Entelekon LLC v. LG Electronics USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Entelekon LLC (New Mexico)
  • Defendant: LG Electronics U.S.A., Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:26-cv-00020, W.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Western District of Texas and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s portable electronic devices with multiple displays infringe a patent related to the mechanical and software-based operation of such devices.
• Technical Context: The technology at issue involves dual-screen portable devices, a product category that aims to provide enhanced multitasking capabilities similar to a desktop computer with multiple monitors.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 10,620,663 - Multiple displays for a portable electronic device and a method of use

• Patent Identification: U.S. Patent No. 10,620,663, "Multiple displays for a portable electronic device and a method of use," issued April 14, 2020. (Compl. ¶9).

The Invention Explained

• Problem Addressed: The patent addresses the limitation of single, small displays on portable electronic devices, which restricts the ability to run or view multiple applications simultaneously, a common feature of desktop computers (’663 Patent, col. 2:8-24). Existing solutions for dual-screen portable devices were described as bulky, compromising the convenience and portability that are key advantages of such devices (’663 Patent, col. 2:25-31).
• The Patented Solution: The invention discloses a portable device with a primary and a secondary display featuring at least two mechanical arrangements. In a first arrangement, the secondary display is "stowed, out of the way mechanically and visually," preserving a single-screen form factor. In a second arrangement, the secondary display is deployed to be "substantially coplanar and adjacent to the one screen" (’663 Patent, Abstract). This allows the device to run two applications simultaneously, with each application having its own user interface on a dedicated display, as depicted in the folding mechanism of Figures 1A-1D (’663 Patent, col. 2:38-54, Figs. 1A-1D).
• Technical Importance: This approach seeks to provide the multitasking benefits of multiple displays without sacrificing the compact form factor and convenience expected of a portable device. (’663 Patent, col. 2:22-28).

Key Claims at a Glance

• The complaint does not identify specific asserted claims within the body of the document. Instead, it alleges infringement of "one or more claims" and incorporates by reference "the Exemplary '663 Patent Claims" identified in charts within an attached Exhibit 2 (Compl. ¶11). As this exhibit was not provided with the filed complaint, a specific breakdown of asserted claims is not possible from the available record.

III. The Accused Instrumentality

Product Identification

The complaint does not name specific products. It refers to the accused instrumentalities as "Exemplary Defendant Products" that are identified in the charts of the incorporated Exhibit 2. (Compl. ¶¶ 11, 16).

Functionality and Market Context

• The complaint alleges that the accused products are made, used, offered for sale, sold, and/or imported by the Defendant. (Compl. ¶11). It further alleges that Defendant’s employees internally test and use the products. (Compl. ¶12).
• The complaint makes no specific allegations regarding the products' commercial importance or market positioning, beyond the general assertion that they are sold to customers. (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint alleges direct and indirect infringement by incorporating claim charts by reference in an Exhibit 2, which was not provided with the filed document (Compl. ¶¶ 11, 16, 17). The complaint does not contain narrative allegations mapping specific claim elements to accused product features. Therefore, a detailed analysis of the infringement theory or a claim chart summary is not possible based on the complaint itself.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as the asserted claims are identified only in an external exhibit not included with the complaint (Compl. ¶11).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since the service of the complaint, Defendant has "actively, knowingly, and intentionally" continued to induce infringement. (Compl. ¶15). The alleged inducing acts include selling the accused products and distributing "product literature and website materials" that instruct end users on how to use the products in an allegedly infringing manner. (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful infringement." However, it alleges that service of the complaint constitutes "Actual Knowledge of Infringement" (Compl. ¶13) and that Defendant continued its allegedly infringing activities "Despite such actual knowledge" (Compl. ¶14). These allegations of post-suit knowledge could form the basis for a later claim of willfulness or a request for enhanced damages under 35 U.S.C. § 284, which is requested in the prayer for relief. (Compl. Prayer for Relief ¶D).

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

1. Sufficiency of Pleading: A threshold issue may be whether the complaint’s reliance on an external, unprovided exhibit to establish the basis for its infringement claims satisfies the plausibility pleading standards of Federal Rule of Civil Procedure 8, as interpreted by Twombly and Iqbal.
2. Claim Scope and Mechanical Equivalence: Assuming the case proceeds, a central technical dispute will likely involve claim construction and the mechanical operation of the accused devices. A key question will be whether the specific mechanisms used in Defendant's products (e.g., hinge designs, attachment cases) fall within the scope of claim terms such as a display being "stowed" and then moved to a "deployed" position where it is "substantially coplanar."
3. Software Functionality Linkage: The patent claims appear to require a specific software interaction between the two displays. For instance, independent claim 1 requires that a user's selection of "first information in the primary display" causes the "secondary display to display second information related to said first information." A key evidentiary question will be whether the accused devices' operating system and software architecture perform this specific, causally-linked function, or if there is a fundamental mismatch in technical operation.