Televo LLC v. LG Electronics USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Televo LLC (New Mexico)
  • Defendant: LG Electronics U.S.A., Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00560, W.D. Tex., 12/09/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to text entry systems for electronic devices that combine single-letter and letter-group inputs.
• Technical Context: The technology addresses methods for improving the speed and accuracy of text input on compact electronic devices, a central challenge in mobile computing during the transition from physical keypads to touchscreens.
• 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

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’s background section identifies a trade-off in mobile text entry methods. Predictive text systems using multi-letter keys are fast but can fail if a word is not in the device's dictionary. Conversely, traditional single-letter entry is precise but can be slow and cumbersome on reduced-size keyboards. Switching between these two modes is described as an inefficient solution (U.S. Patent No. 8,521,927, col. 5:1-14).
• The Patented Solution: The invention proposes a unified text entry system that combines both "single letter operations" and "letter group operations" within a single word entry process. A user can fluidly mix inputs, for instance, by pressing a key once to select a group of letters (e.g., ‘t’, ‘u’, ‘v’) and using a different type of input, such as a directional swipe on the same key, to select a specific single letter (e.g., ‘v’) (’927 Patent, col. 6:3-6). A text prediction subsystem then receives this mixed sequence of specific letters and ambiguous letter groups to generate a list of possible words for the user to select (’927 Patent, Abstract; Fig. 2).
• Technical Importance: The technology aimed to offer the speed advantages of predictive text for common words while retaining the precision of single-letter entry for uncommon words, names, or slang, without requiring the user to explicitly switch modes (’927 Patent, col. 5:36-44).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '927 Patent Claims" but does not identify them (Compl. ¶11). Independent claim 1 is representative of the invention.
• Essential elements of independent claim 1 include:
  • An input subsystem that receives user inputs as "letter entry input operations," where each is a "single keystroke."
  • The system must be capable of interpreting inputs as both "single letter operations" (selecting one letter) and "letter group operations" (selecting multiple possible letters).
  • A text prediction subsystem that receives a "sequence including both" single letter and letter group operations.
  • The prediction subsystem produces a list of possible words by searching a database for words that match the entered single letters and resolve the ambiguity of the entered letter groups.
  • A word processing subsystem that displays the list of possible words to the user.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" and "numerous other devices" made, used, or sold by the Defendant (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentalities' specific functionality. It alleges in a conclusory manner that the accused products "practice the technology claimed by the '927 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that infringement allegations are detailed in claim charts provided as Exhibit 2 (Compl. ¶16). As this exhibit was not included with the complaint, a claim chart summary cannot be constructed. The complaint’s narrative theory of infringement is limited to the assertion that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '927 Patent Claims" (Compl. ¶16).

Identified Points of Contention

Based on the patent’s claims and the general nature of the allegations, the infringement analysis raises several key questions.

• Scope Questions: A central issue may be the interpretation of "single keystroke" in the context of modern touchscreen interfaces. The question for the court will be whether a variety of user interactions, such as taps, long presses, or complex gestures on a virtual keyboard, can each constitute a "single keystroke" as that term is used in the patent, which was filed in 2007 (’927 Patent, col. 9:29-31).
• Technical Questions: The complaint provides no information on the actual operation of the accused products' text prediction systems. A primary technical question will be whether Defendant’s systems are architected to receive and process a "sequence including both" distinct single-letter and letter-group inputs to predict a single word, as claimed, or if they rely on fundamentally different methods, such as probabilistic models based on tap locations or path-based gesture analysis, that do not map to the claimed system architecture (’927 Patent, col. 10:46-53).

V. Key Claim Terms for Construction

Term: "single keystroke" (Claim 1)

Context and Importance

This term is critical because Claim 1 requires that "each of the letter entry input operation is a single keystroke." The viability of the infringement claim against modern touchscreen devices, which lack physical keys, will depend heavily on this term's construction.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification suggests "keystroke" is not limited to a simple press, defining it to include "touching, pressing, moving, swiping, titling, sliding or performing any other gesture" over a key area (’927 Patent, col. 10:62-65). This language may support an interpretation that covers a range of modern touchscreen inputs.
• Evidence for a Narrower Interpretation: The primary embodiment shown in Figure 1 is a "shell style cell-phone" with a physical numeric keypad (’927 Patent, Fig. 1; col. 5:47-54). A defendant may argue that the term, viewed in the context of the specification as a whole, was primarily intended to describe discrete actions on physical or clearly delineated virtual keys, not complex or continuous gestures.

Term: "a sequence including both of said single letter operations and of said letter groups operations" (Claim 1)

Context and Importance

This limitation defines the core novelty of the claimed invention—the ability of the prediction engine to process a mixed input stream for a single word. Plaintiff must demonstrate that the accused systems function in this specific manner.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent abstract and summary describe a system where a user can seamlessly mix input types, suggesting the claim should cover any predictive system that accepts both ambiguous and unambiguous letter inputs to form a word (’927 Patent, Abstract; col. 1:55-59).
• Evidence for a Narrower Interpretation: A defendant could argue that this language requires a specific system architecture where the prediction subsystem explicitly receives and distinguishes between two fundamentally different input types (single vs. group) in a sequence. Modern AI-driven keyboards might be argued to treat all inputs as a single type of probabilistic data (e.g., coordinates of a tap with a radius of uncertainty), which may not constitute the distinct "single letter" and "letter group" operations required by the claim.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since the filing of the suit, Defendant has knowingly induced infringement by selling the accused products and distributing materials like "product literature and website materials" that instruct end users on their infringing use (Compl. ¶14, ¶15).
• Willful Infringement: The complaint does not use the word "willful." However, it alleges that service of the complaint "constitutes actual knowledge of infringement" and that Defendant has continued its allegedly infringing conduct despite this knowledge, which lays a foundation for a claim of post-suit willfulness (Compl. ¶13, ¶14). No facts are alleged to support pre-suit knowledge.

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

This dispute will likely focus on fundamental questions of technological operation and claim scope, for which the complaint currently provides minimal detail.

• A core issue will be one of architectural equivalence: Does the accused LG text entry software operate on the basis of a "text prediction subsystem" that processes a mixed sequence of distinct "single letter" and "letter group" inputs as described in the ’927 Patent, or does it employ a more modern, fundamentally different probabilistic or AI-based architecture that does not map to the claim limitations?
• A second key question will be one of definitional scope: Can the term "single keystroke," originating in a 2007 patent application heavily featuring physical keypads, be construed to cover the full range of taps, swipes, and other complex gestures used on Defendant’s modern touchscreen devices? The answer will likely determine whether the patent can be applied to the accused technology.