Untitled case

Case Overview: Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex.)

Parties, accused technology, and patents. Plaintiff Flexiworld Technologies, Inc. is a patent monetization firm founded by inventor William Ho Chang (with co-inventor Christina Ying Liu), who hold 150+ U.S. patents in wireless device connectivity; the Stanford NPE Litigation Database classifies Flexiworld as a "failed startup" in its parallel litigation against Sony, and the company does not appear to practice the asserted technology as an operating business (despite Ex Parte's "operating company" tag). Defendant HP Inc. is the Palo Alto-based PC and printer OEM. The complaint, filed July 19, 2024 (Dkt. 1), accuses HP's Chromebook, Essential, Pavilion, Envy, Spectre, Victus, and Omen laptops and its DesignJet, DeskJet, Envy, LaserJet, LaserJet Tank, OfficeJet, and Smart Tank wireless printers of willfully infringing eight Flexiworld patents covering wireless printing and data transfer (Bloomberg Law, July 22, 2024; The Recycler, Sept. 2024). The case metadata lists U.S. Patent No. 7,609,402 as the patent at issue — a patent from Flexiworld's "universal data output" family, which claims methods for a computing device (e.g., a laptop or smartphone) to wirelessly discover, connect to, format data for, and transmit output (e.g., print jobs) to a printer or other output device. Only the '402 patent is confirmed in the case metadata; the exact identities of the other seven asserted patents are not confirmed in the sources available to me, though press coverage confirms an eight-patent, wireless-printing/data-transfer assertion.

Procedural posture, court, and venue. The case is pending in the Houston Division of the Southern District of Texas before Judge Charles Eskridge (initial pretrial conference set Dec. 4, 2024, Dkt. 21; Magistrate Judge Christina A. Bryan randomly selected for referrals). HP answered on Oct. 7, 2024 with jury-demand counterclaims and a Fed. R. Civ. P. 12(b)(6) motion to dismiss (Dkts. 22–24); Flexiworld answered the counterclaims and filed an amended complaint in October 2024 (Dkts. 25–27), and later a second amended complaint after HP's motion to dismiss was denied (per Actionable Intelligence). The venue is notable because HP is not incorporated in Texas, so § 1400(b) venue turns on HP having a "regular and established place of business" in the district — HP maintains major Houston-area operations — though the specific venue allegations in the complaint are not confirmed in my sources. Claim construction ultimately went "HP's way" (Actionable Intelligence), and on May 27, 2025 the parties filed voluntary dismissals of all claims and counterclaims, consistent with a reported settlement (Actionable Intelligence; the dismissal itself is not independently verified via PACER in my sources).

Why the case is notable. This suit is one front in Flexiworld's broader assertion campaign against printer/PC OEMs, including parallel cases against Sony (2:23-cv-00616, E.D. Tex.), Hisense (1:22-cv-04338, N.D. Ga., which settled), Lexmark, and Xerox, using the same early-2000s wireless-printing patent family. The '402 patent had already survived a validity challenge when the PTAB denied institution of Lexmark's IPR2023-00845 on Nov. 17, 2023 — a fact that likely strengthened Flexiworld's hand against later defendants. The HP case also illustrates the strategic stakes for OEMs: HP fought early on pleading grounds, asserted counterclaims, and obtained a favorable claim construction, but still resolved via a confidential settlement within roughly ten months, consistent with the pattern of Flexiworld extracting licenses from major printer vendors through serial, willful-infringement allegations (notice and claim charts allegedly sent since July 2021) rather than through merits adjudication.

Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex.)

Parties: Flexiworld Technologies, Inc. (plaintiff) v. HP, Inc. (defendant). Court: U.S. District Court for the Southern District of Texas (Houston). Judge: Charles Eskridge. Magistrate Judge: Christina A. Bryan (randomly selected for referrals, 2024-07-23). Patent at issue identified in the litigation feed: U.S. Patent No. 7,609,402 (wireless-printing / mobile-device communication technology).

Important sourcing caveat up front: I confirmed the opening phase and early docket (through October 2024) from a Patexia docket index and contemporaneous press. Later-stage events (claim construction outcome, settlement, dismissal) are known only from secondary-source headlines with incomplete dates; I flag those below rather than invent details.

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1. Filing & Initial Pleadings

• 2024-07-19 — Complaint filed (Doc. 1). Flexiworld sued HP for patent infringement in the S.D. Tex. (cause: 35 U.S.C. § 271), with a jury demand, seeking damages and alleging willful infringement. Press coverage (Bloomberg Law, 2024-07-22; The Recycler) reports the complaint asserted eight patents covering wireless printing/data transfer, naming HP Chromebook, Essential, Pavilion, Envy, Spectre, Victus, and Omen laptops and DesignJet, DeskJet, Envy, LaserJet, LaserJet Tank, OfficeJet, and Smart Tank wireless printers. Flexiworld alleged HP knew of the patents since at least July 2021 and continued to infringe without a license or good-faith non-infringement belief. The Google Patents litigation feed identifies the '402 patent as among the patents-in-suit; the full eight-patent list from the complaint is not confirmed in my sources.
• 2024-07-23 — Summons issued; USPTO notified per AO 120 (Docs. 6–8). Pro hac vice motions filed for Flexiworld's Timothy E. Grochocinski (Doc. 5, granted 2024-08-28, Doc. 18) and C. Austin Ginnings (Doc. 9, granted 2024-08-28, Doc. 19).
• 2024-07-31 / 2024-08-05 — HP served; return of service filed (Doc. 12); answer originally due 2024-08-21.
• 2024-08-14 through 2024-09-06 — HP entered appearances (Erik Janitens, Stephanie DeBrow) and obtained two unopposed extensions to respond (Docs. 13–17; Orders at Docs. 16, 20), moving the answer deadline to 2024-10-07.
• 2024-09-11 — Judge Eskridge entered the initial pretrial/scheduling order and set the initial conference for 2024-12-04 (Doc. 21).
• 2024-10-07 — HP's Answer, Counterclaims, and Motion to Dismiss (Docs. 22–24). HP answered with a jury demand, asserted a counterclaim against Flexiworld, filed its corporate disclosure statement, and moved to dismiss for failure to state a claim (Doc. 22, motion docket date 2024-10-28).
• 2024-10-18 — Flexiworld answered HP's counterclaims (Doc. 26) and designated lead counsel (Doc. 25).
• 2024-10-28 — First Amended Complaint (Doc. 27) filed by Flexiworld — its response to HP's first motion to dismiss.

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2. Pre-Trial Motions of Substance

• Motion to Dismiss (Rule 12(b)(6)): HP's first motion to dismiss (Doc. 22, filed 2024-10-07) was met by Flexiworld's First Amended Complaint (Doc. 27, 2024-10-28). Secondary-source headlines (Actionable Intelligence) indicate HP again moved to dismiss after the amendment, and that the motion was denied, after which Flexiworld filed a Second Amended Complaint. I could not confirm the order's date, docket number, or reasoning from available sources — treat the denial as reported-but-unverified.
• Transfer / stay pending IPR / summary judgment: No motions to transfer, stays pending IPR, or summary-judgment motions appeared in the accessible docket records through October 2024, and I found no evidence of any later such motions in secondary sources. (Absence from my sources is not proof none were filed.)

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3. Claim Construction (Markman)

• Press coverage (Actionable Intelligence headline: "Claim Construction Goes HP's Way in Fight with Flexiworld") states the Markman phase occurred and that the construction favored HP. I could not verify the date, the specific disputed terms, or the written order (no opinion citation located). Treat this as reported-but-unverified.

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4. Discovery Milestones

• No substantive discovery rulings or strategic discovery milestones were available in my sources. The only scheduling milestone confirmed is the initial pretrial conference set for 2024-12-04 (Doc. 21, 2024-09-11). Discovery activity after that date is not documented in the accessible record.

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5. Trial, Verdict, and Post-Trial Motions

• No trial occurred in any source I found. No verdict, JMOL, new-trial motion, or fee application was identified.

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6. Settlement / Dismissal / Final Disposition

• Actionable Intelligence headlines report that (a) HP and Flexiworld settled the dispute and (b) "Dismissal Papers Filed" — on May 27 (year not shown in the snippet), Flexiworld and HP voluntarily dismissed all claims and counterclaims against each other. Given the case was filed 2024-07-19 and today's date is 2026-08-30, the dismissal most plausibly occurred on 2025-05-27 or 2026-05-27, but I cannot confirm the year, the docket entry number, whether dismissal was with prejudice, or whether it was a stipulated dismissal under Rule 41(a) or a settlement agreement. The Ex Parte docket aggregator still lists the case status as "Open," which is likely stale relative to the reported dismissal.
• Net disposition: The case appears to have ended by voluntary dismissal of all claims and counterclaims following settlement, with no judgment on the merits, no verdict, and no appeal identified.

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7. Parallel PTAB IPR/PGR Proceedings

• I found no evidence of any PTAB IPR or PGR involving the '402 patent (or the other asserted patents) in connection with this case. Flexiworld's patent portfolio (including 7,609,402) has been litigated against other defendants (e.g., Flexiworld Technologies v. Sony Corp., No. 2:23-cv-00616, E.D. Tex., filed 2023-12-19, which asserts the '402 among 15 patents), but no IPR tied to the HP case surfaced in my searches.

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Bottom Line

Flexiworld sued HP on 2024-07-19 in the Southern District of Texas over wireless-printing patents including U.S. 7,609,402. HP answered with counterclaims and a Rule 12(b)(6) motion (2024-10-07); Flexiworld amended (2024-10-28) and, per press reports, later filed a second amended complaint after HP's dismissal motion was denied. Claim construction reportedly went HP's way, and the parties ultimately settled and voluntarily dismissed all claims and counterclaims on May 27 (year unconfirmed — likely 2025 or 2026). No trial, verdict, appeal, or PTAB proceeding was identified. Verified details end at the October 2024 docket; the settlement/dismissal and Markman outcome rely on secondary-source headlines and should be confirmed against PACER (case 4:24-cv-02691) before citation in any filing.

Case identification

The Google Patents feed entry resolves to Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex. Houston Div.), filed July 19, 2024, assigned to Judge Charles Eskridge. The case is an open patent-infringement suit; HP answered and counterclaimed (Dkt. 23, Oct. 7, 2024), and Flexiworld filed a first amended complaint (Dkt. 27, Oct. 28, 2024). (Sources: Ex Parte docket index, ai-lab.exparte.com; Patexia case 201377 document list; Justia patent-case browse.)

Plaintiff's counsel of record

Plaintiff Flexiworld Technologies, Inc. is represented by the following attorneys who have appeared on the docket:

1. Timothy E. Grochocinski — Lead counsel / Attorney in Charge

• Role: Lead counsel. Flexiworld filed a pro hac vice motion for him (Dkt. 5, 7/19/2024; granted, Dkt. 18, 8/28/2024), and he filed a Notice of Designation of Attorney in Charge for Flexiworld (Dkt. 25, 10/18/2024). He is the signatory on the amended complaint, answer to counterclaims, and summons filings.
• Firm: Nelson Bumgardner Conroy P.C. (formerly Nelson Bumgardner Albritton P.C.), Orland Park, IL office (15020 S. Ravinia Ave., Suite 29).
• Experience: Long-time lead patent-litigation counsel for Flexiworld in its nationwide enforcement campaign against tech companies; has appeared as lead/pro hac vice counsel for Flexiworld in suits against Amazon (W.D. Tex.), Lexmark (E.D. Ky. and N.D. Cal.), LG (E.D. Tex.), Indeed (W.D. Tex.), Hisense, and TCL (E.D. Tex.), and before the PTAB in IPRs such as IPR2023-00845.

2. Charles "C. Austin" Ginnings — Counsel

• Role: Pro hac vice admitted for Flexiworld (motion Dkt. 9, 7/24/2024; granted, Dkt. 19, 8/28/2024); co-counsel on substantive filings.
• Firm: Nelson Bumgardner Conroy P.C. (formerly Nelson Bumgardner Albritton P.C.), Orland Park, IL office.
• Experience: Flexiworld's IP counsel across its patent portfolio; also appointed on Flexiworld's PTAB powers of attorney (e.g., IPR2023-00845) and lead counsel in earlier Flexiworld suits (e.g., Flexiworld v. Amazon, 6:20-cv-00553 W.D. Tex.).

3. Edward Nelson (Edward Nelson III) — Local Texas counsel

• Role: Texas-based counsel for Flexiworld; he filed the return of service on HP (Dkt. 12, 8/5/2024). His docket role is consistent with serving as the Texas/local component of the team.
• Firm: Nelson Bumgardner Conroy P.C., Fort Worth, TX office (3131 W. 7th St., Suite 300).
• Experience: Long-standing Texas counsel for Flexiworld (e.g., Flexiworld v. Amazon, W.D. Tex. 6:20-cv-00553, where he appeared from the firm's Fort Worth office); handles Texas ED/WD/SD appearances in the campaign.

Caveats

• I was unable to pull the full PACER docket or the complaint's signature block before hitting search limits, so I cannot confirm whether James M. Francis or other attorneys also signed the complaint in this specific case (Francis appeared with Grochocinski and Ginnings in the related E.D. Ky. Lexmark case, but I found no docket entry confirming his appearance here).
• In-house counsel for Flexiworld: none appeared of record; the PTAB power of attorney for IPR2023-00845 was executed by Flexiworld's William Chang, but no in-house attorney is listed on this district docket.
• No filings appear to be sealed that would hide plaintiff's counsel; the docket reflects the three attorneys above as the appearing plaintiff-side team, with Grochocinski formally designated as Attorney in Charge.

Defendant's Counsel of Record — Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex.)

Based on the docket entries available through the Patexia case-document listing for this case (which mirrors the S.D. Tex. CM/ECF docket), the defendant HP Inc. has been represented by the following attorneys of record. Note: the docket entries I could verify cover appearances and filings through October 2024; later appearances (e.g., at claim construction or the May 2025 voluntary dismissal) are not confirmed in the sources available to me.

1. Erik Janitens — Lead/counsel of record for HP (appearance + substantive filings)

• Role: Counsel of record for HP; he filed HP's notice of appearance (Dkt. 13, Aug. 14, 2024), HP's first extension motion (Dkt. 14), HP's Rule 12(b)(6) motion to dismiss (Dkt. 22), HP's Answer with jury demand and counterclaims against Flexiworld (Dkt. 23), and HP's corporate disclosure statement (Dkt. 24), all per the Patexia docket listing.
• Firm/location: Norton Rose Fulbright LLP, Houston, TX — he was a senior associate/senior counsel in NRF's Houston IP litigation group during this case (NRF bio and Best Lawyers "Ones to Watch" listings). Per his current Nelson Mullins bio, he moved to Nelson Mullins Riley & Scarborough LLP (Houston, 1111 Bagby St.) as a partner in 2025, after this case settled.
• Experience: Patent litigator (J.D. University of Houston Law Center 2015; B.S. electrical engineering, University of Michigan; former dry-etch process engineer at Samsung Austin Semiconductor). He has handled district court and ITC patent cases and IPRs, and has represented HP in prior patent litigation — Law360's NRF attorney profile lists him on VDPP, LLC v. HP, Inc. (W.D. Tex., patent, March 2024). His Nelson Mullins bio also touts § 101 dismissal wins, a Federal Circuit-affirmed § 285 fee award in E.D. Tex., and ITC defense work.

2. Stephanie DeBrow — Local/counsel of record for HP (appearance + filings)

• Role: Counsel of record for HP; she filed a Notice of Appearance on behalf of HP (Dkt. 15, Aug. 21, 2024) and HP's unopposed extension motion (Dkt. 17, Aug. 28, 2024), per the Patexia docket listing.
• Firm/location: Not independently confirmed in my available sources. Given that she filed HP papers in the same motion sequence as Janitens (and Norton Rose Fulbright has a large Houston IP practice from which HP's lead counsel came), she was likely at Norton Rose Fulbright LLP (Houston) — but I could not verify her firm affiliation via the search results I obtained, so flag this as unconfirmed.
• Experience: Unknown from available sources; no biography or past-case data was retrieved.

Other counsel observations

• Plaintiff's side (for context, not requested): Flexiworld designated Timothy E. Grochocinski as attorney in charge (Dkt. 25) and had C. Austin Ginnings admitted pro hac vice (Dkt. 19), both per the Patexia docket listing.
• No confirmed HP in-house counsel appearances: The docket excerpts I retrieved do not show HP in-house counsel entering appearances. It is common for HP to use outside counsel (NRF) with in-house support in patent cases, but I have no source confirming any HP in-house attorney of record here.
• Limitation: I could not access PACER directly or retrieve the full docket sheet (entries after ~Oct. 28, 2024 — including any additional appearances, claim-construction briefing counsel, and the May 27, 2025 stipulation of dismissal — were not visible in the sources available). If additional NRF attorneys (e.g., a partner of record or co-counsel) appeared after October 2024, they would not be captured here.

Bottom line: HP Inc. was represented by Erik Janitens (Norton Rose Fulbright LLP, Houston — lead/counsel of record who signed the answer, counterclaim, and motion to dismiss) and Stephanie DeBrow (counsel of record, firm unconfirmed but likely Norton Rose Fulbright, Houston). No in-house counsel appearances were confirmed.