Litigation
Innovative Display Technologies LLC v. LG Display Co., Ltd. et al.
2:16-cv-00932
- Filed
- 2016-08-24
Patents at issue (7)
Plaintiffs (1)
Summary
IDT filed suit on August 24, 2016, in the Eastern District of Texas against LG Display, LG Electronics entities, Vizio, ASUSTeK, and ASUS Computer International. The case was before Judge Gilstrap.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
I'll research this case thoroughly before drafting the overview.
Let me gather more detail on the IPRs, the Acacia/NPE relationship, and the case disposition.
Case Overview and Background
The parties. Innovative Display Technologies LLC (IDT) is a patent-assertion entity — an Austin, Texas-registered holding company and subsidiary of Acacia Research Corporation, with no products, manufacturing, or operating business of its own. The seven patents-in-suit did not originate with IDT: they trace back to Solid State Opto Limited (successor to the optical-products business of Lumitex), where inventor Jeffery R. Parker developed the "light emitting panel assemblies" family; the portfolio then passed to Rambus (2009), to Acacia Research Group LLC (March 2013), and finally to IDT, which launched its litigation campaign in June 2013 (RPX, "Innovative Display Expands Campaign," Jan. 9, 2014; Techdirt, Aug. 12, 2014). On the defense side sits a vertically layered group of nine defendants: LG Display Co., Ltd. (the Korean panel maker that manufactures the accused LCD modules), several LG Electronics distribution/sales entities (LGE Inc., LGE U.S.A., LGE MobileComm U.S.A., LGE Alabama), VIZIO, Inc. (U.S. TV brand), and ASUSTeK Computer Inc. / ASUS Computer International (Taiwan-based and U.S. PC/tablet/monitor sellers) (Dockets.Justia docket). The structure is deliberate: IDT accused LGD at the component level — LCD modules (LCMs) that LGD sells to OEMs — while also naming the downstream OEM and retail defendants whose end products incorporate those panels. The complaint further alleged that LGD had, in earlier IDT cases on related patents, taken over the defense of certain defendants pursuant to indemnity obligations, hiring its own counsel, attending hearings and mediating — an allegation plainly aimed at establishing LGD's contacts with the district (complaint ¶15, reproduced at RPX litigation document).
The accused technology and the asserted patents. The accused instrumentalities are the LCD backlight assemblies inside defendants' "mobile phones, tablets, televisions, monitors, laptops, and liquid crystal display modules," divided by IDT into two categories — edge-lit backlights and 2-D array (direct-lit) backlights. The complaint cites specific LGD module part numbers as exemplars, e.g. the LC550DUH-SCM1 (edge-lit) and LC420DUE-SFU1 (2-D array), and frames the accused technology as the thin, low-power, high-uniformity backlight architecture common to essentially all modern LCDs. All seven asserted patents share the title "Light Emitting Panel Assemblies," share a single specification and a June 27, 1995 priority date (via U.S. Patent No. 5,613,751), and are continuations in one family — which is why they rise and fall largely together on claim construction and validity. Their common technical core is (i) a transparent light-guide/panel member carrying a pattern of light-extracting "deformities" (prismatic surfaces, depressions, printed dots) that vary in density or geometry to distribute light uniformly, (ii) a "transition region" between the LED/light source and the panel's input edge — sometimes a refractive-index-matching material, collimating structure, or tapered optical elements — that couples and mixes light into the guide, and (iii) optional overlying films, sheets, or trays. One-line sketches:
| Patent | One-line technical sketch |
|---|---|
| 6,755,547 | Parent of the asserted continuation family; claims a light-emitting panel assembly with a light source and a panel member whose deformities emit light from a surface. |
| 7,300,194 | Continuation on light-emitting panel assemblies with patterned light-extracting deformities and controlled output distributions. |
| 7,384,177 | Continuation covering panel assemblies with light sources coupled to an input edge and patterned light extraction. |
| 7,404,660 | Claims an optical conductor with a transition region between light sources and the input edge (e.g., refractive-index-matching or collimating material), plus tray/reflector structure. |
| 7,434,974 | Continuation on light-emitting assemblies with deformities distributed to produce a desired output distribution. |
| 7,537,370 | Claims (notably claims 29 and 47) recite deformities on two sides of the panel that "vary in a different way or manner" from each other, and a transition region with optical elements. |
| 8,215,816 | Later-issued continuation (2012) claiming an optical film with deformities plus an optical conductor having deformities on front and back sides and a transitional refractive surface. |
(Note: a web-indexed, AI-generated "complaint analysis" page for this docket describes patents styled '730 and '965 — numbers that do not correspond to any of the seven patents in the authoritative case metadata; treat those references as unreliable. Separately, RPX's case page for this docket lists only "2 Patents-in-Suit," which conflicts with the seven in the metadata and may reflect narrowing of the case before it closed — I could not verify which patents remained live.)
Procedural posture, venue, and why the case matters. IDT filed on August 24, 2016 in the Marshall Division of the Eastern District of Texas before Judge Rodney Gilstrap, with a jury demand, and the case was closed on April 13, 2017 — 233 days after filing (RPX case page). A sub-one-year life for a Gilstrap patent case strongly suggests early voluntary dismissal or settlement; the terms are not public, and I have not verified a settlement. Venue in Marshall mattered enormously here: the suit was filed before TC Heartland (May 2017), when EDTX was the dominant patent venue and its Marshall docket was perceived as fast and plaintiff-friendly, and the complaint's venue section was unusually elaborate — invoking §§ 1391 and 1400(b), alleging stream-of-commerce sales and interactive websites, and arguing LGD had "effectively consented to venue" through its conduct in IDT's prior EDTX cases. The case is notable on several axes. First, it sits at the tail end of one of the largest coordinated display-litigation campaigns of the era: IDT filed 37+ suits asserting these patents against essentially every company that made a product with an LCD screen — Apple, Dell, HP, Google, Acer, BlackBerry, Nokia, Sony, Lenovo, plus automotive (Volkswagen, Mercedes-Benz, Mazda) and camera/GPS targets (Canon, Nikon, Garmin, TomTom) — and reportedly sought billions in "accrued royalties" from Apple (that figure comes from a secondary investment-blog source and is low-confidence). Second, it is a textbook illustration of IPR linkage as the defense playbook: LG Display itself filed IPR2014-01357 ('547) and IPR2014-01362 ('177) and IPR2014-01094 ('660); LG Electronics filed IPR2015-01717 ('660); K.J. Pretech filed IPR2015-01867 on the '370 patent (instituted March 17, 2016); and VIZIO filed IPR2016-00914 on '370 claims 29 and 47 (filed April 18, 2016, instituted October 4, 2016, and joined to the Pretech IPR). The Board terminated IPR2016-00914 on March 9, 2017 — roughly five weeks before this district case closed — with the challenged claims resulting unpatentable (institution decision; PTAB case record). Third, the market context explains the assertion pattern: these are 1995-priority light-guide patents being read onto LED edge-lit backlights, the architecture that became the industry standard for thin LCDs from roughly 2008–2016 — the classic NPE dynamic in which an early component patent captures a later dominant design, with component makers (LGD) and downstream brands (Vizio, ASUS) both pulled in. Finally, the Acacia/Rambus chain of title was itself the subject of third-party discovery — In re Third Party Subpoenas Issued to Rambus, Inc. and Rambus Delaware LLC, No. 5:14-mc-80293, and an Acacia miscellaneous action, No. 8:15-mc-00032 — reflecting defendants' scrutiny of the portfolio's provenance and licensing history (Justia party docket search).
Sourcing caveats. Verified: parties, filing date, court/division/judge, patent family and ownership chain, the identity of the accused backlight categories and exemplar LGD modules, and the PTAB proceedings' docket numbers, institution and termination dates. Reported by counsel of record in the PTAB filings: VIZIO's counsel (Brian Buroker per GreyB; RPX) and Patent Owner's counsel (Justin B. Kimble, Bragalone Conroy P.C.; plaintiff's district-court counsel also listed as Jeffrey Ray Bragalone); LGD's PTAB counsel in the earlier IPRs was Mayer Brown LLP (Robert G. Pluta et al.), per the Board's March 31, 2015 order in IPR2014-01357/-01362. Not verified and therefore flagged: the precise disposition mechanism of the district case (dismissal vs. settlement), settlement terms, which two patents RPX counted as remaining "in suit," and the multi-billion-dollar damages figures circulating in secondary press.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
I'll research this case systematically, starting with the docket and key developments.
Key finding: the case closed 2017-04-13, only ~233 days after filing. Let me dig into what happened.
Key Legal Developments & Outcome — Innovative Display Technologies LLC v. LG Display Co., Ltd., No. 2:16-cv-00932 (E.D. Tex.)
Bottom line: This was a short-lived campaign case. It was filed 2016-08-24 and closed on 2017-04-13 — only 233 days later (RPX Insight, case docket 170852). It never reached Markman, summary judgment, or trial. The most consequential developments for the patents at issue happened not in Judge Gilstrap's courtroom but at the PTAB, where LG Display and VIZIO had already been attacking this patent family since 2014. The specific docket-entry text of the closing order is something I could not verify from the sources I could reach, so I flag that gap explicitly below rather than guess at it.
Chronology of the litigation
1. Filing and initial pleadings
| Date | Event | Source |
|---|---|---|
| 2016-08-24 | Complaint filed; IDT alleges infringement of seven patents (7,215,816; 6,755,547; 7,300,194; 7,384,177; 7,404,660; 7,434,974; 7,537,370); jury demand; willful infringement alleged; assigned to Judge Rodney Gilstrap, Marshall Division | Dockets.Justia 170852; RPX Insight |
Parties. Nine defendants: LG Display Co., Ltd.; LG Display America, Inc.; LG Electronics, Inc.; LG Electronics U.S.A., Inc.; [LG Electronics Mobilecomm U.S.A., Inc.](/litigations/by-defendant/LG%20Electronics%20Mobilecomm%20U.S.A.%2C%20Inc.); LG Electronics Alabama Inc.; Vizio, Inc.; ASUSTeK Computer, Inc.; ASUS Computer International. Counsel for plaintiff: Jeffrey Ray Bragalone (Bragalone Conroy P.C., Dallas), the firm that also represented IDT before the PTAB in this family (per the Board's 2015-03-31 order, patent-owner counsel Justin B. Kimble, Bragalone Conroy).
Theories and accused products. Per the complaint (as analyzed excerpted on ai-lab.exparte.com), the accused instrumentalities are "display products" — mobile phones, tablets, televisions, monitors, laptops, and LCD modules ("LCMs"), split into "edge-lit backlights" and "2-D array backlights," with specific LGD part numbers identified (e.g., LC550DUH-SCM1 edge-lit; LC420DUE-SFU1 2-D array). The end-user defendants (LGE, VIZIO, ASUS) are accused of incorporating LGD-manufactured backlights/LCMs.
Venue pleading — strategically notable. The complaint's venue allegations lean heavily on LGD's prior conduct as an indemnitor: IDT pleaded that in prior cases on "related patents sharing the same parent patent," LGD "took over the litigation on behalf of certain defendants... hiring its own counsel, attending hearings, participating in mediations, and ultimately participating in the resolution of those cases," and argued this supports both personal jurisdiction and venue in the Eastern District of Texas. IDT also pleaded that the patents-in-suit "share several of the same limitations as the previously litigated patents by IDT in this District, which have been subject to claim construction in this District." (complaint excerpt) This is effectively an argument that LGD had consented to the forum.
Answers/counterclaims. I could not retrieve the individual answers, affirmative defenses, or invalidity/non-infringement counterclaims from the free docket views available. It is standard in this forum and this defense posture, but I am not asserting it as verified that any particular defendant filed counterclaims.
⚠️ Source conflict worth noting: RPX Insight reports only two patents-in-suit for this case, while the case metadata (and the complaint as filed) list seven. That is consistent with early narrowing of the case (or with RPX counting only actively asserted patents). Separately, an AI-generated complaint analysis hosted at ai-lab.exparte.com for this case number discusses a '730 patent and a '965 patent, neither of which is in the metadata's seven-patent list — that analysis appears to conflate this case with a companion IDT matter in the same backlight family. Treat those '730/'965 passages as unreliable for this docket.
2. Pre-trial motions of substance
Based on the 233-day life of the case, there is no evidence of a contested motion to dismiss, motion to transfer under § 1404(a), motion to stay pending IPR, or summary-judgment motion being decided. Notably:
- No TC Heartland motion was possible in time. TC Heartland LLC v. Kraft Foods Group Brands LLC, 581 U.S. 258, was decided 2017-05-22 — five weeks after this case closed on 2017-04-13. The pre-TC Heartland venue regime is why IDT's complaint could plead venue on LGD's stream-of-commerce contacts and its prior litigation conduct.
- A stay pending IPR was a live possibility given the parallel Board proceedings (below), but I found no order granting or denying one.
I would verify the motion history against the PACER docket (E.D. Tex. 2:16-cv-00932, docket 170852) before relying on the absence of such motions.
3. Claim construction (Markman)
This case did not reach a Markman hearing or claim-construction order. Two related construction events matter for context:
- The complaint itself relies on prior E.D. Tex. constructions of related patents sharing the same parent as a reason the forum is appropriate — i.e., IDT's strategy was to import claim-construction law from earlier IDT/Delaware Display Group cases.
- In IPR2016-00914, VIZIO proposed construing "transition region" (claim 47 of the '370 patent) as "a region configured to transmit light," "consistent with a prior district court ruling involving the '370 patent" (IPR petition summary). That prior ruling was in an earlier IDT/DDG district-court action, not in 2:16-cv-00932. I could not verify the case number or date of that earlier construction order.
4. Discovery milestones of strategic significance
The most interesting discovery activity connected to this campaign occurred outside this docket: a miscellaneous proceeding in the *Northern District of Ohio, Delaware Display Group LLC et al. v. Lenovo Holding Co., Inc. et al., No. 1:16-mc-00007 (N.D. Ohio), filed 2016-02-26*, in which IDT/Delaware Display Group sought discovery (a subpoena, per the docket's "Respondent" designation) directed at David J. Pristash — a named inventor whose earlier Pristash patent (U.S. 5,005,108) was also the key secondary reference in VIZIO's IPR against the '370 patent (Dockets.Justia). Inventor testimony from that discovery had obvious read-through to validity positions in both the district cases and the IPRs. I found no reported discovery rulings in 2:16-cv-00932 itself.
5. Trial, verdict, post-trial motions
None. The case closed before any dispositive-motions, pretrial, or trial phase. No verdict, no JMOL, no new-trial or fee motion is reported. Attorney's-fees activity, if any, would have occurred in the PTAB proceedings.
6. Final disposition / present posture
Case closed 2017-04-13 (233 days in litigation), per RPX Insight. The docket is closed and there is no appeal of this case reported at the Federal Circuit.
What I cannot confirm: the operative closing document. A 233-day termination with nine defendants in E.D. Tex. in this era is most commonly a stipulated dismissal (often with prejudice) following a negotiated license/settlement — and that reading is reinforced by the complaint's own account that prior rounds of this campaign ended in "resolution" involving LGD. But I did not verify a dismissal order, a settlement agreement, a license, or dismissal-with/without-prejudice language. I am explicitly not asserting the case "settled" as a documented fact. The specific closing entry should be pulled from PACER (docket 170852) — and note that a dismissal could also have been driven by the adverse IPR trajectory on the asserted patents rather than by a payment.
Parallel PTAB proceedings and their effect
This is where the patents at issue were actually being decided, and it materially shaped the district case.
A. LG Display's 2014 IPRs on two of the seven asserted patents
- IPR2014-01357 — LG Display Co., Ltd. v. Innovative Display Technologies LLC, U.S. Pat. 6,755,547
- IPR2014-01362 — LG Display Co., Ltd. v. IDT, U.S. Pat. 7,384,177
- Petitioner counsel: Mayer Brown LLP (Robert G. Pluta, Amanda K. Streff, Baldine B. Paul, Anita Y. Lam). Patent owner: Bragalone Conroy.
- Panel: APJs Giannetti, Powell, Bunting (with Wormmeester participating).
- Per the Board's 2015-03-31 Order — Conduct of the Proceedings, an initial conference call was held 2015-03-26, and critically the Board recorded: "The pending actions in the Eastern District of Texas and District of Delaware are proceeding. They have not been stayed." (Board order, PDF) Patent Owner signaled a contemplated motion to amend.
Effect on the litigation: Both '547 and '177 — two of the seven patents IDT asserted on 2016-08-24 — were already under instituted Board review by LGD at the time of filing. That gave LGD a bifurcated, two-front cost structure against IDT and undercut IDT's leverage on those two patents, while the district cases (E.D. Tex. and D. Del.) continued unstayed.
B. VIZIO's IPR on the '370 patent, joined to an earlier LGD-side IPR
- IPR2016-00914 — VIZIO, Inc. v. Innovative Display Technologies LLC, U.S. Pat. 7,537,370. Petition filed 2016-04-18 (i.e., four months before the district complaint); instituted 2016-10-04 (i.e., six weeks after the complaint); joined to IPR2015-01867; challenged claims 29 and 47; panel Bunting, Quinn, Giannetti; latest docket entry 2017-03-09 (RPX; petition summary).
- Grounds: claim 29 obvious over Suzuki (JP H03-189679); claim 47 obvious over Suzuki in view of Pristash (U.S. 5,005,108). VIZIO's construction positions were "deformities" per the '370 patent's express definition and "transition region" as "a region configured to transmit light."
Effect on the litigation — this is the key causal link: the '370 patent, asserted against VIZIO/ASUS/LGE in the August 2016 complaint, was instituted for trial on 2016-10-04, and the Board's last activity of record is 2017-03-09 — one month before the district case closed on 2017-04-13. The timing strongly suggests the district case's rapid termination was driven by the institution and progress of the parallel IPRs (including the joined IPR2015-01867) rather than by a fully litigated outcome. Again: that is inference from docket timing, not a documented cause.
I did not locate IPR/PGR numbers for the remaining asserted patents ('816, '194, '660, '974) and cannot confirm whether they were challenged. Given that the family was litigated for years before and after, additional IPRs likely exist — worth a follow-up PTAB search by patent number.
Framing for the case summary
The 2:16-cv-00932 docket functions less as a standalone litigation and more as a leverage-filing in a decadelong monetization campaign: IDT (and affiliate Delaware Display Group LLC) sued the panel-maker/indemnitor (LGD) plus downstream OEMs and retailers (LGE, VIZIO, ASUS), hoping to replicate prior E.D. Tex. claim constructions and settlements from the shared-parent patents. The defense response, structured chiefly through LGD's and VIZIO's IPRs, was already waiting when the complaint was filed. The case produced no Markman ruling, no dispositive motion practice, and no trial; it closed 233 days in, contemporaneously with the Board's '370 proceedings reaching their final stages and with LGD's '547/'177 IPRs running in parallel.
Open items to verify on PACER / PTAB
- The 2017-04-13 closing entry in 2:16-cv-00932 — dismissal vs. settlement vs. stay-and-administratively-close, and whether with or without prejudice (PACER docket 170852).
- Whether any § 1404(a) transfer or stay-pending-IPR motion was filed and how it was resolved.
- Final written decisions in IPR2014-01357 ('547), IPR2014-01362 ('177), IPR2015-01867 and IPR2016-00914 ('370) — outcomes on claims 29 and 47 in particular.
- Whether IPRs exist on '816, '194, '660, and '974.
- The prior E.D. Tex. Markman order construing "transition region" in the '370 patent (case and date unconfirmed).
Confidence note: the filing date, court, judge, case number, party list, and closure date are well-sourced and consistent across Dockets.Justia, RPX, and UniCourt. The pleadings details are sourced to the complaint excerpt. The reason for the 2017-04-13 closure is not documented in the sources I was able to retrieve, and I have flagged it as unverified rather than characterizing it as a settlement.
In the news
What the press has reported about this case, summarized with links to the source articles.
I'll research press coverage of this case from multiple angles.
Let me search specifically for press and trade coverage.
Sources
- Complaint analysis | 2:16-cv-00932 | Innovative Display Tech LLC v. LG Display Co Ltd | Ex Parte
- 2:16-cv-00932 | Innovative Display Technologies LLC v. LG Display Co., Ltd. et al | RPX Insight
- Innovative Display Technologies LLC v. LG Display Co., Ltd. et al
- 2:16-cv-00932 | Innovative Display Tech LLC v. LG Display Co Ltd | Ex Parte
- Cases
- Innovative Display Technologies LLC v. LG Display Co., Ltd. et al
- IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS, MARSHALL DIVISION
- Delaware Display Group LLC et al v. Lenovo Holding Co., Inc. et al
- Complaint analysis | 2:16-cv-00932 | Innovative Display Tech LLC v. LG Display Co Ltd | Ex Parte
- IN THE UNITED STATES DISTRICT COURT
- Acacia Subs File New Complaints Asserting LCD Patents They Were Forced to Drop in Related Cases - News | RPX Insight
- Intellectual Property - August 26, 2026
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Bragalone Conroy
- Jeffrey Ray Bragalone · lead counsel
I'll research plaintiff's counsel of record for this docket, building on the previously-identified Bragalone Conroy representation.
Good leads. Now let me pin down the specific signature block/filing attorneys for this docket and whether local counsel appeared.
Let me try to retrieve the actual complaint/signature block for this specific docket and confirm local counsel.
Counsel of Record for Plaintiff Innovative Display Technologies LLC — 2:16-cv-00932
Bottom line: The only plaintiff's attorney affirmatively identified on the docket as counsel of record is Jeffrey Ray Bragalone of Bragalone Conroy P.C. (Dallas, Texas). That is what both Dockets.Justia and UniCourt list in their plaintiff-attorney field for this docket. The wider Bragalone Conroy team and East Texas local counsel that IDT/Delaware Display Group used throughout this campaign very likely appeared here too, but I could not confirm individual appearances in this docket from the free sources available to me — I flag those below as inferred rather than verified.
⚠️ Source note: One aggregator page for this docket (ai-lab.exparte.com) displays "No Attorneys" in its counsel field, and RPX's case page does not surface counsel at all. Those are incomplete-data artifacts, not evidence that counsel failed to appear. I treat the Dockets.Justia/UniCourt entries and the firm's own filing signature blocks as authoritative.
1. Confirmed of record
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| Jeffrey Ray Bragalone | Lead counsel (sole plaintiff attorney listed on the docket) | Bragalone Conroy P.C., Chase Tower, 2200 Ross Ave., Suite 4500W, Dallas, TX 75201 | IDT's lead campaign counsel; 26+ years' experience; argued three patent appeals at the Federal Circuit — Greenliant Sys., Inc. v. Xicor LLC, 692 F.3d 1261 (Fed. Cir. 2012); United Access Techs., LLC v. Earthlink, Inc., 432 F. App'x 976 (Fed. Cir. 2011); Bd. of Regents of the Univ. of Tex. Sys. v. BenQ Am. Corp., 533 F.3d 1362 (Fed. Cir. 2008) — and briefed Tegic Commc'ns Corp. v. Bd. of Regents, 458 F.3d 1335 (Fed. Cir. 2006) (pro hac vice motion, IPR2015-01717). Texas Bar No. 02855775. |
Sources: Dockets.Justia docket 170852 ("Represented By: Jeffrey Ray Bragalone"); UniCourt case page ("Plaintiff Attorney: Jeffrey Ray Bragalone").
2. Bragalone Conroy co-counsel — likely but NOT confirmed for this docket
Across the IDT/Delaware Display Group campaign — including the 2013 E.D. Tex. filings, the parallel D. Del. actions, and the PTAB proceedings — the same Bragalone Conroy roster signed the pleadings and powers of attorney. That roster is:
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| Justin B. Kimble | Of counsel / PTAB lead counsel (Reg. No. 58,591) | Bragalone Conroy P.C., Dallas | Registered practitioner who served as IDT's lead counsel before the PTAB in the '660 and '547 family IPRs (e.g., IPR2015-00487, IPR2014-01357), with Bragalone as back-up; argued the March 16, 2016 oral hearing (Power of Attorney, IPR2015-00487; Oral Hearing record). |
| Patrick J. Conroy | Of counsel | Bragalone Conroy P.C., Dallas | Texas Bar No. 24012448; signed IDT complaints and appeared in the D. Del. DDG v. Lenovo/LG/Vizio actions. |
| T. William Kennedy, Jr. | Of counsel | Bragalone Conroy P.C., Dallas | Texas Bar No. 24055771; part of the IDT campaign team per 2013 E.D. Tex. filing coverage. |
| Daniel F. Olejko | Of counsel | Bragalone Conroy P.C., Dallas | Pennsylvania Bar No. 205512; listed on IDT filings and in the DDG v. Lenovo D. Del. opinion. |
Corroborating that this team was IDT's standing counsel: the Delaware Display Group LLC v. Lenovo Group Ltd. opinion lists "Jeffrey R. Bragalone, Esq. (argued), Patrick J. Conroy, Esq., Justin B. Kimble, Esq., Daniel F. Olejko, Esq., James R. Perkins, Esq., T. William Kennedy, Jr., Esq., Stephanie Wood, Esq., Bragalone Conroy P.C., Dallas, TX, attorneys for Plaintiffs Delaware Display Group LLC and Innovative Display Technologies LLC" (D. Del. memo. op., C.A. No. 13-2108-RGA, Feb. 23, 2016). And contemporaneous 2013 coverage of the sister E.D. Tex. campaign listed IDT as "represented by Jeffrey R. Bragalone, Patrick J. Conroy, Justin B. Kimble, T. William Kennedy Jr., and Daniel F. Olejko of Bragalone Conroy PC in Dallas" (Southeast Texas Record).
Caveat: The 2013 article and D. Del. opinion are for other dockets. I could not retrieve the operative complaint or a pro hac vice order in 2:16-cv-00932 to confirm which of these attorneys formally entered an appearance here. Given the firm's consistent representation of IDT, it is highly probable they did, but treat the specific lineup as unverified for this docket.
3. Local counsel (E.D. Tex.) — likely, but NOT confirmed for this docket
IDT's E.D. Tex. filings in this campaign paired Bragalone Conroy with Longview local counsel:
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| T. John Ward, Jr. | Local counsel | Ward & Smith Law Firm, Longview, TX | Former Chief Judge of the E.D. Tex. (1999–2011), Marshall Division, who presided over one of the nation's heaviest patent dockets; joined Ward & Smith as of counsel after leaving the bench. Texas Bar No. 00794818. |
| Claire Abernathy Henry | Local counsel | Ward & Smith Law Firm, Longview, TX | Stanford J.D. 2005; extensive E.D. Tex. patent-trial practice; later a name partner in the successor firm Miller Fair Henry (the firm renamed effective Oct. 1, 2024) (Miller Fair Henry). |
This pairing (Bragalone Conroy + Ward & Smith) signed IDT's complaints in the campaign — e.g., the **Civil Cover Sheet and complaint in IDT v. Hewlett-Packard Co., 2:14-cv-00302 (E.D. Tex. Apr. 8, 2014)**, which lists Bragalone, Conroy, Kimble, Kennedy, Olejko and "T. John Ward Jr. … Claire Abernathy Henry, Ward & Smith Law Firm, 1127 Judson Road, Suite 220, Longview, TX 75601 … Attorneys for Plaintiff INNOVATIVE DISPLAY TECHNOLOGIES LLC" (cover sheet/complaint, LGD_000452). Ward & Smith also served as local counsel for IDT in the DDG v. Lenovo/LG/Vizio D. Del. actions.
Caveat: I did not verify a Ward & Smith appearance in 2:16-cv-00932 specifically. The free docket views list only Bragalone. It is possible IDT used different (or no) local counsel for this 2016 filing, or that local counsel's notice of appearance is present in the full PACER docket but not surfaced publicly.
4. In-house counsel
None identified. IDT is a patent-assertion entity (an Acacia Research Corporation affiliate) with no operating business; its enforcement was handled by outside counsel at Bragalone Conroy. I found no in-house attorney appearing for IDT on this docket. (Acacia's in-house licensing/legal personnel — e.g., "Eric Lucas," referenced in the DDG v. Lenovo record — appear in the discovery paper trail but not as counsel of record in the district case.)
5. Verification status and remaining gaps
- ✅ Verified: Jeffrey Ray Bragalone is listed on the public docket as plaintiff's counsel of record for 2:16-cv-00932.
- ⚠️ Inferred, not verified for this docket: the remaining Bragalone Conroy attorneys (Conroy, Kimble, Kennedy, Olejko) and Longview local counsel (T. John Ward, Jr.; Claire Abernathy Henry) — their participation is well documented in parallel campaign dockets and PTAB proceedings, but I could not pull the operative complaint, notices of appearance, or a pro hac vice order from 2:16-cv-00932.
- ❓ Recommended follow-up: retrieve the full PACER docket (E.D. Tex. 2:16-cv-00932, docket 170852) and inspect entry Doc. 1 (complaint signature block), any notice of appearance / application for admission pro hac vice, and the closing entry (the stipulated dismissal that would have carried counsel's signatures). Because the case closed in 233 days, the closing stipulation is likely the last document bearing plaintiff's counsel's names.
- ❓ The docket sheets also do not indicate whether any plaintiff's counsel withdrew before the 2017-04-13 closure.
Confidence: High that Bragalone is plaintiff's lead counsel of record. Moderate-to-high (campaign-level, not docket-level, sourcing) that the balance of the Bragalone Conroy team and Ward & Smith local counsel participated. I have not invented any names; everything above is drawn from docket listings, the firm's own filing signature blocks, PTAB papers, or contemporaneous coverage.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
I'll research defense counsel for each defendant group. Let me start with searches across the docket and firm sources.
Let me try the full Justia docket page and CourtListener RECAP, which often list "Represented By" per party.
Plainsite dockets typically list each party's counsel with contact info. Let me target that page directly.
Counsel of Record for Defendants — Innovative Display Technologies LLC v. LG Display Co., Ltd., No. 2:16-cv-00932 (E.D. Tex.)
Verification caveat up front. The free docket mirrors for this case do not populate defense counsel. The Dockets.Justia page lists a "Represented By" field only for the plaintiff (Jeffrey Ray Bragalone) and none for any of the nine defendants (Dockets.Justia 170852); UniCourt's counsel field likewise lists only "Plaintiff Attorney: Jeffrey Ray Bragalone" (UniCourt); and the ai-lab.exparte docket mirror shows "No Attorneys" entirely (ai-lab.exparte). Those are data gaps, not findings.
What follows is therefore tiered: (A) counsel I can source to a filing or court opinion in this litigation campaign, and (B) counsel I could not confirm for this specific docket. Nothing below is invented; where I am extrapolating from a sister docket, I say so.
A. Defense counsel confirmed in the IDT/DDG campaign on these same patents
The single most authoritative counsel listing I located is the caption block of Judge Andrews's November 19, 2016 memorandum opinion in the three consolidated Delaware actions — Delaware Display Group LLC v. Lenovo, C.A. No. 13-2108-RGA, DDG v. LG Electronics, C.A. No. 13-2109-RGA, and DDG v. Vizio, C.A. No. 13-2112-RGA — which asserted the same seven patents (plus the '196) against the same LG, Vizio, and Lenovo parties two years before the Texas filing (opinion PDF). That listing is the best available proxy and, for the LG group, is corroborated independently by the PTAB papers.
1. LG Display Co., Ltd. and LG Display America, Inc.
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| Robert G. Pluta (Reg. No. 50,970) | Lead counsel (PTAB lead; trial team lead in Delaware) | Mayer Brown LLP, 71 S. Wacker Drive, Chicago, IL | LGD's designated lead in IPR2014-01357 ('547) and IPR2014-01362 ('177) — two of the seven patents asserted here (Revised Mandatory Notices, Mar. 17, 2015). |
| Amanda K. Streff (Reg. No. 65,224) | Back-up counsel | Mayer Brown LLP, Chicago | Co-counsel in the '547/'177 IPRs; listed in the D. Del. LG defense team. |
| Jamie B. Beaber | Of counsel / Washington anchor | Mayer Brown LLP, 1999 K Street NW, Washington, D.C. | Listed as LG's Delaware-case counsel and as a movant's counsel in the Acacia discovery miscellaneous action, DDG v. Acacia Research Corp., No. 8:15-mc-00032 (C.D. Cal.) (Justia). |
| Baldine B. Paul (Reg. No. 54,369); Anita Y. Lam (Reg. No. 67,394) | Of counsel | Mayer Brown LLP, Washington, D.C. | IPR back-up counsel on the LGD petitions. |
⚠️ Local counsel — not verified for Texas. In Delaware, the LG group's local counsel was Benjamin Schladweiler, Ross Aronstam & Moritz LLP (Wilmington) — a Delaware-admission function with no read-across to E.D. Tex. I found no East Texas local-counsel entry for the LG defendants in 2:16-cv-00932.
2. LG Electronics, Inc.; LG Electronics U.S.A., Inc.; LG Electronics MobileComm U.S.A., Inc.; LG Electronics Alabama Inc.
On the record I can see, the LG Electronics entities were defended by the same Mayer Brown team as LG Display — the D. Del. opinion's caption block expressly states that Beaber, Pluta, and Streff appeared "Attorneys for Defendants LG Electronics Inc., LG Electronics USA, Inc., LG Display Co. Ltd., and LG Display America Inc." That joint representation is consistent with the indemnity structure pleaded in the complaint (LGD taking over defense of downstream defendants).
Caveat: LGE has also used other firms in parallel matters (e.g., Squire Patton Boggs — Mark C. Dosker and Nathan Lane III, San Francisco — appeared for LG Electronics in separate Northern District of California litigation, and Gibson Dunn / Sidley appear in later LG matters per expert-disclosure records). I could not verify which firm signed LGE's answer in 2:16-cv-00932 specifically.
3. VIZIO, Inc.
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| Jason C. Lo | Lead trial counsel (Delaware action) | Gibson, Dunn & Crutcher LLP, Los Angeles, CA | Caption counsel "for Defendant Vizio, Inc." in C.A. No. 13-2112-RGA (Nov. 19, 2016 opinion). |
| Brian Buroker | PTAB counsel | Gibson, Dunn & Crutcher LLP, Washington, D.C. | VIZIO's counsel in IPR2016-00914 ('370, claims 29 and 47), filed 2016-04-18, instituted 2016-10-04, joined to IPR2015-01867 (per PTAB/RPX records cited in the prior sections of this report). |
| Pilar G. Kraman | Delaware local counsel (not Texas) | Young Conaway Stargatt & Taylor LLP, Wilmington, DE | Local-admission role only; no E.D. Tex. read-across. |
4. ASUSTeK Computer, Inc. and ASUS Computer International
❌ Not identified. I found no filing, opinion, or docket entry naming ASUS's counsel in either 2:16-cv-00932 or the Delaware companion actions (ASUS was not a defendant in the 13-2108/2109/2112 trio). I am not going to guess at a firm. ASUS's counsel must be pulled from the PACER docket.
B. What I could not verify (and why it matters here)
- No defense appearance is reflected in any free docket view. Given the case closed only 233 days after filing (2017-04-13), it is possible that not every defendant — particularly the foreign parents (LGD, LGE-Korea, ASUSTeK) — had entered an appearance or answered before dismissal. I could not confirm which defendants appeared, whether any filed Rule 12 or § 1404(a) motions, or whether any counterclaimed for declaratory judgment of invalidity/non-infringement. The previously generated sections flag the same gap on the motion history.
- In-house counsel: none identified. No LG, VIZIO, or ASUS in-house attorney appears as counsel of record in any source I could reach. LGE/LGD legal-department personnel appear in the discovery record of related matters (e.g., the Acacia/Rambus third-party subpoena actions) but not as counsel here.
- No Texas local counsel identified for any defendant. The East Texas local-counsel role in this campaign ran through firms like Ward & Smith for the plaintiff and The Dacus Firm (Deron R. Dacus, Tyler) for other IDT defendants such as Volkswagen in 2:14-cv-00300 — but I found nothing tying a local firm to the LG, VIZIO, or ASUS defendants in 2:16-cv-00932.
C. Explicit source conflicts / flags
- AI-generated docket pages remain unreliable for this docket. The ai-lab.exparte "complaint analysis" for 2:16-cv-00932 continues to discuss a '730 and a '965 patent, and its docket page reports "No Attorneys" for all parties. As flagged in the earlier sections, those patent numbers match no patent in the authoritative case metadata. Do not use that page for counsel identification.
- RPX's case page does not surface counsel at all for this docket, so it neither confirms nor contradicts the above.
- The Delaware caption block is a proxy, not proof. I am labeling the Mayer Brown / Gibson Dunn identifications as campaign-verified because they come from a court opinion in a sister action on the same patents and the same corporate parties — not from an appearance in 2:16-cv-00932.
D. Recommended PACER pulls to close the gap
- Doc. 1-3 (summonses) and every Notice of Attorney Appearance / Application for Admission Pro Hac Vice in 2:16-cv-00932 (docket 170852) — these will name the actual trial teams and any E.D. Tex. local counsel.
- Any answer, Rule 12(b) motion, or corporate disclosure statement filed before the 2017-04-13 closure, which carries the signature block for each defendant group.
- The closing order/stipulation — in a multi-defendant case, the signature blocks there will show which defense firms were still in the case at termination.
Confidence summary: High confidence that Mayer Brown LLP (Pluta, Streff, Beaber) represented the LG Display and LG Electronics defendants in the IDT/DDG campaign on these patents, and that Gibson, Dunn & Crutcher (Lo; Buroker at the PTAB) represented VIZIO. Low/unverified for: the specific appearances in 2:16-cv-00932, any Texas local counsel, LGE's possibly separate counsel, and ASUS's counsel entirely.