical films. The infringement theory depends on whether an assembly of a light guide plate and a lens film can be considered "monolithic." Practitioners may focus on this term because if it is construed to mean "formed from a single, continuous piece of material," it could present a significant non-infringement argument for products made from laminated layers.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's focus is on the functional relationship between the lenses and the waveguide. Language stating the lenses are formed "directly in the front surface" (Compl. ¶100) could be argued to cover processes like molding or embossing a film that is then permanently bonded to the LGP, thereby functioning as a single, inseparable unit.
- Evidence for a Narrower Interpretation: The figures in the ’342 patent may depict the lenses and waveguide as a single, contiguous cross-section without any boundary line, suggesting an invention conceived as a single piece of molded plastic. The abstract or summary might emphasize this single-piece construction as an advantage.
The Term: "a spacing distance...generally decreases with a distance from the first edge" (’630 Patent, Claim 17)
Context and Importance: This term defines the core technical feature used to achieve uniform brightness. Infringement hinges on whether the accused products' dot patterns conform to this rule. Practitioners may focus on this term because its construction will determine whether proof of infringement requires showing a strict mathematical progression or if any pattern that trends toward higher density away from the edge is sufficient.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the word "generally" implies that some local variations or non-uniformities in the decreasing pattern are permissible, as long as the overall trend is maintained. The specification's description of the problem solved—brightness uniformity—could support an interpretation that covers any pattern achieving this goal through a density gradient (RE49,630 Patent, col. 17:39-49).
- Evidence for a Narrower Interpretation: The detailed description of the ’630 patent might provide specific examples, figures, or mathematical relationships that illustrate a more precise, ordered decrease in spacing. Such embodiments could be cited to argue that "generally" does not cover arbitrary or randomized patterns that happen to have a higher average density at one end.

VI. Other Allegations

Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b) based on Defendant's affirmative acts of providing instructions, user manuals, advertisements, and established distribution channels that allegedly encourage and facilitate the infringing use of the accused products by consumers and distributors (Compl. ¶99, ¶105, ¶118).
Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the asserted patents. This knowledge is claimed to stem from at least a February 25, 2021 pre-suit notice letter, prior patent infringement lawsuits filed by Plaintiff against Defendant on March 24, 2022, and a prior jury verdict finding Defendant’s infringement of the ’342 Patent to be willful (Compl. ¶70, ¶71, ¶135, ¶136). The complaint further alleges that Defendant has a policy of willful blindness by not reviewing the patents of others (Compl. ¶137).

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

A core issue will be one of claim scope and construction: can terms such as "a single monolithic structure" from the ’342 patent be construed to cover modern backlight units assembled from distinct, laminated optical films, and does the mathematical thickness requirement in the ’630 patent read on the physical dimensions of the accused products?
A key evidentiary question will be one of technical implementation: for the patents related to light distribution, does the physical pattern of microstructures on the accused monitor backlights in fact follow the claimed rule where spacing "generally decreases with a distance from the first edge," or is uniform brightness achieved through an alternative, non-infringing design?
A central legal and factual dispute will be willful infringement: given the extensive litigation history and a prior jury verdict of willfulness for the ’342 patent, the court will have to determine whether Defendant’s continued sale of accused products constitutes objective recklessness, which could expose the Defendant to enhanced damages for any proven infringement.