BMW of North America, LLC v. Innovative Display Technologies LLC

I'll research this case—note that the metadata identifies IPR2015-00933 at the PTAB, so I'll verify both the IPR and any underlying district court litigation.

I have solid groundwork. Now let me verify the PTAB outcome, the parallel IPRs, and IDT's corporate background.

Now let me pin down the district court details (venue order, dismissal) and what happened in the parallel IPRs on the '563 patent.

Case Overview & Background

Parties. The named "case" here is not a district-court action but an instituted-petition docket at the Patent Trial and Appeal Board: BMW of North America, LLC and BMW Manufacturing Co., LLC v. Innovative Display Technologies LLC, IPR2015-00933 (P.T.A.B., petition filed Mar. 24, 2015), challenging U.S. Patent No. 6,508,563. The petitioner side is an operating company — BMW of North America (BMWNA), the Delaware-incorporated U.S. importer/distributor headquartered in Woodcliff Lake, New Jersey, and BMW Manufacturing Co. (BMWMC), the Greer, South Carolina assembly operation. The patent owner is a classic non-practicing entity: Innovative Display Technologies LLC, a Texas LLC with its sole office in Plano, Texas, and a subsidiary of publicly traded patent-licensing firm Acacia Research Corporation (NASDAQ: ACTG; its parent, Acacia Research Group LLC, is identified in the record as "ARG"). IDT acquired the Parker/Solid State Opto "light emitting panel" portfolio on June 26, 2013, and its CEO in this period was Marvin Key. IDT's own mandatory notices and Acacia's SEC filings confirm the NPE structure and licensing/enforcement business model.

The technology and accused products. The '563 Patent (issued Jan. 21, 2003; inventors Jeffery R. Parker, Mark D. Miller, and Thomas A. Hough; original assignee Solid State Opto Limited; earliest priority Jan. 16, 1996) is titled "Light Emitting Panel Assemblies for Use in Automotive Applications and the Like." In one-line terms: it claims a light-emitting panel (a light guide/optical conductor) with light sources mounted in a light transition area adjacent a light input surface, using shaped deformities or optical elements on the panel to extract and distribute light — with embodiments using a resiliently deformable elastomeric panel that absorbs impact without breakage, plus instrument-panel and switch/button backlighting variants. The lineage traces back to Lumitex's optical business and Solid State Opto Limited, which sold the family to Rambus before it passed through Rambus Delaware and Acacia to IDT (secondary-source chain-of-title; treat with mild caution). In the underlying suit IDT accused BMW vehicles having exterior lights — specifically BMW 323i/325i/325xi/328i/328xi/330i/330xi/335i/335xi and M3 sedans, and in the amended complaint the tail lamps bearing part numbers 63217161955 and 63217161956 — of infringing the '563 and its continuation, the '956 Patent. That tailoring matters: the '563 was IDT's "auto patent," asserted against lamps, while its sibling "Display Patents" ('547, '194, '177, '660, '974, '370, '816) were asserted against the displays in BMW 3-, 5-, and 6-series vehicles.

Procedural posture and venue. The predicate litigation was Innovative Display Technologies LLC v. BMW of North America, LLC et al., No. 2:14-cv-00106-JRG (E.D. Tex., Marshall Division), complaint filed Feb. 21, 2014 before Judge Rodney Gilstrap (IDT's mandatory notices list Feb. 28, 2014; the docket entry for Dkt. 1 shows Feb. 21). BMW moved to transfer to the District of New Jersey on June 16, 2014 (Dkt. 22); Judge Gilstrap denied the motion in a Memorandum Opinion and Order dated March 30, 2015 (Dkt. 35), holding BMW failed to show D.N.J. was "clearly more convenient" and emphasizing, among other things, that inventor Hough resides in Dallas, that IDT/ARG maintained their only offices in the district, and — notably — that the court had already issued a Markman decision in IDT v. Acer construing seven of the nine patents in suit, 2014 WL 4230037 (E.D. Tex. Aug. 26, 2014), and had several related IDT cases pending. The BMW case was consolidated for all pretrial issues (except venue) into the Hyundai lead case, No. 2:14-cv-201-JRG (Dkt. 34, Oct. 14, 2014), where a claim construction order covering the '563 issued May 4, 2015 (Dkt. 244). Two months after the transfer denial — and one day before the one-year anniversary of BMWMC's March 25, 2014 service date, i.e., against the § 315(b) bar — BMW filed IPR2015-00933 on the '563 and IPR2015-00934 on the '956. The district case settled and was dismissed with prejudice on July 6, 2015 (Dkt. 291); the parties then jointly moved to terminate both IPRs on July 9, 2015 (Paper 6), and the Board (Judges Green, Giannetti, Quinn, and Wormmeester; Quinn writing) terminated both proceedings before any institution decision on July 13, 2015 (Paper 9), granting confidentiality of the settlement agreement. Google Patents' "settled" label matches this record exactly.

Why it's notable. Three things. First, it is a window into the 2013–2015 Acacia/IDT enforcement wave — dozens of suits against LCD/display and consumer-electronics companies and, unusually, against automakers rather than only Tier-1 lighting suppliers, with the auto OEM suits consolidated in Judge Gilstrap's court and each auto defendant (BMW, Toyota, Nissan, Honda, Mercedes-Benz) settling separately. Second, the IPR linkage is a textbook "defendant-side PTAB leverage" pattern: BMW's petitions attacked the '563 with a dense set of automotive- and backlight-specific prior art — the Satsukawa SAE paper on wraparound lamp illumination, Lutz, Tokita, Shinkai, Okano, Takahashi, Nakazawa, and Pristash — supported by a declaration from Dr. Michael Leeby, and the settlement was filed together with the dismissal order, so the license terms remain confidential and unverified. Third, the supply-chain dynamic is instructive: component suppliers Koito Manufacturing and Stanley Electric filed their own IPRs on the '563 and '956 as early as Jan. 15, 2015 (IPR2015-00574, -00575), and Toyota (IPR2015-00828, -00895/-00896/-00897) and Mercedes-Benz USA (IPR2015-01067) filed later in 2015 — i.e., the auto industry responded both at the OEM and supplier levels. Finally, the March 30, 2015 transfer denial is a frequently overlooked pre-TC Heartland data point on how E.D. Tex. retained NPE cases through § 1404(a) even where the accused products were designed abroad and assembled out of state.

I'll research this case and its parallel district court litigation.

Bottom line first

The metadata for this matter is the PTAB side of a two-front dispute. The "litigation" you asked about is Innovative Display Technologies LLC v. BMW of North America, LLC, No. 2:14-cv-00106-JRG (E.D. Tex.) — the district court case in which the '563 patent was asserted — with IPR2015-00933 (and its companion IPR2015-00934, on the '956 patent) as BMW's counter-offensive at the Board. Both tracks ended in settlement in July 2015 before any claim construction ruling specific to BMW, any institution decision, or any trial. No merits adjudication of the '563 patent ever occurred in this dispute.

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Chronology

1. Filing and initial pleadings (2014)

Counsel: IDT — Demetrios Anaipakos, Amir Alavi, Brian Simmons, George W. Webb III (Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing, Houston). BMW — Joseph P. Lavelle / Andrew Neal Stein (Crowell & Moring LLP), the same firm (Sanok, Lindsay) that handled the IPRs.

2. Pre-trial motions of substance

(a) Motion to transfer to D.N.J. — DENIED (the only substantive contested motion decided).

• 2014-06-16: BMW moves under 28 U.S.C. § 1404(a) to transfer to the District of New Jersey (Dkt. 22), relying on Kent (BMWNA) and McCraw (BMWMC) declarations.
• 2014-09-15: IDT opposition (Dkt. 28), leaning heavily on judicial economy — the court had already issued a Markman ruling on 7 of the 9 asserted patents in IDT v. Acer.
• 2014-09-25 reply (Dkt. 29); 2014-10-06 sur-reply (Dkt. 33).
• 2015-03-31: Judge Gilstrap denies transfer (Dkt. 35). He found D.N.J. would have been a proper venue, but BMW failed to show it was "clearly more convenient." Documents-access factor favored transfer "in an abundance of caution"; compulsory process and witness-convenience factors cut against (inventor Thomas A. Hough lives in Dallas; Jeffery R. Parker, in Pleasanton, CA, declared willingness to try the case in E.D. Tex.); local interest and congestion favored E.D. Tex. Opinion: Justia, No. 2:14-cv-00106, Dkt. 35.
• Also during this period: consolidation order (Dkt. 34) consolidating pretrial issues (except venue) into the Hyundai lead case, No. 2:14-cv-00201-JRG-RSP, with the BMW case as a member case.

**(b) No motion to dismiss on the merits, no motion to stay pending IPR, no summary judgment, no Apple v. Samsung-style stay fight.** The IPR petitions were filed on the eve of the § 315(b) bar (see below) and the case settled before any stay motion ripened.

3. Claim construction (Markman)

The case was consolidated for pretrial purposes, so the operative construction order was entered in the lead case:

• 2014-08-26: IDT v. Acer Inc., No. 2:13-cv-522 (E.D. Tex.) (Payne, J.), 2014 WL 4230037 — construed terms in the seven Display Patents; objections overruled 2014-12-15 (Gilstrap, J.). IDT used

I'll search several angles for press coverage of this IPR and the related litigation.

Let me search additional angles for press coverage.

Press coverage of this specific IPR is essentially nonexistent. I searched the case caption, the party names, the '563 patent number, and settlement/verdict angles across general web indexes; no Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, EFF, or JD Supra article about IPR2015-00933 or about IDT v. BMW, No. 2:14-cv-00106 (E.D. Tex.), surfaced. The only item I found that reports the filing itself is the National Law Review's "PTO Litigation Center Report – March 25, 2015," a routine new-filings roundup that lists "Trial Number – IPR2015-00933," Patent No. 6,508,563 ("Light Emitting Panel Assemblies for Use in Automotive Applications and the Like"), patent owner Innovative Display Technologies LLC, and petitioners BMW of North America, LLC and BMW Manufacturing Co., LLC, filed 3/24/2015. Everything else I located is primary docket material — the petition, IDT's mandatory notices identifying the parallel E.D. Tex. suits against BMW, Toyota, Nissan, Honda, and Mercedes-Benz, and the July 9, 2015 joint motion to terminate — not journalism. Any assertion that the trade press covered this IPR in detail should be treated as unsourced; if Law360 or Bloomberg Law wrote about the July 2015 termination, those pieces are paywalled and did not surface in open search, and I have not cited them.

The broader campaign of which this IPR was a part did draw critical press attention. Techdirt published "Know Your Troll: Innovative Display Technologies Targeting Any Company That Creates A Product With An LCD Screen" on 2014-08-12, framing IDT as an Acacia Research subsidiary that "makes no products," counting 37 IDT lawsuits among Acacia's 63 holding companies and roughly 669 total suits, and cataloguing targets that included auto manufacturers (Volkswagen, Mercedes-Benz, Mazda), camera makers (Canon, Nikon), GPS suppliers (TomTom, Garmin) and handset/tablet defendants. Notably, that article does not name BMW, so it is context for the litigation campaign rather than coverage of this proceeding; it also reports specific figures — that IDT's second suit against Apple demanded "nearly $6 billion in 'accrued royalties'" and that IDT had "already secured a licensing agreement from Garmin" — that go beyond anything in the IPR record here and should be attributed to Techdirt alone. Korean trade outlet etnews (2014-12-09) similarly reported in an NPE-focused piece that IDT, described as an Acacia Research subsidiary, had sued Hyundai/Kia in March over automotive-lighting patents — again a sibling case in the same wave, not the BMW matter.

On the outcome, the press record is silent and the reporting gap is filled only by filings. The parties filed a joint motion to terminate IPR2015-00933 on 2015-07-09, simultaneously filing the written settlement agreement as Exhibit 1012 under a joint request to keep it separate and confidential as business confidential information under 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c); BMW's updated exhibit list in that filing also attaches the E.D. Tex. dismissal order (Dkt. 291, July 6, 2015), which dismissed IDT's claims and BMW's counterclaims with prejudice, each side bearing its own costs. No outlet I found reported any settlement figure, royalty rate, or damages number for BMW, and the confidentiality request makes it unlikely one exists in the public record — so the "settled" status reflected in Google Patents is accurate but essentially unelaborated in the press. What did get disclosed publicly were settlements in neighboring cases: Acacia filed an 8-K on June 19, 2015 disclosing that IDT and Delaware Display Group settled and licensed with Mercedes-Benz U.S. International and Mercedes-Benz USA resolving No. 2:14-cv-00535, and an October 2015 8-K item reporting a settlement and license with General Motors and Valeo North America resolving No. 1:14-cv-00850 in D. Del.; Yahoo Finance carried a release on IDT's settlement and license with MiTAC Digital (Magellan). Those disclosures confirm the campaign's pattern of resolving suits through paid licenses without public terms.

The one piece of genuine corporate-side commentary is background rather than case reaction: Acacia's May 2, 2013 press release announcing that a subsidiary had acquired an automotive-illumination portfolio from Rambus covering "headlights, taillights, and internal and external lighting," with CEO Paul Ryan quoted that the deal "demonstrates our growing strength and opportunity in the automotive sector." That release — which predates the BMW suit by nine months and does not mention BMW, the '563 patent, or any litigation — is the closest thing to an executive statement on the record, and it is the origin story for the tail-light assertions that BMW challenged in this IPR. Beyond that, I found no analyst commentary, no industry-reaction quotes, and no reported market impact tied to IPR2015-00933; the case appears to have been resolved quietly eleven days after the district court dismissal and roughly three months after filing, before any institution decision.

Sources

• UNITED STATES PATENT AND TRADEMARK OFFICE
• 11. Active case work: 1Q2015 to 2Q2015; BMW of N
• BEFORE THE PATENT TRIAL AND APPEAL BOARD
• IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
• Innovative Display Technologies LLC v
• C
• Innovative Display Technologies LLC v. BMW of North America, LLC et al
• Innovative Display Technologies LLC v. BMW of North America, LLC et al - This case was last updated from U
• INNOVATIVE DISPLAY TECHNOLOGIES LLC v. Hyundai Motor Co., Dist. Court, ED Texas 2015 - INNOVATIVE DISPLAY TECHNOLOGIES LLC v. Hyundai Motor Co., Dist. Court, ED Texas 2015
• 60. On information and belief, BMW has been and now is directly infringing, and/or inducing infringement by others, and/or contr...
• BEFORE THE PATENT TRIAL AND APPEAL BOARD
• Innovative Display Technologies LLC v

I'll research counsel on both sides — the petitioner (BMW, named first in the IPR caption) and the patent owner/plaintiff (IDT) in the parallel E.D. Tex. litigation.

Now let me pin down the district court appearance list and local counsel details.

Let me verify the full district-court appearance list for 2:14-cv-00106 and BMW's side.

Preliminary note on "plaintiff" in this case

The task asks for plaintiff's counsel, but this proceeding has a split identity that matters:

• In IPR2015-00933 itself, BMW of North America, LLC and BMW Manufacturing Co., LLC are the petitioners (listed first in the Board's caption), and Innovative Display Technologies LLC ("IDT") is the patent owner/respondent.
• In the underlying patent infringement suit, Innovative Display Technologies LLC v. BMW of North America, LLC, No. 2:14-cv-00106-JRG (E.D. Tex., filed Feb. 21, 2014), IDT is the plaintiff and BMW is the defendant.

I therefore list IDT's counsel (the infringement plaintiff) as the primary answer, and add BMW's counsel in both forums for completeness. Everything below is drawn from filed papers and docket mirrors; no attorney has been inferred.

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A. Plaintiff / Patent Owner — Innovative Display Technologies LLC

1. Demetrios Anaipakos — lead trial counsel (district court)

• Firm: Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing P.C. ("AZA"), 3460 One Houston Center, 1221 McKinney Street, Houston, TX 77010 (713-655-1101).
• Role: Filed the original complaint (Dkt. 1, 2/21/2014) and first amended complaint (Dkt. 8, 4/7/2014) and the Rule 7.1/AO-120 filings on IDT's behalf; authored IDT's opposition to BMW's § 1404(a) transfer motion (Dkt. 28, filed 9/15/2014), which Judge Gilstrap credited in denying transfer (Dkt. 35, 3/30/2015). The July 9, 2015 joint motion to terminate in the IPR identifies him expressly as IDT's "Attorney of Record in Co-Pending Litigation."
• Experience note: Board certified in civil trial law (Texas Board of Legal Specialization); career-long plaintiff/defendant complex commercial and IP litigator, repeatedly listed in Best Lawyers (since 2010) and Texas Super Lawyers; name partner of a firm Law360 profiled as a "Texas Powerhouse" and that IAM Patent 1000 ranked among top U.S. plaintiff patent firms. (He and Amir Alavi later left AZA, which now practices as Ahmad, Zavitsanos & Mensing — see The Texas Lawbook, "AZA's Name Shortens with Departure of Two Name Partners.")

2. George Walton Webb III — lead PTAB counsel for the patent owner

• Firm: AZA, Houston (same address); gwebb@azalaw.com.
• Role: IDT's designated lead counsel of record in IPR2015-00933 under 37 C.F.R. § 42.8(b)(3), Reg. No. 60,737. Signed IDT's Mandatory Notices (Paper 5, Apr. 10, 2015) and co-signed the Joint Motion to Terminate (Paper 6, July 9, 2015).
• Experience note: A registered practitioner who served as IDT's PTAB lead across the '563/'956 automotive-lighting IPRs; filed the same mandatory notices in the near-identical Toyota IPR2015-00895 on the '563 patent. (Minor record inconsistency worth flagging: the July 2015 motion lists his Reg. No. as 60,797, while the April 2015 notices list 60,737.)

3. Amir H. Alavi — back-up counsel (both forums)

• Firm: AZA, Houston (then a name partner).
• Role: Named back-up PTAB counsel in IDT's mandatory notices (pro hac vice motion noted as "pending"); also listed on the E.D. Tex. docket as counsel for plaintiff/counter-defendant.
• Experience note: IAM Patent 1000 "silver"-level recommended Texas patent litigator, singled out by IAM for his lead role in Versata Software Inc. v. SAP America Inc. (the $139M+ Texas verdict); frequent Best Lawyers/Lawdragon honoree for IP and commercial litigation.

4. Brian Ervin Simmons — back-up counsel / of counsel

• Firm: AZA, Houston (listed as Of Counsel in firm materials); bsimmons@azalaw.com.
• Role: Named back-up PTAB counsel in the mandatory notices (pro hac vice "pending") and listed on the district docket as plaintiff-side counsel.
• Experience note: Member of AZA's IP group on the IDT matters; described in firm/press materials as part of the firm's patent-litigation bench (IAM/HBJ top-10 Houston IP firm coverage).

5. Thomas John Ward, Jr. — local counsel

• Firm: Ward & Smith Law Firm, Longview, TX (903-757-6400).
• Role: Notice of Attorney Appearance for plaintiff IDT filed Sept. 29, 2014 (Dkt. 30) — the standard Marshall-division local-counsel arrangement for the IDT campaign. The same firm served as IDT's local counsel in sibling suits (e.g., IDT v. Volkswagen AG, No. 2:14-cv-00300, where Thomas John Ward, Jr., Jack Wesley Hill, and Claire Abernathy Henry appear for IDT).
• Experience note: Longtime E.D. Tex. patent local counsel; the Ward firm is one of the standard Marshall/Ringgold plaintiffs' shops for NPE dockets.
• Caveat: For the BMW case specifically I confirmed only Ward's appearance; I did not find an appearance by Hill or Henry on the 2:14-cv-00106 docket sheet, so I do not attribute them to this case.

Counsel that did not appear here (worth flagging)

• Bragalone Conroy P.C. (Justin B. Kimble, Jeffrey R. Bragalone, Terry A. Saad, Nicholas C. Kliewer, T. William Kennedy — Dallas) was IDT's PTAB counsel in roughly twenty sibling IPRs, per its Feb. 10, 2015 updated power of attorney in IPR2015-00363. That POA enumerates the covered proceedings and does not include IPR2015-00933, consistent with AZA handling this one.
• David E. Warden (AZA, Reg. No. 35,733) appeared for IDT in IPR2015-00574 (Koito/Stanley, same '563 patent) but I found no appearance by him in -00933.
• No in-house IDT/Acacia attorney appears as counsel of record; IDT CEO Marvin Key appears only as a declarant/witness (Dkt. 28-2).

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B. Petitioner / Defendant — BMW of North America, LLC and BMW Manufacturing Co., LLC

IPR2015-00933 (and companion IPR2015-00934 on the '956 patent)

• Jeffrey D. Sanok — lead counsel, Reg. No. 32,169; Crowell & Moring LLP, Intellectual Property Group, 1001 Pennsylvania Avenue NW, Washington, DC 20004-2595. Longtime PTAB/ITC patent litigator (Crowell & Moring IP Group). Signed the petitioner power of attorney (Mar. 24, 2015) and the joint motion to terminate.
• Jonathan M. Lindsay — back-up counsel, Reg. No. 45,810; Crowell & Moring LLP (Washington, DC address of record, with an Irvine, CA phone line). Co-signed the power of attorney and the termination motion; also identified as BMW's counsel in the co-pending litigation section of that motion.
• Harlanne Caulfield, Corporate Counsel, BMW Manufacturing Co., LLC — in-house, executed the § 42.10(b) power of attorney on BMW's behalf (not counsel of record before the Board).

2:14-cv-00106 (E.D. Tex.)

• The docket mirrors list Andrew Neal Stein as the sole attorney of record for the BMW counterclaimants/counter-defendants (BMW NA and BMW Manufacturing). I could not verify his firm affiliation from open sources, and I decline to guess; note also that Crowell & Moring's Washington team is not listed on the district docket in the Justia/UniCourt mirrors, which suggests BMW's E.D. Tex. trial team was staffed separately (likely with local counsel) from its PTAB team. A PACER pull of the 2:14-cv-00106 docket sheet (attorney appearance entries) would resolve this in one step.

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C. Sourcing and gaps

• Counsel identifications above are grounded in primary filings: the petitioner Power of Attorney (Mar. 24, 2015); IDT's Mandatory Notices (Paper 5, Apr. 10, 2015); the Joint Motion to Terminate (Paper 6, July 9, 2015), which carries both sides' signature blocks and expressly names Anaipakos as litigation counsel of record; and the E.D. Tex. docket entries for Dkts. 1, 8, 28, 30 and 35 (Justia docket; UniCourt; Dkt. 35 opinion).
• Nothing here is sealed in a way that conceals counsel. The only confidentiality in the record is the settlement agreement (Ex. 1012) filed under the § 317(b)/§ 42.74(c) request; that does not affect appearances.
• Unresolved: whether the Board granted the pro hac vice motions for Alavi and Simmons (still "pending" as of the April 2015 notices; the case terminated July 2015 before any further substantive papers), and the firm for Andrew Neal Stein.
• Contradiction to flag: IDT's mandatory notices state the E.D. Tex. suit was "filed February 28, 2014," but the docket and Judge Gilstrap's opinion both give February 21, 2014. The notice appears to be in error.

I'll research counsel of record on both sides — the district court defendants (BMW) and the IPR parties — using docket sources and firm records.

Clarifying who the "defendant" is

Two different captions matter here, and the metadata points to the PTAB one:

So "counsel for the defendant(s)" maps to BMW's defense team (Crowell & Moring) in the district court, mirrored by Crowell's PTAB team in the IPR — and IDT's patent-owner team is set out below for completeness, since it is the opposing side of record in this proceeding.

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1. BMW of North America, LLC / BMW Manufacturing Co., LLC — Defendants (E.D. Tex.) and Petitioners (PTAB)

District court (No. 2:14-cv-00106-JRG)

No local counsel appears on the face of the docket. The E.D. Tex. docket (Justia/UniCourt extracts) shows only Crowell & Moring names on the BMW side — no Marshall/Tyler local-counsel firm. E.D. Tex. has no formal local-counsel rule, so this is not anomalous, but I could not access PACER directly to rule out a later-substituted local firm; treat "no local counsel" as docket-derived but not PACER-verified.

PTAB (IPR2015-00933) — this is the operative "counsel of record" for this case

Per BMW's Power of Attorney dated 2015-03-24 (Paper 2), BMW appointed practitioners under Crowell & Moring Customer No. 23911:

In-house contact (not counsel of record): Harlanne Caulfield, Corporate Counsel, BMW Manufacturing Co., LLC — executed the 2015-03-24 Power of Attorney on behalf of the petitioners. She is a client-side signatory, not an attorney appearing before the Board.

Note on Lavelle/Stein vs. Sanok/Lindsay: Lavelle and Stein appear on the district court docket but are not among the practitioners named in the PTAB power of attorney; the POA designates only Sanok (lead) and Lindsay (back-up). That division of labor — district-court team vs. registered-practitioner PTAB team — is consistent with Lavelle/Stein not being registered to practice before the USPTO, though I have not independently verified their registration status (neither appears with a Reg. No. in the PTAB papers I reviewed). The earlier sections' reference to "Joseph P. Lavelle / Andrew Neal Stein … the same firm (Sanok, Lindsay) that handled the IPRs" is therefore accurate as a firm-level statement but should not be read as the same individual attorneys appearing in both forums.

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2. Innovative Display Technologies LLC — Patent Owner / Respondent in IPR2015-00933 (and plaintiff below)

Important caveat / possible discrepancy to flag: IDT did not use one uniform PTAB firm across the campaign. In the LG Display IPRs on the Display Patents (e.g., IPR2015-00487) and in IPR2015-01717, IDT's power of attorney names Justin B. Kimble, Jeffrey R. Bragalone, Terry A. Saad, Nicholas C. Kliewer and T. William Kennedy of Bragalone Conroy P.C. (Dallas); in IPR2015-00574 it used David E. Warden of AZA alongside Webb. I located only Webb as the signing Patent-Owner attorney in IPR2015-00933's papers, and I did not locate IDT's own power of attorney/mandatory-notices signature block designating lead and back-up counsel in this IPR (the April 10, 2015 mandatory notices I could retrieve show only the certificate of service on petitioner's counsel). So: Webb is confirmed as counsel of record by signature; whether another AZA or Bragalone Conroy attorney was formally designated lead counsel in IPR2015-00933 is not confirmed from the record I could reach.

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3. What I could not verify

• PACER was not directly accessed. Docket-level attorney lists come from Justia and UniCourt extracts of the E.D. Tex. docket and from PTAB filings on Docket Alarm / PTACTS. A PACER pull of No. 2:14-cv-00106 would confirm whether any additional Crowell attorney or local counsel entered an appearance between April 2014 and the July 2015 dismissal.
• No sealed or ex parte appearance issues affect this list: the parties' July 9, 2015 confidentiality request (Paper 7) covered only the settlement agreement (Ex. 1012), not counsel designations. No attorney information in this matter is sealed.
• Bar numbers, firm titles and office assignments are as printed in the PTAB papers; individual practice histories beyond the docketed activity above are not asserted here because I could not corroborate them from firm bios or reported decisions in this search.

Primary sources

• BMW Petitioners' Power of Attorney, IPR2015-00933 (2015-03-24), naming Sanok (lead) and Lindsay (back-up), signed by Harlanne Caulfield — Docket Alarm copy
• IDT Mandatory Notices, IPR2015-00933 (2015-04-10), with service certificate listing Sanok/Lindsay as petitioners' lead/back-up counsel — Docket Alarm copy
• Joint request for confidential treatment, IPR2015-00933 (2015-07-09), signed by Sanok/Lindsay for petitioners and /George W. Webb/ for patent owner — Docket Alarm copy
• E.D. Tex. docket, No. 2:14-cv-00106 — [Justia](https://