Entelekon LLC v. Microsoft Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Entelekon LLC (New Mexico)
  • Defendant: Microsoft Corporation (Washington)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:26-cv-00021, W.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper 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 portable electronic devices with multiple displays.
• Technical Context: The technology concerns the mechanical and software integration of a secondary display into a portable device, allowing it to be stowed when not in use and to run a separate application when deployed.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events 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 (’663 Patent).

The Invention Explained

• Problem Addressed: The patent addresses the limitation of small screen size on portable electronic devices, which restricts the ability to run or view multiple applications simultaneously. It notes that prior attempts at dual-screen devices were often bulky and did not provide a way to conveniently hide the second screen or automatically launch relevant applications upon its deployment (’663 Patent, col. 2:6-32).
• The Patented Solution: The invention proposes a portable device with a primary display and a secondary display that has at least two mechanical arrangements. In a first arrangement, the secondary display is "stowed, out of the way mechanically and visually." In a second arrangement, the secondary display is deployed to be "substantially coplanar and adjacent to the one screen" to allow both to be used (’663 Patent, Abstract; Fig. 1A-1D). When deployed, the secondary display can run the graphical user interface of a second application, enabling two programs to run simultaneously, each on its own display (’663 Patent, col. 2:44-54).
• Technical Importance: This approach sought to provide the multitasking benefits of a dual-monitor setup, common in desktop computing, to portable devices without permanently sacrificing the device's portability and convenience when only a single screen is needed (’663 Patent, col. 2:21-32).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" and "at least the exemplary claims" identified in an attached exhibit, but does not specify any particular claims in the body of the complaint (Compl. ¶11). Independent claim 1 is representative of the patent's core inventive concept.

• Independent Claim 1:
  • A portable device comprising a primary display and a secondary display.
  • The secondary display is physically protected when stowed.
  • The secondary display runs a second application while the primary display runs a first application in at least one operating mode.
  • Both displays show viewable information to a user during at least one operating mode.
  • Selecting first information on the primary display causes the secondary display to show related second information.
  • Selecting third information on the secondary display causes the primary display to show related fourth information.
• The complaint does not explicitly reserve the right to assert dependent claims, but its broad reference to "one or more claims" suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers generically to "Exemplary Defendant Products" that are purportedly identified in "charts incorporated into this Count" via Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market position. It alleges only that the unspecified products "practice the technology claimed by the '663 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint incorporates its infringement allegations by reference to claim charts in Exhibit 2, which is not provided (Compl. ¶17). The complaint's narrative infringement theory alleges that the "Exemplary Defendant Products" directly infringe by "making, using, offering to sell, selling and/or importing" products that "satisfy all elements of the Exemplary '663 Patent Claims" (Compl. ¶11, ¶16). Without the identification of the accused products or the specific claim charts, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"physically protected when stowed" (Claim 1)

• Context and Importance: The scope of this term will be critical for determining infringement, as it defines the required condition of the secondary display in its non-use state. Practitioners may focus on this term because the required level of "protection" could differentiate the patent from devices where a second screen is merely folded shut or covered without specific protective features.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term could be construed broadly to mean any state where the screen is not exposed to the user or typical environment, such as being folded inward against another surface.
  • Evidence for a Narrower Interpretation: The specification describes the "closed position" of devices as providing "much more protection against impact, abrasion, scratches, liquids and other potential harms than the open position" (’663 Patent, col. 7:38-40). This language could support a narrower construction requiring a configuration that provides substantial resilience against specific physical damage, beyond simple concealment.

"runs a second application" (Claim 1)

• Context and Importance: This term defines the software functionality required when the second screen is active. Its construction will determine whether infringement requires two independent software processes or if different views generated by a single, multi-screen-aware application would suffice.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests this can include "a second display window managed by the same program or module that is displaying information on the first display," which may support a broader view that does not require a wholly separate application (’663 Patent, col. 6:16-19).
  • Evidence for a Narrower Interpretation: The patent repeatedly refers to launching an "appropriate second application" and offering "at least two programs running simultaneously, each with its own visual user-interface operating on its own display," which could support a narrower reading requiring two distinct programs (’663 Patent, col. 2:50-54; col. 3:62-65).

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 specific content of these materials is purportedly referenced in Exhibit 2 (Compl. ¶14).

Willful Infringement

The basis for willfulness appears to be post-suit knowledge. The complaint alleges that Defendant gained "actual knowledge of infringement" upon service of the complaint and corresponding claim charts, and that its continued infringement thereafter is willful (Compl. ¶13, ¶15). No allegations of pre-suit knowledge are made.

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

• A primary procedural issue will be one of pleading sufficiency: Does the complaint's failure to identify any accused products by name or to include its infringement contentions in the pleading itself, instead relying entirely on incorporation of an external exhibit, satisfy the plausibility standard required to state a claim for patent infringement?
• A core issue will be one of claim scope: Can the functional limitation "runs a second application" be met by a single software application designed to manage content across two screens, or does it require two distinct, independently operating programs? The resolution of this question will be central to determining infringement for modern dual-screen devices.
• A key definitional question will be the construction of physical state: What degree of security and concealment is required for a secondary display to be considered "physically protected when stowed"? The answer will determine whether the physical design of an accused dual-screen device falls within the patent's scope.