Flexiworld Technologies, Inc. v. HP, Inc.

Parties. Flexiworld Technologies, Inc. is a patent monetization/licensing entity — the Stanford NPE Litigation Database classifies it in the "Failed startup" category — built around the inventions of founder William Ho Chang (and co-inventor Christina Ying Liu), who hold 150+ U.S. patents in wireless communications and digital-output technology (The Recycler, Sept. 2024; npe.law.stanford.edu). Flexiworld does not sell products; it licenses and litigates a portfolio of wireless printing, streaming, and device-discovery patents against essentially every major printer and TV OEM. HP, Inc. is the Palo Alto-based PC and printer giant (the post-2015 split-off that retained printing and personal systems) and the world's largest printer vendor, selling the DesignJet, DeskJet, Envy, LaserJet, LaserJet Tank, OfficeJet, and Smart Tank printer lines plus Chromebook, Essential, Pavilion, Envy, Spectre, Victus, and Omen laptops (Bloomberg Law, July 22, 2024).

Accused technology and patents. The July 19, 2024 complaint (Bloomberg Law) accuses HP's Wi-Fi/Bluetooth-enabled laptops and wireless printers of infringing Flexiworld's wireless printing and over-the-air digital-content output patents; press reports say the original complaint asserted eight U.S. patents, with willfulness allegations based on notice dating to at least July 2021 (The Recycler). The operative case, per the case metadata, centers on U.S. Patent No. 9,836,257 — "Mobile information apparatus that includes intelligent wireless display, wireless direct display, or transfer of digital content for playing over air the digital content at smart televisions, television controllers, or audio output devices" (priority to January 2001; granted Dec. 5, 2017). In plain terms, the '257 patent claims a mobile device (smartphone/laptop/tablet) that wirelessly discovers a nearby output device and streams or transfers digital content over the air to smart TVs, TV controllers, or audio systems (Unified Patents patent portal; Google Patents). The amended complaint (docket 27, filed Oct. 28, 2024) appears to have narrowed the case; I could not verify the full eight-patent list from PACER-grade sources.

Procedural posture, venue, and significance. The case is pending in the Houston Division of the Southern District of Texas before Judge Charles Eskridge (initial pretrial conference set for Dec. 4, 2024; Patexia docket entries 21–27). HP answered with a jury demand and counterclaim and simultaneously moved to dismiss for failure to state a claim on Oct. 7, 2024 (docs. 22–23); Flexiworld answered the counterclaim (doc. 26) and filed an amended complaint (doc. 27). Secondary reporting (Action Intell) says HP's motion to dismiss was later denied, Flexiworld filed a second amended complaint, claim construction went HP's way, and the parties filed voluntary dismissal papers on May 27 (2025) — but the case metadata still lists the case as active/pending, so I flag that outcome as reported but not PACER-verified in my sources. Venue is significant because Flexiworld is not a Texas company: HP's substantial Houston-area footprint (the legacy Compaq campus in Spring, Texas, within the district) supplies the "regular and established place of business" required by 28 U.S.C. § 1400(b), and S.D. Tex. has become a favored patent venue. The case is notable as part of Flexiworld's serial NPE campaign against every major printer OEM (Canon, Epson, Brother, Xerox, Sony, and now HP), and for its PTAB linkage: the '257 patent was challenged in Roku's IPR2022-01267 (petition filed July 29, 2022), and Flexiworld won at least one PTAB Final Written Decision in November 2023 in Unified Patents' IPR2022-00775 (though I could not confirm from my sources that the latter IPR targeted the '257 patent specifically). A negotiated exit here would fit Flexiworld's pattern of with-prejudice settlements (e.g., its Xerox dismissals) that leave the underlying wireless-output portfolio enforceable against remaining OEMs.

I'll research this case thoroughly, starting with the docket and key filings.

I found useful leads. Let me dig deeper into the detailed case tracker and docket.

Let me access the detailed articles from Action Intelligence, which tracks this case closely.

Based on my research (which hit the search step limit, so I'll flag sourcing gaps explicitly), here is the chronological development of Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex., Judge Charles Eskridge).

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Case posture & disposition in brief

The case was resolved by settlement and voluntary dismissal of all claims and counterclaims. The most recent tracked development is a May 27 (year likely 2026) stipulation/voluntary dismissal of the entire case. No trial, verdict, or Federal Circuit appeal occurred. The "Active/pending" status in the case metadata appears stale relative to the settlement reports.

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Chronological developments

1. Filing & initial pleadings

• 2024-07-19 — Flexiworld filed its Complaint (Dkt. 1) in the Southern District of Texas, accusing HP's wireless printers (DesignJet, DeskJet, Envy, LaserJet, LaserJet Tank, OfficeJet, Smart Tank) and laptops (Chromebook, Essential, Pavilion, Envy, Spectre, Victus, Omen) of infringement. Bloomberg Law reported the filing on 2024-07-22, noting Flexiworld alleged knowledge of the patents since at least July 2021 and willful infringement. (Sources: Patexia docket; Bloomberg Law "HP Sued for Allegedly Infringing Multiple Patents for Printers," 2024-07-22; The Recycler.)
  • Note on patents: The original complaint per press coverage asserted eight patents; the case metadata identifies only U.S. Patent No. 9,836,257 ("Mobile information apparatus that includes intelligent wireless display…"). The '257 patent is also asserted by Flexiworld in Flexiworld v. Sony (2:23-cv-00616, E.D. Tex.) and a Hisense case (N.D. Ga.), per Stanford NPE Litigation Database. It appears the case was narrowed to the '257 patent via amendment, but I could not confirm the exact narrowing document.
• 2024-08-14 / 08-21 — HP appearances by Erik Janitens (Dkt. 13) and Stephanie DeBrow (Dkt. 15).
• 2024-08-26 / 09-06 — Two unopposed extension orders; HP's answer deadline moved to 2024-10-07 (Dkts. 16, 20).
• 2024-09-11 — Initial pretrial/scheduling conference order (Dkt. 21); conference set for 2024-12-04 before Judge Eskridge.
• 2024-10-07 — HP filed (i) Motion to Dismiss for Failure to State a Claim (Dkt. 22) and (ii) Answer with Jury Demand and Counterclaim against Flexiworld (Dkt. 23), plus a corporate disclosure statement (Dkt. 24). The counterclaim is described in later coverage as tied to HP's motion practice but its specific allegations (e.g., non-infringement/declaratory judgment or inequitable conduct) were not confirmed in my search.
• 2024-10-18 — Flexiworld answered HP's counterclaim with a jury demand (Dkt. 26) and designated Timothy Grochocinski as attorney in charge (Dkt. 25).
• 2024-10-28 — Flexiworld filed an Amended Complaint (Dkt. 27). Per Action Intelligence's headline "Flexiworld Amends Complaint against HP, HP Again Moves to Dismiss," HP responded with another motion to dismiss targeting the amended pleading.

2. Pre-trial motions of substance

• Motions to dismiss (two rounds): HP's first Rule 12(b)(6) motion (2024-10-07, Dkt. 22) was superseded by Flexiworld's amendment. HP filed a second motion to dismiss after the amended complaint. Per Action Intelligence ("With HP's Motion to Dismiss Denied, Flexiworld Files Second Amended Complaint against HP"), the court denied HP's dismissal motion (at least in substantial part), and Flexiworld then filed a Second Amended Complaint.
• No transfer motion, no stay-pending-IPR motion, and no summary-judgment motion were identified in my searches. I cannot rule them out from the docket (I could not pull the full docket sheet), but none appeared in the tracked coverage.
• Claim construction (Markman): The case reached claim construction. Per Action Intelligence's headline "Claim Construction Goes HP's Way in Fight with Flexiworld," the Markman ruling largely favored HP's proposed constructions. I could not retrieve the order itself (no PACER citation), so the specific terms and order date are unconfirmed.

3. Discovery milestones

• The only confirmed scheduling milestone is the initial pretrial/scheduling conference ordered for 2024-12-04 (Dkt. 21). Action Intelligence's headline "Flexiworld and HP Continue to Fight over Flexiworld's Patent-Infringement Claims" suggests active discovery-era motion practice, but no specific discovery orders (claim charts, infringement/invalidity contentions disputes, privilege fights, etc.) were confirmed in my search.

4. Trial, verdict, post-trial motions

• None. No trial date was reached; no verdict, JMOL, new-trial motion, or fee motion was identified. The case settled before trial.

5. Settlement, dismissal, final disposition

• Settlement: Action Intelligence reported "HP and Flexiworld to Settle Patent Dispute," indicating the parties reached a settlement in principle (terms confidential, not disclosed in my sources).
• 2026-05-27 (year inferred; not confirmed) — "Dismissal Papers Filed in Flexiworld's Patent-Infringement Complaint against HP": Flexiworld and HP voluntarily dismissed all claims and counterclaims against each other — consistent with a Rule 41 stipulation of dismissal (likely with prejudice per the settlement). This is the final disposition of the case.
  • Sourcing caveat: The Action Intelligence snippet states "On May 27… voluntarily dismissed all claims and counterclaims," but I could not confirm the year (2026 is inferred from the article being the newest item and today's date). I also could not confirm the dismissal docket number or whether it was with or without prejudice.

6. Parallel PTAB IPR/PGR proceedings

• IPR2022-00775 — Unified Patents, LLC v. Flexiworld Technologies, Inc. (the only Flexiworld IPR surfaced): The Board issued a Final Written Decision on 2023-11-01 determining no challenged claim unpatentable and dismissing Flexiworld's revised motion to amend — a Flexiworld win. This IPR predates the HP case and was brought by Unified Patents, not HP; I could not confirm from my snippets whether it involved the '257 patent (the IPR search hit appeared in a '257-related query, suggesting a possible link, but this is unconfirmed).
• No HP-initiated IPR/PGR on the '257 patent was identified. If HP had petitioned, the case coverage (which tracked the litigation closely) would likely have flagged a stay request; none appeared.
• Parallel district-court litigation on the '257 patent: Flexiworld v. Sony (2:23-cv-00616, E.D. Tex., filed 2023-12-19) and the Hisense action (1:22-cv-04338, N.D. Ga.) involve the same patent, per the Stanford NPE Litigation Database, but I found no evidence those cases affected the HP action.

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Key sourcing caveats

• Well-sourced: Filing date, docket numbers 1–27, HP's answer/counterclaim/motion to dismiss (2024-10-07), Flexiworld's amended complaint (2024-10-28), Judge Eskridge assignment, and the initial-complaint allegations (Bloomberg Law, Patexia, The Recycler).
• Sourced but incomplete (headline-level only): The denial of HP's dismissal motion, the second amended complaint, the HP-favorable Markman ruling, the settlement, and the May 27 dismissal — all from Action Intelligence's case tag page, which I could not open in full due to the search limit. Dates for these events are not confirmed.
• Unconfirmed: The exact patent scope (8 patents in the original complaint vs. the '257-only metadata), the substance of HP's counterclaim, the IPR2022-00775 patent number, and whether the final dismissal was with prejudice.

I'll research the counsel of record for Flexiworld Technologies, Inc. in this case. Let me search multiple sources.

I found key docket entries. Let me now research the individual attorneys and their firms.

I've identified the two out-of-state attorneys. Now let me identify the local counsel — Edward Nelson (filed the return of service) — and confirm the full plaintiff counsel list.

Based on the available docket and public records, here is the plaintiff's counsel of record in Flexiworld Technologies, Inc. v. HP, Inc., No. 4:24-cv-02691 (S.D. Tex., Judge Charles Eskridge). All three are from the patent boutique Nelson Bumgardner Conroy P.C. (formerly Nelson Bumgardner Albritton P.C.), which has served as Flexiworld's counsel across its nationwide enforcement campaign.

Plaintiff's counsel of record

1. Timothy E. Grochocinski — Lead counsel / Attorney in Charge (pro hac vice)

• Firm/office: Nelson Bumgardner Conroy P.C., 15020 S. Ravinia Ave., Suite 29, Orland Park, IL 60462 (email: tim@nelbum.com).
• Docket support: Filed the complaint (docket 1, July 19, 2024); moved for pro hac vice admission (docket 5), granted by Judge Eskridge (docket 18, Aug. 28, 2024); designated "Attorney in Charge" for Flexiworld in this case (docket 25, Oct. 18, 2024); filed Flexiworld's answer to HP's counterclaim (docket 26).
• Experience: Flexiworld's lead district-court counsel in its serial wireless-printing/streaming patent campaign — including suits against Sony (E.D. Tex. 2:23-cv-00616), Lexmark (E.D. Ky. 5:22-cv-00097/98), Roku (W.D. Tex.), Amazon (W.D. Tex. 6:20-cv-00553), Epson (C.D. Cal. 8:21-cv-00807), Xerox (W.D.N.Y. 6:23-cv-06372), Kyocera (N.D. Tex. 3:26-cv-02381), and most recently LG and TCL (E.D. Tex.) (PacerMonitor, UniCourt, Justia dockets).

2. Charles Austin Ginnings ("C. Austin Ginnings") — Pro hac vice counsel (lead/back-up)

• Firm/office: Nelson Bumgardner Conroy P.C., Orland Park, IL (also listed at 745 McClintock Drive, Suite 340, Burr Ridge, IL 60527); USPTO Reg. No. 62,706 (austin@nelbum.com).
• Docket support: Moved for pro hac vice admission (docket 9, July 24, 2024), granted (docket 19, Aug. 28, 2024).
• Experience: Flexiworld's lead PTAB counsel. Notably, he was substituted as lead counsel for Flexiworld in IPR2022-00775 (Unified Patents v. Flexiworld) — the IPR challenging U.S. Patent No. 9,836,257, the very '257 patent in suit — and he was also lead counsel in Lexmark's IPR2023-00845/00846 against Flexiworld patents (PTAB mandatory-notice filings, May 2022–May 2023). He has also appeared pro hac vice for Flexiworld in the Xerox, Amazon, Lexmark, LG, and TCL cases (Justia, PacerMonitor, UniCourt).

3. Edward R. Nelson III — Texas-based partner / local (ECF-registered) counsel

• Firm/office: Nelson Bumgardner Conroy P.C., 3131 West 7th Street, Suite 300, Fort Worth, TX 76107 (ed@nelbum.com / ed@nbafirm.com).
• Docket support: Appears as the ECF filer of the summons return of service on HP (docket 12, Aug. 5, 2024) — the only Texas-admitted attorney visible on the plaintiff side of the docket in my sources.
• Experience: Name partner of the firm and its Texas anchor; served as Flexiworld's Texas counsel in the W.D. Tex. Amazon case (6:20-cv-00553) and filed the firm-name-change notice in the C.D. Cal. Epson case (8:21-cv-00807) (DocketAlarm, Unified Patents portal). Note: his Fort Worth office sits in the Northern District of Texas, but he is S.D. Tex.-admitted and functions as the local/ECF counsel here.

Caveats

• No in-house counsel of record appears on the docket. Flexiworld is a licensing NPE; founder William Ho Chang signed PTAB powers of attorney on the company's behalf, but no Flexiworld in-house attorney is listed as counsel in this case.
• I could not pull the complaint's signature block (PACER paywall), so additional associates may be of record beyond the three ECF filers identified above. Brent Bumgardner and James M. Francis appear for Flexiworld in other cases but do not appear in the docket excerpts I reviewed for this HP case, so I have not listed them as counsel here.
• The docket excerpts I reviewed run through the amended complaint (docket 27, Oct. 28, 2024). Secondary reporting (Action Intell) says voluntary dismissal papers were filed on May 27, 2025, but the case metadata still lists the case as active; if a dismissal has been entered, the counsel of record would remain as listed above for the period of the litigation.

Sources: Patexia docket for 4:24-cv-02691 (docs. 1, 5, 9, 12, 18, 19, 25–27); USPTO PTAB filings in IPR2022-00775 (targeting the '257 patent) and IPR2023-00845/00846 (Nelson Bumgardner Conroy P.C. mandatory notices identifying Ginnings, Grochocinski, and Bumgardner); DocketAlarm W.D. Tex. docket 6:20-cv-00553 (Grochocinski and Nelson, III listings); PacerMonitor/UniCourt dockets for the Sony, Lexmark, Xerox, and Kyocera cases; Justia dockets for the TCL and LG cases.

HP, Inc. — Counsel of Record

Based on the docket record and firm sources, HP is represented by Norton Rose Fulbright US LLP (Houston office). Two attorneys are confirmed of record from the docket; a third was identified in passing but could not be verified. I could not pull the full PACER docket sheet, so additional appearances (particularly after the second amended complaint and claim-construction phase) may exist that my sources did not surface.

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1. Erik Janitens — lead defense counsel (docket filings)

• Role: Appeared as HP's counsel of record via Notice of Appearance (Dkt. 13, filed 2024-08-14). He is the attorney who filed the substantive defense papers: the unopposed extension motion (Dkt. 14), the Motion to Dismiss for Failure to State a Claim (Dkt. 22), and the Answer with Jury Demand and Counterclaim (Dkt. 23) — all entered Oct. 7, 2024 — plus HP's corporate disclosure statement (Dkt. 24). On the docket, he is effectively HP's lead filing attorney.
• Firm/location: Norton Rose Fulbright US LLP, Houston, TX (1111 Bagby St., Heritage Plaza). Note: At the time of this case he was a senior associate/senior counsel at Norton Rose Fulbright (2015–2025); his current bio indicates he later moved to Nelson Mullins Riley & Scarborough LLP (Houston, same Bagby Street address), so he is no longer at NRF as of 2026.
• Experience: Registered patent attorney (B.S. electrical engineering, Michigan; J.D., Houston Law Center, 2015); handles all phases of district-court and ITC patent litigation, plus IPR practice before the PTAB. Former dry-etch process engineer at Samsung Austin Semiconductor. Notably, per Law360's attorney tracker, Janitens had previously represented HP itself in VDPP, LLC v. HP, Inc. (W.D. Tex., March 2024) — confirming an existing HP-defense relationship. Other matters include the Match Group v. Muzz and Bell Semiconductor v. Silicon Laboratories cases (W.D. Tex.).

2. Stephanie DeBrow — defense counsel (experienced senior litigator)

• Role: Appeared as HP's counsel of record via Notice of Appearance (Dkt. 15, filed 2024-08-21). No substantive motion is attributed to her by name in the docket snippets I retrieved (the Oct. 7 filings were entered under Janitens's name), but her appearance on behalf of HP and her seniority make her a likely lead/supervising co-counsel.
• Firm/location: Norton Rose Fulbright US LLP, Houston, TX.
• Experience: A heavyweight patent litigator: former clerk to Judge Timothy B. Dyk (Federal Circuit), registered patent attorney (B.S. mechanical engineering, Texas A&M; J.D. with honors, UT Austin, 2010), and admitted to the Federal Circuit and all Texas federal districts. Recognitions include Lawdragon 500 Leading Global IP Lawyers (2025), Best Lawyers in America (patent litigation/appellate), Texas Super Lawyer, and Patexia's Top 10 CAFC defense attorneys. Her bio describes defending major tech companies (mobile chip providers, telecommunications, e-commerce, movie-theater chains) in district court, ITC § 337 investigations, and Federal Circuit appeals, with experience across wireless networking and telecommunications — squarely on point for Flexiworld's wireless-printing patent.

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Sourcing caveats & gaps

• Firm identification: Confirmed via the Patexia docket page (Dkts. 13, 15, 22–24 all bear Janitens/DeBrow entry stamps) and the Ex Parte case/attorney pages, which list "Norton Rose Fulbright US LLP" for Janitens on this matter; Law360's attorney directory confirms the NRF affiliation.
• Additional HP counsel: The Ex Parte case page for 4:24-cv-02691 lists attorneys generically, but I could not open it in full before hitting the search limit. It is plausible that other NRF Houston attorneys (e.g., a partner overseeing Janitens, or additional associates) entered appearances for the claim-construction and dismissal phases, but no additional names are confirmed and I decline to speculate.
• In-house counsel: No HP in-house attorney appearance was identified in my sources. HP commonly staffs outside-counsel-led litigation with in-house IP counsel behind the scenes, but none is of record per available docket data.
• Local counsel: Both Janitens and DeBrow are Houston-based and admitted in S.D. Tex., so no separate local-counsel engagement is indicated.
• Post-settlement status: Consistent with the prior sections, the case reportedly ended via settlement and voluntary dismissal (May 2025/2026 per Action Intelligence), so these attorneys' engagements presumably terminated with the dismissal. If Janitens's mid-2025 move to Nelson Mullins occurred before the final dismissal papers, a successor NRF attorney may have signed the stipulation — that document was not retrievable in my searches.