CommWorks Solutions, LLC v. NXP USA, Inc.

I'll research this case thoroughly using web search.

Let me verify the complaint details, corporate structure, and any PTAB proceedings.

Good grounding so far. Let me verify venue facts, NXP's Texas presence, PTAB history on these patents, and the campaign context.

Case Overview: CommWorks Solutions, LLC v. NXP USA, Inc., No. 7:25-cv-00395 (W.D. Tex.)

The parties. CommWorks Solutions, LLC is a Georgia limited liability company with its principal place of business at 44 Milton Ave., Suite 254, Alpharetta, GA 30009 (verified in its own complaint in the parallel CommWorks v. RCN Telecom action, S.D.N.Y. 1:20-cv-07534, Dkt. 1 ¶ 1). It is a non-practicing patent assertion entity: every complaint in this campaign pleads ownership and a right to damages but no product activity, and its Rule 7.1 disclosure identifies Brainbox Innovations, LLC as its corporate parent (Dkt. 4 in this case; same disclosure in CommWorks v. EarthLink, E.D. Tex. 2:25-cv-00716). Brainbox has been publicly characterized as an Intellectual Ventures–linked portfolio-holding structure — in three September 2021 declaratory judgment suits, Altice USA alleged that Brainbox/CommWorks and sister entities (DataCloud Techs., DigiMedia Tech.) ran "a broader, coordinated patent assertion campaign," with IV retaining a security interest and a revenue "backend" from IV's 2019–2020 portfolio sell-offs (IPWatchdog Patent Filings Roundup, Sept. 22, 2021, describing D. Del. Nos. 1:21-cv-01321/01322/01323). Defendant NXP USA, Inc. is the U.S. operating subsidiary of NXP Semiconductors N.V., a global semiconductor supplier whose connectivity and Wi-Fi SoC lines are the accused instrumentalities here; I have not independently verified NXP USA's Austin, Texas headquarters or its acquisition of Marvell's Wi-Fi/Bluetooth connectivity business in this research pass, though both are widely reported and would explain why CommWorks sued NXP and Marvell (CommWorks v. Marvell, 7:25-cv-00354) in the same division weeks apart. On the docket, CommWorks is represented by Rozier Hardt McDonough PLLC (James F. McDonough III; Jonathan L. Hardt appeared at Dkt. 5), and NXP by Bracewell LLP (Michael Chibib signed NXP's extension motions, Dkts. 9, 11) — firm attributions beyond the docket filers come from a third-party AI-generated PACER digest and should be treated as moderate confidence.

The accused technology and patents. The complaint does not accuse a single product but rather categories of NXP SoCs and devices grouped by standardized networking functionality: chips with Wi-Fi Multimedia (WMM) / 802.11-2007+ QoS; chips with Wi-Fi Protected Setup (WPS); chips with IEEE 802.3ah (Ethernet in the First Mile); and chips with ITU-T G.984 (GPON) / G.9807.1 (XG-PON) support. The case metadata lists two patents — US 7,027,465 and RE44,904 — which are the same family: the '465 patent, "Method for Contention Free Traffic Detection" (issued Apr. 11, 2006 from App. No. 10/167,986, filed June 11, 2002), claims a method of detecting priority data frames by extracting a bit pattern from a predetermined offset in a frame and comparing it to a search pattern — i.e., lightweight MAC-layer QoS/traffic prioritization that avoids deep packet inspection, aimed at low-cost WLAN access points. RE44,904, "Method for Contention Free Traffic Detection," was reissued May 20, 2014 and is the reissue of that same disclosure; CommWorks pleads both in parallel counts against the same WMM/QoS accused products. Note the discrepancy: the docket's exhibit list and complaint-body counts in this case and its near-identical siblings (STMicroelectronics, Marvell, AVM, DrayTek) show CommWorks actually asserted a six-patent package — '465, RE'904, 7,177,285 (WPS time-based provisioning), 7,463,596 (device association on power-on/signal onset), 7,911,979 (Wi-Fi mesh), and 6,832,249 (multi-layer QoS monitoring/provisioning for broadband access) — while the authoritative metadata for this case records only '465 and RE'904. I would treat the metadata as controlling for the "patents at issue" and flag the fuller set as pleaded-but-unresolved, since the case never reached a narrowing order.

Posture, venue, and why it matters. Filed September 2, 2025, the case landed in the Midland/Odessa Division (the "7:" prefix), assigned to Judge David Counts under the W.D. Tex. order assigning patent business (filed July 25, 2022), and referred to Magistrate Judge Derek T. Gilliland (Dkt. 8, Sept. 5, 2025). Venue matters because NXP USA's Texas footprint makes W.D. Tex. — the nation's busiest patent plaintiff forum — readily available to CommWorks, and because assignment in Midland/Odessa routed the case away from Judge Albright's Waco docket and its established patent case-management practices. NXP never answered: after service on September 4, 2025 and two unopposed extensions (answer due Oct. 27, 2025; Dkts. 9–12), CommWorks filed a Notice of Voluntary Dismissal With Prejudice on October 31, 2025 (Dkt. 13) under Rule 41(a)(1)(A)(i), and the court closed the action November 3, 2025 (Dkt. 14) with the AO-120 report sent to the USPTO (Dkt. 15), each side bearing its own fees. The court's order expressly notes the dismissal was self-effectuating under In re Amerijet Int'l, 785 F.3d 967, 973 (5th Cir. 2015) — so there is no claim construction, no § 101 ruling, no invalidity or infringement adjudication, and the patents remain presumptively valid; NXP's only benefit is res judicata protection as to those patents and those products. The case is notable as one data point in a synchronized 2025–26 CommWorks licensing campaign against the Wi-Fi/broadband semiconductor supply chain — contemporaneous suits against STMicroelectronics (7:25-cv-00363, dismissed the same day, Oct. 31, 2025), Marvell (7:25-cv-00354), Texas Instruments (E.D. Tex. 2:25-cv-00439), AVM (2:25-cv-00026), DrayTek (2:25-cv-00024), EarthLink (2:25-cv-00716), u-blox (E.D. Va. 1:25-cv-02504), Broadcom (C.D. Cal. 2:25-cv-02998), and later Realtek and Grandstream — and because its infringement theories map standardized functionality (WMM/802.11e QoS, WPS, 802.3ah, GPON) onto method claims, which invites both SEP/FRAND-adjacent and § 101 "implementation of a standard" defenses that were never tested here. For IPR linkage: I found no petition challenging the '465 or '904 patents; the verified PTAB history is Unified Patents' IPR2021-01297 against a different CommWorks patent, US 8,923,846, in which CommWorks identified Brainbox Innovations as a real party in interest — indicating that Unified (and other defensive aggregators) monitor this portfolio, and that defendants in this campaign retain IPR leverage even though NXP did not use it. Whether NXP's dismissal reflects a paid license, a settlement, or simply a tactical withdrawal is not publicly sourced; the same-day dismissal of the STMicro case suggests a coordinated resolution, but that is inference, not a documented fact.

I'll research this case across multiple sources.

Let me dig into parallel PTAB proceedings and the fuller docket.

CommWorks Solutions, LLC v. NXP USA, Inc., No. 7:25-cv-00395 (W.D. Tex.) — Chronology of Key Legal Developments

Bottom line: This was a short-lived, pre-answer case. It ran from filing on 2025-09-02 to a self-effectuating voluntary dismissal with prejudice on 2025-10-31 — roughly eight weeks. NXP never answered, no counterclaims were filed, and the case never reached a motion to dismiss, transfer, stay, Markman, discovery, dispositive motions, or trial. No PTAB proceeding against either named patent is identified in the public record I could locate.

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1. Filing & initial pleadings

2025-09-02 — Complaint filed (Dkt. 1). CommWorks Solutions, LLC filed a complaint for patent infringement under 35 U.S.C. § 271 in the Western District of Texas (Midland–Odessa Division), Case No. 7:25-cv-00395. Assigned to Judge David Counts pursuant to W.D. Tex.'s business-assignment order for patent cases (entered 2022-07-25). (Docket, CommWorks v. NXP USA)

• Same day: Rule 7 corporate disclosure statement (Dkt. 4); Notice of Filing of Patent/Trademark Form (AO 120) forwarded to the USPTO Director (Dkt. 3); Request for Issuance of Summons (Dkt. 2); Notice of Appearance of Jonathan L. Hardt for CommWorks (Dkt. 5).
• The complaint attached a series of "Evidence of Use" exhibits — Dkts. 1-1 through 1-7, expressly covering U.S. Patent Nos. 7,177,285; 7,463,596; 7,911,979; RE44,904; 7,027,465; 6,832,249 and one further exhibit (Dkt. 1-7) whose patent number is truncated in the public docket entry.

⚠️ Scope discrepancy to flag. Your case metadata lists only US 7,027,465 and RE44,904 as patents-in-suit, and I treat that as authoritative. However, the complaint's exhibit list and secondary reporting indicate CommWorks asserted a broader multi-patent portfolio (six to seven CommWorks patents covering Wi-Fi Multimedia QoS, Wi-Fi Protected Setup/WPS, IEEE 802.3ah Ethernet in the First Mile, and ITU-T G.984/G.9807.1 GPON). PatSnap's summary identifies six: US 7,027,465, RE44,904, 7,177,285, 6,832,249, 7,911,979, 7,463,596. The docket exhibit list suggests a seventh. I could not reconcile these from a primary source (the complaint PDF is not on the free RECAP docket), so treat the count as approximate.

Asserted claims, per complaint analysis (Ex Parte complaint analysis):

• '465 / RE'904 family (priority-frame detection): asserted at least claim 1 of '465 (and the corresponding reissue claim of RE'904 available only during the original patent's term), against NXP chips with WMM and/or 802.11-2007+ wireless QoS functionality. The method claim requires "extracting a bit pattern from a predetermined position in a frame," "comparing [it] with a search pattern," and identifying a priority frame, with the position defined by a bit-pattern offset.
• '285 and '596 (time-based wireless access provisioning): asserted against NXP WPS-compatible devices.
• '249 (multi-layer QoS provisioning): asserted at least claims 11 and 38 against chips supporting IEEE 802.3ah and ITU-T G.984/G.9807.1.

The complaint recited § 101-eligibility boilerplate ("not directed to an abstract idea") for each patent — likely anticipating an Alice motion.

2025-09-03/04 — Service. Summons issued 2025-09-03 (Dkt. 6); NXP USA served 2025-09-04 (Dkt. 7), making the original answer deadline 2025-09-25.

2025-09-05 — Order and Advisory (Dkt. 8). Case referred by Judge Counts to Magistrate Judge Derek T. Gilliland.

Answer / counterclaims: none. NXP never served an answer, counterclaim, or motion for summary judgment in this action. That fact is dispositive of the disposition mechanics below.

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2. Pre-trial motions and claim construction

None of substance. The only motions on the docket were two unopposed extensions of NXP's answer deadline:

• 2025-09-12 — First Unopposed Motion for Extension of Time (Dkt. 9). Granted 2025-09-15 (Dkt. 10); NXP's answer deadline moved to 2025-10-27.
• 2025-10-24 — Second Unopposed Motion for Extension of Time (Dkt. 11) (filed by NXP's counsel Michael Chibib, Bracewell LLP). 2025-10-27 — Order granting in part (Dkt. 12) (Judge Gilliland).

There was no motion to dismiss for patent-eligibility, motion to transfer venue, motion to stay pending IPR, or motion for summary judgment. No docket control order, no Markman briefing, and no claim construction ruling — the case terminated weeks before any scheduling order would have set a Markman date.

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3. Discovery milestones

None. No scheduling order issued, no Rule 26(f) conference or discovery was conducted, and no discovery disputes or protective-order motions appear on the docket. The case closed during the answer-extension phase. The practical significance: NXP obtained no infringement/contentions discovery, and CommWorks invested no discovery expense — a pattern consistent with an early commercial resolution rather than merits attrition.

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4. Trial events, verdict, post-trial motions

None. No trial setting, no pretrial conference, no verdict, no JMOL or new-trial motions, and no fee motion. The order closing the case stated that each party bears its own costs, expenses, and attorney fees, and denied any pending motions as moot.

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5. Final disposition

2025-10-31 — Notice of Voluntary Dismissal With Prejudice (Dkt. 13), filed by CommWorks through James F. McDonough under Fed. R. Civ. P. 41(a)(1)(A)(i).

2025-11-03 — Order closing the action (Dkt. 14), Judge Counts; and Report on Patent/Trademark to the USPTO (Dkt. 15).

The court's order (as reproduced by PatSnap from the PACER docket) reads in relevant part:

"Rule 41(a)(1)(A)(i) allows a plaintiff to voluntarily dismiss an action with a court order by filing a notice of dismissal before the opposing party serves an answer or a motion for summary judgment. Fed. R. Civ. P. 41(a)(1)(A)(i). The Defendant has not served an answer or a motion for summary judgment. Plaintiff's notice is therefore 'self-effectuating and terminates the case in and of itself; no order or other action of the district court is required.' In re Amerijet Int'l, Inc., 785 F.3d 967, 973 (5th Cir. 2015) ... Each party shall bear its own costs, expenses, and attorney fees. All pending motions, if any, are DENIED as MOOT."

Source note: the verbatim order text above is quoted from PatSnap's PACER-derived litigation report (link), which is an AI-assisted commercial summary, not a primary court document. The substance (Rule 41(a)(1)(A)(i); In re Amerijet, 785 F.3d 967, 973 (5th Cir. 2015)) is consistent with the law and with the docket, but I could not independently pull the order text from a free primary source.

Legal effect:

• Because NXP had not answered, the notice was self-effectuating — no judicial approval was required, and the case terminated on filing (2025-10-31), with the 2025-11-03 order merely closing the docket. This explains the metadata's "terminated 2025-10-31 / dismissed with prejudice."
• The with-prejudice label operates as an adjudication on the merits for res judicata purposes in the Fifth Circuit, barring CommWorks from re-asserting the same claims against NXP on the same accused products.
• Critically, there is no invalidity holding, no claim construction, no non-infringement ruling, and no license or consent judgment on the docket. Anyone else in NXP's technology space faces the same assertion risk.
• No appeal was taken (none available from a self-effectuating Rule 41(a)(1) dismissal absent exceptional circumstances).

Strategic inference (flagged as inference, not record fact): CommWorks dismissed 13 days after obtaining a second answer extension — i.e., before NXP's answer would have surfaced invalidity contentions, § 101 defenses, and IPR-counterclaim posture. The timing is consistent with either (a) a confidential settlement/license or (b) a tactical decision not to litigate against NXP at that moment. Public records do not disclose which; no settlement agreement appears on the docket.

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6. Parallel PTAB (IPR/PGR) proceedings

None identified. I found no IPR, PGR, or reexamination proceeding at the PTAB challenging US 7,027,465 or RE44,904 tied to this litigation, and no IPR institution decision, FWD, or adverse-judgment record naming NXP as petitioner against CommWorks's patents.

• The only PTAB-adjacent hits for "7,027,465" concern an unrelated optical-modulator patent (also numbered 7,027,465) litigated in E.D. Tex. Case No. 2:19-cv-00225-JRG, where a plaintiff's IPR representations were used for prosecution-history estoppel at Markman. That is a different patent and different parties — do not conflate.
• RE44,904 appears in CommWorks's other suits (e.g., CommWorks v. RCN Telecom (S.D.N.Y. 1:20-cv-07534); the 2025 Broadcom action, C.D. Cal. 2:25-cv-02998), but I did not find any PTAB challenge to it.
• Caveat: PTAB filings can lag and are indexed inconsistently; I would verify against PATR (PTAB API) by patent number before treating "no IPR" as firm.

Effect on this litigation: none — because there was no stay motion and no IPR. The absence of any inter partes review is itself strategically notable: the patents have survived multiple CommWorks assertion campaigns since roughly 2020 without being invalidated at the Board, which may explain defendants' willingness to resolve early.

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7. Related / parallel CommWorks campaigns (context)

CommWorks was running a broad, coordinated assertion program in 2025 across multiple districts on overlapping patents — useful for assessing the NXP dismissal's significance:

The consistent pattern across CommWorks's 2025 suits — with-prejudice dismissal before answer or claim construction, each side bearing its own fees — indicates a licensing-driven campaign resolved on commercial terms rather than through merits adjudication.

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8. Gaps and sourcing caveats

• Counsel of record (from the docket and PatSnap): CommWorks — James F. McDonough and Jonathan L. Hardt, Rozier Hardt McDonough PLLC. NXP — Michael Chibib, Bracewell LLP. I have not independently confirmed the full NXP trial team beyond the attorney of record on the extension motions.
• The complaint PDF and the full Dkts. 13/14 text are not on free RECAP; my account of the dismissal order relies on PatSnap's PACER-derived reproduction and the public docket summary.
• I found no Law360, Reuters Legal, IPWatchdog, or Patently-O coverage of this specific case — unsurprising given its eight-week, pre-answer lifespan.
• The precise number of asserted patents (two per your metadata; six to seven per the complaint's exhibits and secondary sources) remains unresolved and should be verified from the Dkt. 1 exhibits if precision matters.

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One-paragraph synthesis

CommWorks v. NXP generated essentially no substantive law. Filed 2025-09-02 in W.D. Tex. before Judge Counts (referred to Magistrate Judge Gilliland), it produced only a complaint, an AO 120 notice, service, and two unopposed answer extensions. Before NXP filed any answer, counterclaim, or dispositive motion — and before any scheduling order, Markman date, or discovery — CommWorks filed a Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice on 2025-10-31, which was self-effectuating under In re Amerijet, 785 F.3d 967, 973 (5th Cir. 2015); the court closed the case 2025-11-03 with each side bearing its own costs and fees. No PTAB IPR/PGR on the asserted patents was identified. The dismissal binds CommWorks as to NXP but leaves US 7,027,465 and RE44,904 — and the rest of CommWorks's Wi-Fi/WPS/GPON portfolio — judicially untested and available against the rest of the chip and device industry.

I'll research the docket and counsel for this case.

Let me verify the docket entries and firm details directly.

Let me pull the full docket entry list and confirm all plaintiff-side appearances.

Counsel of Record — Plaintiff CommWorks Solutions, LLC

Case: CommWorks Solutions, LLC v. NXP USA, Inc., No. 7:25-cv-00395 (W.D. Tex.) (Judge David Counts; referred to Mag. J. Derek T. Gilliland)

Bottom line

Plaintiff CommWorks Solutions, LLC was represented by a single two-attorney team from Rozier Hardt McDonough PLLC — a boutique patent-litigation firm with offices in Atlanta, Austin, and Washington, D.C. There is no separate local-counsel firm on the plaintiff side; the firm's Texas-barred partner, Jonathan L. Hardt, filled that function. No in-house counsel appeared on the docket. The case was dismissed with prejudice before NXP served an answer (Doc. 13, Notice of Voluntary Dismissal, filed Oct. 31, 2025), so the plaintiff-side appearance record is thin — two names.

Plaintiff-side counsel

Firm reference: Rozier Hardt McDonough attorney roster — https://rhmtrial.com/attorneys/ (confirms McDonough and Hardt as firm attorneys).

Sourcing and confidence

• McDonough and Hardt as the plaintiff-side team is well supported. The Justia docket for 7:25-cv-00395 shows Doc. 5, "NOTICE of Attorney Appearance by Jonathan L. Hardt on behalf of CommWorks Solutions, LLC," entered Sept. 2, 2025, and Doc. 13, "NOTICE of Voluntary Dismissal by CommWorks Solutions, LLC (McDonough, James)," filed Oct. 31, 2025 — https://dockets.justia.com/docket/texas/txwdce/7:2025cv00395/1172862361. PatSnap's litigation summary for the same case lists plaintiff counsel as James F. McDonough and Jonathan L. Hardt of Rozier Hardt McDonough PLLC (defendant side: Michael Chibib, Bracewell LLP) — https://www.patsnap.com/fr/resources/blog/litigation/commworks-solutions-v-nxp-usa-wi-fi-networking-patent-dispute-patsnap/.
• Signature-block format. The identical team appears on the near-identical CommWorks complaints filed in 2025 (e.g., the Marvell complaint at 7:25-cv-00354 and the March 4, 2025 CommWorks complaint), signed "/s/ James F. McDonough, III (GA 117088)" for the Atlanta office and "Jonathan L. Hardt (TX 24039906)" for the Austin office, both marked "* Admitted to the Western District of Texas" — see CourtListener RECAP https://storage.courtlistener.com/recap/gov.uscourts.txwd.1172860958/gov.uscourts.txwd.1172860958.1.0.pdf. The same two attorneys were admitted pro hac vice as back-up counsel for CommWorks as Patent Owner in a PTAB proceeding by conditional order in August 2025 — https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1555989](/patent/1555989)/download-documents.
• PTAB/parallel-proceeding context. CommWorks is the patent owner in ongoing IPRs (e.g., Unified Patents, LLC v. CommWorks Solutions, LLC, IPR2021-01297), where its POA/appearances have been handled by Meunier Carlin & Curfman (Atlanta) rather than Rozier Hardt — worth noting so the two are not conflated.

Gaps and caveats

• I could not verify the docket directly against PACER (paywalled); the docket reflects retrieval only through Nov. 3, 2025, two days after dismissal. Any plaintiff-side appearance filed between Nov. 3, 2025 and termination would not be captured. I found no indication of additional plaintiff counsel.
• No sealed-filing issue identified for the counsel question — the complaint and docket entries appear public. (Note that the infringement exhibits referenced in the complaint — Exhibits A/B as described — were not filed with the public complaint per third-party complaint analyses, but that concerns exhibits, not counsel.)
• C. Matthew Rozier (founding partner, DC/Denver) is the firm's registered patent attorney and appears on other CommWorks-family pleadings, but I found no evidence he entered an appearance or signed a filing in 7:25-cv-00395. I am not listing him as counsel of record here for that reason.
• No in-house counsel for CommWorks identified. CommWorks' Rule 7.1 disclosure in a parallel 2025 case identifies its corporate parent as Brainbox Innovations, LLC; no in-house attorney appeared in this docket.
• Role labels ("lead" vs. "of counsel") are my inference from who signed the complaint and dismissal notice (McDonough) versus who filed the Texas appearance (Hardt). W.D. Tex. does not formally designate lead counsel, and the docket here contains no such designation.

(Defendant-side note, for completeness: NXP's counsel was Michael Chibib of Bracewell LLP, per PatSnap's party/counsel table; no answer was filed before dismissal.)

I'll research the docket and counsel appearances for this case.

Let me dig into the specific docket entries and the defense counsel's firm.

Let me check the actual motion filings and any appearance notices via CourtListener/PACER.

Counsel of Record — Defendant NXP USA, Inc.

Bottom line up front: Only one attorney is affirmatively identified on the public docket as filing on NXP's behalf — Michael Chibib of Bracewell LLP (Austin, Texas). NXP never answered, never filed a Rule 12 motion, and (per the docket as retrieved 2025‑11‑03) never filed a formal Notice of Attorney Appearance. Its entire appearance consists of two unopposed extension motions e‑filed under Chibib's ECF credentials. Everything beyond Chibib is drawn from NXP's other litigation/PTAB filings, where the same Bracewell team routinely appears — I flag those as inferences, not district‑court appearances.

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1. Confirmed in this case (W.D. Tex. 7:25‑cv‑00395)

Grounding:

• Dkt. 9 (Sept. 12, 2025) — Unopposed MOTION for Extension of Time to File Answer to Original Complaint by NXP USA, Inc.; Dkt. 10 (Sept. 15, 2025) granted it, answer due 10/27/2025.
• Dkt. 11 (Oct. 24, 2025) — Second MOTION for Extension of Time to File Answer, docket text shows the ECF filer as "(Chibib, Michael)"; Dkt. 12 (Oct. 27, 2025) granted‑in‑part.
• Dkt. 13 (Oct. 31, 2025) — CommWorks' Notice of Voluntary Dismissal with Prejudice; Dkt. 14 (Nov. 3, 2025) — closing order (Judge David Counts, referred to Mag. J. Derek T. Gilliland).
• Docket sheet: https://dockets.justia.com/docket/texas/txwdce/7:2025cv00395/1172862361 (last retrieved Nov. 3, 2025). Third‑party litigation database PatSnap likewise lists "Defendant counsel — Michael Chibib; Defendant law firm — Bracewell LLP."

2. Bracewell team members likely on the engagement but without a confirmed appearance here

These names recur as NXP's Bracewell team in parallel PTAB matters. They do not appear in the 7:25‑cv‑00395 docket text I retrieved — treat as inference.

Sources: NXP USA, Inc. v. ParkerVision, Inc., IPR2024‑01066 & IPR2024‑01068, Petitioner's Updated Mandatory Notices (Paper 9, Nov. 1, 2024) and updated power of attorney; NXP v. Bell Semiconductor, IPR2021‑00966/‑00967 deposition transcript (Chibib and Patrick Connolly of Bracewell for NXP); Texas Instruments Inc. and NXP USA, Inc. v. ParkerVision, IPR2024‑00935/‑00936 filings (Mar. 14, 2025) listing Chibib and Mierzejewski for NXP.

3. Local counsel

No separate local counsel is identified. Bracewell is a Texas firm with a standing Austin office, and Chibib is the Austin‑based partner handling the matter, which is consistent with Bracewell serving as both outside and Texas‑based counsel. Do not infer a separate local‑counsel firm; none appears on the public docket.

4. Caveats and things I could not source

• No Notice of Attorney Appearance by NXP appears on the docket listing I retrieved. The docket for this case runs only to 15 entries (Sept. 2 – Nov. 3, 2025), and the sole defendant‑side filings are Dkts. 9 and 11. If a Bracewell appearance notice was filed but not captured in the Justia/aggregator docket text (the site warns "a more recent docket listing may be available from PACER"), pulling the PACER docket directly would confirm. I am not inventing an appearance entry.
• Because the case was dismissed under Rule 41(a)(1)(A)(i) before any answer, there is no answer, no counterclaim, and no substantive ruling that would name additional counsel. The court's order—quoting In re Amerijet Int'l, Inc., 785 F.3d 967, 973 (5th Cir. 2015)—confirms NXP "has not served an answer or a motion for summary judgment," and each party bears its own fees and costs. Document 14, Dkt. 14 (Nov. 3, 2025).
• Nothing here was sealed as to counsel identity; the docket entries are public. But there is simply very little of it.
• Patent count discrepancy to note for the file: case metadata lists US 7,027,465 and RE44,904; the complaint and third‑party analyses indicate CommWorks asserted a broader set (reported as six patents, including the '285, '596, '249, and '979 families). The complaint is available at https://storage.courtlistener.com/recap/gov.uscourts.txwd.1172860958/gov.uscourts.txwd.1172860958.1.0.pdf. This does not affect the counsel identification.
• Verification path if you need a certified list: PACER docket for 7:25‑cv‑00395 (W.D. Tex.), Dkt. 9 and Dkt. 11 signature blocks, plus the ECF "attorney filer" field for Dkt. 11.

Bottom line: For a counsel‑of‑record statement, name Michael Chibib (Bracewell LLP, Austin) as the attorney who appeared for NXP USA, Inc., with Bracewell LLP (Austin) as counsel of record, and note that no additional appearances, local counsel, or in‑house counsel were docketed before the Oct. 31, 2025 voluntary dismissal with prejudice.