Innovative Display Technologies LLC v. ZTE Corp.

I'll research this case across multiple sources. Let me start with several searches.

Let me dig deeper into the case outcome and the parallel IPR results.

Case Overview: Innovative Display Technologies LLC v. ZTE Corp., No. 2:13-cv-00527 (E.D. Tex., Marshall Div.)

The parties. The plaintiff, Innovative Display Technologies LLC (IDT), is a Texas limited liability company with its principal place of business in Plano, Texas — a non-practicing entity/shell plaintiff with no products or manufacturing operations (Southeast Texas Record case listing; Techdirt profile). IDT is an Acacia Research subsidiary: in its mandatory notices in the parallel IPR2014-01357, IDT identified Acacia Research Group LLC and Acacia Research Corporation as real parties-in-interest, and a companion Acacia case's Rule 7.1 disclosure identified Acacia Research Group LLC/Corporation as IDT's parent and affiliate (IPR2014-01357 Patent Owner Mandatory Notices; GM/IDT D. Del. docket, D.I. 4 in 1:14-cv-00850). The Stanford NPE Litigation Database classifies IDT's asserted patents as "Acquired patents" (NPE Litigation Database). The patents themselves have an operating-company lineage: they originated with Lumitex (Cleveland, Ohio) and inventor Jeffrey Parker, passed through Solid State Opto Limited, were sold to Rambus (Rambus International Ltd./Rambus Inc./Rambus Delaware LLC), then assigned to Acacia in March 2013, and finally to IDT (RPX Insight, Jan. 9, 2014; STPI analysis). The defendants are ZTE Corporation and ZTE (USA) Inc., the Chinese telecommunications-equipment and smartphone/tablet manufacturer and its U.S. affiliate (the PTO's AO 120 filing for this docket names exactly those two entities).

The accused technology. IDT accused ZTE of selling LCD-display devices — the campaign broadly targeted "computers, laptops, cell phones, tablets, printers, and calculators" — whose liquid-crystal display backlighting allegedly embodied the patents; IDT also alleged willful infringement based on an August 2012 notice letter, and sought an injunction plus damages, treble damages, interest, costs, and fees (Mandour Law summary of the complaints; Southeast Texas Record). Note: the specific ZTE product models accused in the 2:13-cv-527 complaint exhibits are not verified in the sources I could retrieve — the campaign-level description is well sourced, but the ZTE-specific infringement contentions are not.

The asserted patents. All seven are titled "Light Emitting Panel Assemblies," share a common written description, and claim priority to a June 27, 1995 ancestor (U.S. 5,613,751); the court treated the '547 specification as representative (Innovative Display Techs. LLC v. Acer Inc., No. 2:13-CV-522-JRG, 2014 WL 4230037 (E.D. Tex. Aug. 26, 2014)). Technical sketches (from the '547 abstract and the claim constructions):

• 6,755,547 (issued 6/29/2004) — backlight with a light-emitting member overlaid by a separate transparent sheet/film with an air gap; a pattern of "deformities" controls output distribution so light "pass[es] through a liquid crystal display with low loss."
• 7,300,194 (11/27/2007) — continuation covering light-emitting panel assembly configurations with patterned light-extracting deformities.
• 7,384,177 (6/10/2008) — related panel-assembly claims to edge-lit backlight structures.
• 7,404,660 (7/29/2008) — panel assembly claims emphasizing the tray/housing and light-output control.
• 7,434,974 (10/14/2008) — LED(s) positioned near/against a panel entrance surface, a tray or housing whose cavity entirely receives the panel, end- and side-edge reflectors, and mounting posts/tabs.
• 7,537,370 (5/26/2009) — panel with patterns of deformities on both front and back sides, at least some deformities being of a different type on one side than the other, plus an overlying film/sheet/substrate.
• 8,215,816 (7/10/2012) — panel entirely received in a tray/housing with edge reflectors, an overlying component, and an input edge with a refractive surface that redirects light "more in the width direction."

Posture, venue, and why the case matters. IDT filed this suit on June 28, 2013 in the Marshall Division of the E.D. Tex. as one of a seven-case salvo that same day against Acer, Dell, HP, Huawei, BlackBerry/RIM, and ZTE; Microsoft (2:13-cv-783) and Nokia (2:13-cv-784) followed in October 2013 (IDT's own related-matter list in IPR2014-01357). The docket number carries the -JRG suffix associated with Judge Rodney Gilstrap, one of the nation's busiest patent jurists, and the lead consolidated case for claim construction was the Acer action, No. 2:13-cv-522-JRG, where Magistrate Judge Roy Payne issued the August 26, 2014 Markman order (Vlex/Studicata summaries; Southeast Texas Record). Venue matters because Marshall in 2013–2015 was the paradigm plaintiff-friendly patent forum — fast local patent rules, experienced juries, and historically high plaintiff win rates — and IDT's decision to file essentially every case there (with a parallel Delaware wing through co-plaintiff Delaware Display Group LLC, whose cases went to Judge Richard G. Andrews) is a textbook example of strategic forum selection in an NPE campaign (RPX, Jan. 9, 2014; D. Del. Mem. Op., Nov. 6, 2015, No. 1:13-cv-02108-RGA).

The case is notable for three reasons. First, it is a quintessential Acacia mass-assertion campaign: IDT ultimately filed roughly 35–37 suits covering almost every major smartphone, tablet, and PC maker — and then automakers (Mercedes, BMW, Toyota, Hyundai, Honda, VW, Mazda, Nissan), camera makers (Canon, Nikon), GPS vendors (Garmin, TomTom, MiTAC), and wireless carriers (AT&T, Verizon, Sprint, T-Mobile) — before largely monetizing through settlements (Techdirt; RPX; IDT's IPR related-matter list; Avvo case history for IDT's lead counsel Jeffrey Bragalone). ZTE itself settled — IDT's counsel lists a "favorable settlement" dated January 6, 2015 for 2:13cv527-JRG, and docket trackers show the case closed (Avvo attorney case list; Ex Parte docket summary). Caveat: I could not verify the exact settlement/dismissal docket entry through PACER directly, so treat the January 2015 date as attorney-reported. Second, the portfolio drew an extraordinary PTAB response — one of the largest early IPR clusters against a single NPE — with petitions by Microsoft (IPR2014-01092/-01094/-01095/-01096), LG Display (IPR2014-01357, -01359), Sony (IPR2015-00753, -00755, -00756, -00757), Mercedes-Benz (IPR2015-00359 through -00366 and IPR2015-01114), LG Electronics (IPR2015-00487, -00489, -00506), and KJ Pretech/Vizio (IPR2015-01866/-01867/-01868, with VIZIO IPR2016-00910 and -00914 joined) (PTO Litigation Center Reports, Nat'l L. Rev.; PTAB petitions). Third, the litigation exposed validity weaknesses in the claims: the Texas Markman struck an expert declaration and held the "quite small in relation to the width and length of the sheet or film" limitation indefinite (Acer, 2014 WL 4230037), and the Delaware court later held "relatively low angles" (’196) and "more in the width direction" ('816) indefinite, while noting IDT/DDG dropped the '177, '660, and '973 patents from the Delaware cases after IPRs were instituted (RPX, Dec. 29, 2015; D. Del. Mem. Op., Nov. 6, 2015).

Sourcing caveats: Party identity, filing date, patents asserted, the Acacia/Rambus chain of title, and the claim-construction holdings are well corroborated across court opinions, PTAB filings, RPX, and the Stanford NPE database. Less well verified in what I retrieved: (1) the specific ZTE products/exhibits in the complaint; (2) the precise settlement docket entry and dismissal date in 2:13-cv-00527; and (3) the final written decisions and outcomes of each IPR (I confirmed institution-level activity and the KJ Pretech/Vizio final hearing, but not the ultimate claim-cancellation results for every patent). Those three points should be confirmed against PACER and the PTAB docket before being relied on as fact.

I'll research this case systematically. Let me start with several searches.

The case appears to have settled. Let me dig into the docket and PTAB proceedings.

Let me dig into the ZTE-specific docket and the PTAB proceedings.

I've hit my search-step limit, so here is what I was able to verify, with clear flags on what remains unsourced.

Innovative Display Technologies LLC v. ZTE Corp., No. 2:13-cv-00527 (E.D. Tex., Marshall Div.)

Bottom line: This case never reached trial. It was one of six complaints IDT filed on 2013-06-28 as part of a coordinated LCD backlighting campaign, it was worked up through claim construction, and it terminated by settlement rather than judgment. The asserted patents were separately hammered in a large PTAB IPR cluster, and the district-court claim-construction ruling that governs them (in the lead case) invalidated one claim of the '547 patent as indefinite.

A caveat up front: I was unable to pull the raw PACER/RECAP docket sheet for 2:13-cv-00527 in this session. Items below attributed to "docket" reflect secondary-source reporting (Justia/Ex Parte docket aggregators, Stanford NPE database, Southeast Texas Record, Avvo case list). I flag the specific gaps explicitly rather than fill them.

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1. Filing & initial pleadings

• 2013-06-28 — Complaint filed. IDT (a Texas LLC, Plano, TX) sued ZTE Corporation and ZTE (USA) Inc. in the Marshall Division, alleging infringement of seven patents, all titled "Light Emitting Panel Assemblies" and all tracing priority to a common ancestor with an earliest priority date of 1995-06-27:
  • U.S. 6,755,547 ('547); 7,300,194 ('194); 7,384,177 ('177); 7,404,660 ('660); 7,434,974 ('974); 7,537,370 ('370); 8,215,816 ('816).
• The complaint was the sixth of a same-day wave of Marshall Division suits: Acer (2:13-cv-00522), Dell ('523), Hewlett-Packard ('524), Huawei ('525), Research in Motion/BlackBerry ('526), and ZTE ('527). Source: Southeast Texas Record, filing report (also reflected in the PTO § 290 notices on file at ptacts.uspto.gov, which list 2:13-cv-00527 and the five '547/'194/'177/'660/'974 patents).
• Relief sought: injunction, compensatory damages, treble damages for willful infringement, interest, costs, and attorney's fees. IDT alleged the defendants were notified in August 2012 that the patents covered their sleeker/thinner display technology and continued anyway — the willfulness hook. (Source: Mandour & Associates case note; corroborated by the complaint's damages prayer in the Southeast Texas Record filing report.)
• Counsel for plaintiff: Jeffrey R. Bragalone, Patrick J. Conroy, Justin B. Kimble, T. William Kennedy Jr., Daniel F. Olejko (Bragalone Conroy PC, Dallas); T. John Ward Jr. and Claire Abernathy Henry (Ward & Smith, Longview). Source: Southeast Texas Record, 2013 filing report.
• Judge: The case was assigned in the Gilstrap/Edwards/Marshall track and carries the "-JRG" suffix in later references (Judge Rodney Gilstrap). Source: Avvo docket listing for the Bragalone firm.

Not verified: The ZTE defendants' answer, affirmative defenses, and any counterclaims (e.g., declaratory judgment of non-infringement/invalidity). ZTE's answer date, its invalidity contentions, and whether it pleaded inequitable conduct are not in the sources I retrieved. I will not guess at these.

2. Pre-trial motions of substance

I could not confirm from sourced material that ZTE individually filed a motion to transfer, a motion to dismiss, or a motion to stay pending IPR. What is documented for the campaign:

• Transfer-coordination / consolidation: The six Marshall Division cases and later-filed related suits (e.g., IDT v. Mercedes-Benz U.S. Int'l, 2:14-cv-535) were consolidated for pretrial purposes into lead case No. 2:13-cv-522-JRG (Acer). Source: the caption of the Court's claim construction order (IDT v. Acer Inc., 2:13-cv-522-JRG (Lead Case)) and the related-matters section of the Mercedes-Benz IPR petition (IPR2015-01114), which states the '535 case was "presently consolidated in Lead Case No. 2:14-cv-201."
• Motion to strike plaintiff's expert declaration (granted). In the lead case, the Court granted Defendants' motion to strike the 6/16/2014 Declaration of Kenneth I. Werner (plaintiff's claim-construction expert) — Dkt. No. 85, 2014-07-11 Order. So IDT went into Markman without its expert declaration. Source: IDT v. Acer, Claim Construction Memorandum and Order at 3 (via Justia, Filing 101).
• Parallel Delaware front: IDT's related entity Delaware Display Group LLC filed companion suits in D. Del. (e.g., Delaware Display Group LLC v. LG Electronics, 1:13-cv-02109; v. VIZIO, 1:13-cv-02112; v. Amazon.com, 1:13-cv-02106; v. Pantech, 1:13-cv-02110). Source: Stanford NPE Litigation Database patent pages; LG Display IPR2014-01095 institution decision.

3. Claim construction (Markman)

This is the substantive heart of the case, and it did reach Markman — but in the lead consolidated case, not in '527 specifically.

• 2014-07-30 — Markman hearing on all seven patents-in-suit.
• 2014-08-26 — Claim Construction Memorandum and Order, by Magistrate Judge Roy S. Payne, in IDT v. Acer, 2:13-cv-522-JRG (Lead Case) (Filing 101). Key holdings:
  • "deformities" (agreed by the parties): "any change in the shape or geometry of a surface and/or coating or surface treatment that causes a portion of the light to be emitted." This agreed construction later became central to the PTAB proceedings (below).
  • "pattern of deformities" / "pattern of light extracting deformities" → "a pattern of deformities, including, but not limited to, a random placement pattern or a variable pattern."
  • "continuous side walls" → plain meaning; the Court expressly rejected defendants' proposed "uninterrupted walls free of breaks," citing prosecution-history disclaimer standards (Omega Eng'g).
  • "transition region" → "a region configured to transmit light" (defendants' "spreads and transmits" rejected on claim-differentiation grounds).
  • "different type" of deformities → plain meaning; defendants' prosecution-disclaimer argument (deletion of "or shape" during prosecution) rejected.
  • "an air gap" → plain meaning; defendants' "continuous layer… no direct physical contact" rejected.
  • "predetermined" → "fixed."
  • "well defined" → "distinct"; indefiniteness attack rejected.
  • "pass through a liquid crystal display with low loss" → treated as a non-limiting whereby clause; indefiniteness attack rejected.
  • "to [suit/fit] a particular application" → plain meaning; indefiniteness attack rejected.
  • Critically: "a pattern of deformities on one side of the sheet or film having a width and length that is quite small in relation to the width and length of the sheet or film" was held indefinite under § 112 ¶ 2, and therefore Claim 1 of the '547 Patent was held invalid. This was the one term where the defendants won, under Nautilus / Datamize.

Why it matters to ZTE: The '547 patent's Claim 1 indefiniteness holding applied across the consolidated group. Note that the CC order's caption lists Acer, Huawei, Microsoft, BlackBerry, Dell and HP as defendants — ZTE does not appear in that caption, which suggests either that '527 was not folded into the lead case, or that it was on a separate track by August 2014. I could not confirm which. Treat the "ZTE was bound by the '522 lead-case constructions" proposition as inference, not sourced fact.

4. Discovery milestones with strategic significance

Not verified. I could not retrieve the '527 discovery record (P.R. 3-1 infringement contentions, P.R. 3-3 invalidity contentions, P.R. 4-2/4-3 exchange, e-discovery disputes, or any § 101/§ 112 early-dispositive practice). I will not invent dates. What is documented is the expert-declaration strike (Dkt. 85, 2014-07-11) and the extensive prosecution-history exhibits attached to the defendants' claim-construction briefing (Dkt. Nos. 69, 75, 82, 86), which shows heavy reliance on the file wrappers of all seven patents.

5. Trial events, verdict, post-trial motions

• No trial and no verdict in 2:13-cv-00527. The ZTE action resolved before trial.
• Accordingly, there were no JMOL, new-trial, or § 285 fee motions in this case that I can source.
• For context on the campaign (not this case): IDT's sibling actions did proceed to trial against other display OEMs, and the K.J. Pretech / VIZIO / Lenovo IPRs noted below were argued on an expedited schedule specifically because "both Lenovo and VIZIO have trials that are imminent on two of these three patents." Source: Oral Hearing transcript, IPR2015-01866/-01867/-01868, 2017-01-10. I could not verify the specific verdicts or outcomes of those separate trials in this session and won't state them.

6. Settlement / final disposition

• 2015-01-06 — Favorable settlement. The Bragalone firm's own case list records: "Innovative Display Technologies LLC v. ZTE Corporation et al — Jan 06, 2015 — OUTCOME: Favorable settlement — Case no. 2:13cv527-JRG … Patent Litigation regarding portfolio of LCD display back-lighting patents." Source: Avvo attorney case list for Jeffrey R. Bragalone.
• The Stanford NPE Litigation Database and the Ex Parte docket aggregator both list the case as "Closed."
• No judgment, injunction, damages award, or appeal — the case ended by agreed dismissal pursuant to settlement. The same firm's list shows the companion Acer ('522) and Mercedes-Benz ('535) cases also ended by "favorable settlement following mediation" (2015-03-11 and 2015-06-22 respectively), which is consistent with a coordinated global resolution of the East Texas IDT wave.
• Terms of the ZTE settlement (license, payment, covenant) are not public in the sources I retrieved.

Note a tension in the record: The Mercedes-Benz IPR petition (IPR2015-01114, filed 2015-04-25) still lists "IDT v. ZTE Corp., 2:13-cv-00527, E.D. Tex." among the actions in which the '816 patent was asserted. Petitions commonly catalog every action in which a patent was ever asserted, so this does not necessarily contradict a January 2015 settlement. I flag it rather than resolve it.

7. Parallel PTAB proceedings on the asserted patents

There was no ZTE-filed IPR that I could source, but the asserted patents were the subject of a dense IPR cluster brought by IDT's other opponents. The two most significant:

(a) LG Display, Inc. — the 2014 cluster. LG Display filed five petitions against five of the seven patents:

• IPR2014-01092 ('974), IPR2014-01094 ('660), IPR2014-01095 ('816), IPR2014-01096 ('370), IPR2014-01097 ('194).
• 2015-01-13 — IPR2014-01095, Decision Denying Institution of review of claims 1–4 of the '816 patent (Paper 9; panel: Giannetti, Powell, Bunting; opinion by Bunting). The Board held LG failed to supply a fact-based rationale for combining Pristash with Tsunoda (or Imai) — merely asserting "it would also be obvious" — and denied all four obviousness grounds. Patent Owner filed its preliminary response 2014-10-16.
• Effect on litigation: A clean defense-side win for IDT; the '816 claims survived untouched at the Board.

(b) The 2015–2017 cluster — Mercedes-Benz, K.J. Pretech, VIZIO, Lenovo.

• Related '816 proceedings identified in IDT's own filings: IPR2014-01095; IPR2015-00366; IPR2015-00496; IPR2015-00752; IPR2015-00834.
• IPR2015-01114 — Mercedes-Benz USA, LLC v. IDT, filed 2015-04-25 on '816 claims 1, 3, 4 (real parties: MBUSA, Mercedes-Benz U.S. International, Daimler North America / Daimler AG). Grounds: (1) obviousness over Guzik + Abdala; (2) Guzik + Abdala + Tsunoda; (3) Pristash + Tsunoda. Petitioner sought the Board to construe "deformities" as "change[s] in the shape or geometry of the panel surface and/or coating or surface treatment that causes a portion of the light to be emitted."
• IPR2015-01866 ('816), IPR2015-01867 ('370), IPR2015-01868 ('974) — K.J. Pretech Co., Ltd. v. IDT, with VIZIO joined (Cases 2016-00910, 2016-00914). Oral hearing held 2017-01-10 (Chief panel: Giannetti, Quinn, Bunting). Counsel: Robert G. Pluta / Saqib Siddiqui (Mayer Brown) for K.J. Pretech; Blair Silver / Jason Lo (Gibson Dunn) for VIZIO; Eric Klein (Vinson & Elkins) for Lenovo; Jeffrey R. Bragalone and Justin B. Kimble (Bragalone Conroy) for IDT. The Board had instituted on all challenged claims of the '974 patent, and its construction of "deformities" (two-pronged: shape change + light emission) drove the anticipation analysis over Kisou.
• IPR2015-01866 was the '816 petition, filed by K.J. Pretech on 2015-09-11 (per the PTO Litigation Center Report of 2015-09-14); Tech Center 2800.

Effect on the ZTE litigation: Indirect. The IPR filings did not stay '527 (no stay order sourced), and the ZTE case settled in January 2015 — before the 2015 petition wave ripened. But the IPRs materially shaped the value of the portfolio: they pierced the '816 claims with a second wave of petitioners after LG Display's 2015 loss, expanded Board construction of "deformities" that later fed the merits in K.J. Pretech, and created the invalidity risk that plausibly accelerated IDT's settlements with ZTE, Acer, and Mercedes-Benz across 2015.

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Chronology at a glance

Open items I could not source

1. ZTE's answer, counterclaims, and invalidity contentions.
2. Whether ZTE moved to transfer, dismiss, or stay (and the dispositions).
3. Whether '527 was consolidated into the '522 lead case — the CC order caption omits ZTE.
4. Any ZTE-filed IPR on the seven patents.
5. The settlement terms and exact dismissal order (date/entry number) in '527.
6. Discovery-specific milestones in '527 (P.R. 3-1/3-3, document-production disputes).

If you can supply the '527 docket sheet (Dkt. numbers) or access to PACER, items 1–6 are straightforwardly fillable and I can fold them into this chronology.

I'll search for press coverage of this case across multiple angles.

Let me search additional angles: trade press, the Markman ruling coverage, and settlement reporting.

Let me check for ZTE-specific reporting and Chinese-language/trade coverage.

Press and analyst coverage

Bottom line: this docket drew essentially no case-specific press. I found no Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, or JD Supra article about IDT v. ZTE itself, and no coverage at all of the January 2015 settlement. What exists falls into three buckets: (1) a handful of filing-roundup and law-firm items that name ZTE as one of the defendants; (2) campaign-level NPE-tracking and tech-policy coverage that discusses the IDT/Acacia assertion program without ever reaching this docket; and (3) Acacia's own corporate disclosures, which report several IDT settlements but—so far as I could find—never mention ZTE. I hit my search-step limit, so treat the negative finding as "not located," not "proven absent."

The items that actually name ZTE. The Southeast Texas Record reported in its roundup of the June 28, 2013 Marshall Division filings that "Innovative Display Technologies v. ZTE Corp. et al Case No. 2:13-cv-00527" was one of six same-day suits, listed the seven "Light Emitting Panel Assemblies" patents, noted that IDT is "a Texas limited liability company with its principal place of business in Plano," and recorded that the plaintiff sought "an injunction and … damages, treble damages, interest, court costs and attorney's fees," with a jury demand and the Bragalone Conroy/Ward & Smith appearance list. A Mandour & Associates case note published just after the filing is the only commentary I found that discusses the complaint's theory, reporting that IDT alleged "the defendants were informed in August 2012 that the technology for sleeker displays on computers and cell phones was held by Innovative Display Technologies and all use of the technology should cease," and that continued sales made infringement "willful," entitling IDT to "triple damages, as well as interest and attorneys fees." Taiwan's Science & Technology Policy Research and Information Center (STPI) ran a 2013-07-11 Chinese-language analysis placing the ZTE case in a table of the six companion suits and characterizing the whole thing as another "patent trust case" (專利信託案件), tracing the patents Lumitex → Solid State Opto → Rambus → Acacia → IDT and reporting that Rambus paid US$26 million for part of the optical portfolio.

Campaign-level coverage supplies the numbers the ZTE docket never generated. RPX reported on 2014-04-10 that IDT "continues to find new targets for its campaign asserting patents related to LCD components," that "almost 30 cases have been filed since IDT began asserting these patents in litigation almost a year ago," and that "the asserted patents originated with Solid State Opto and were transferred to Rambus in 2009, then assigned to Acacia in March 2013," with targets including "Apple, Acer, Blackberry, Dell, HP, LG, Nokia, and Sony." Techdirt went further on 2014-08-12, profiling IDT under the headline "Know Your Troll," counting 37 IDT suits among 63 Acacia subsidiaries and "669 lawsuits," and arguing that IDT had "already secured a licensing agreement from Garmin. But that's it. Not a very productive set of weaponized patents." Notably, none of this campaign reporting names ZTE as a defendant, and none reports a damages demand in this case — the only dollar figures in the press record are the STPI $26 million acquisition price and, in a different IDT case, Techdirt's report that IDT's second suit against Apple sought "nearly $6 billion in 'accrued royalties.'"

Where accounts diverge, and where reporting outran the record. The sharpest conflict is editorial: Techdirt's "troll"/"weaponized patents"/"low conversion rate" framing is directly contradicted by Acacia's own statements — Techdirt itself quotes Acacia's Marvin Key saying "the implication is when someone is sued … that every single one of those cases is frivolous, abusive and without merit. And that's simply untrue" — and Techdirt's August 2014 "not a very productive set" assessment was overtaken within a year by Acacia's 8-K reporting a March 2015 "settlement and license agreement with Dell Inc., and Hewlett-Packard Company" resolving Nos. 2:13-cv-523 and 2:13-cv-524, a June 2015 8-K reporting a "patent license agreement with LG Display Co., Ltd.," and a BusinessWire release on 2015-08-13 announcing a Sony settlement, also covered by Benzinga. That silence is itself a data point: I found no Acacia 8-K, press release, or trade item reporting a ZTE settlement, even though settlements with Dell/HP, LG Display, and Sony were publicly disclosed — so the January 2015 ZTE resolution rests on plaintiff's-counsel reporting only, not on press or issuer disclosure. Separately, the Mandour note is imprecise in ways worth flagging against the record: it calls the plaintiff "Innovative Display Technologies, Inc." (the docket entity is an LLC) and says the patents "are held by Ohio native Jeffrey Parker" (Parker is the named inventor; title ran through Solid State Opto/Rambus/Acacia to IDT, as STPI and RPX both correctly report). One factual gap in the earlier sections can now be partly closed, though not from press: the complaint text as reproduced in the PTAB exhibit filings identifies the accused ZTE products as "mobile phones, tablets, and mobile hotspots (e.g., the ZTE N910 mobile phone)" — a detail no press account I found reported.

Sources

• 7404660 | NPE Litigation Database - 7404660
• 6079838 | NPE Litigation Database
• Innovative Display Technologies LLC
• Technology Company Accuses Dell, HP of Patent Infringement
• 84. Upon information and belief, distributors and consumers that purchase ZTE's products that include all of the limitations of ...
• 94. Upon information and belief, ZTE has been and is directly infringing under 35 U
• 發光面板組件專利訴訟，Innovative Display Technologies 控告Dell等6間公司 - ︿Top
• Attorney Jeffrey R. Bragalone's Legal Cases
• Case 2:13-cv-00522-JRG Document 69 Filed 06/16/14 Page 1 of 35 PagelD #: 907
• acacia – Techdirt
• nikon – Techdirt
• Acacia Subsidiaries Enter into Settlement and Patent License Agreement with Sony Corporation - Acacia Subsidiaries Enter into Settlement and Patent License Agreement with Sony Corporation

I'll research the plaintiff's counsel of record for this case. Let me start with several searches.

Let me pull the docket aggregator page and search for the specific complaint/filings.

I found the core counsel listing. Let me verify against the docket and gather firm/role details.

Plaintiff's Counsel of Record — IDT v. ZTE, No. 2:13-cv-00527 (E.D. Tex.)

Caveat up front: My direct access to the PACER docket sheet for this specific case was limited in this session, so the roster below is grounded primarily in a contemporaneous E.D. Tex. filings report (Southeast Texas Record's "Recent patent infringement cases filed in the Eastern District of Texas," which reproduces the complaint's caption/signature block) plus the related-case docket data and firm profiles returned by search. I was not able to independently download the live docket to confirm every appearance, withdrawal, or substitution of counsel over the life of the case. Where a role is inferred rather than documented on the docket, I flag it.

Counsel listed on the complaint (filed June 28, 2013)

The complaint identified the following attorneys as representing plaintiff Innovative Display Technologies LLC (a Plano, TX LLC and Acacia Research Corp. subsidiary):

Bragalone Conroy PC — Dallas, Texas

Ward & Smith Law Firm — Longview, Texas

What I could and could not confirm

• Confirmed by source: The Southeast Texas Record filing report (setexasrecord.com, story 510621652) lists exactly this group — "Jeffrey R. Bragalone, Patrick J. Conroy, Justin B. Kimble, T. William Kennedy Jr. and Daniel F. Olejko of Bragalone Conroy PC in Dallas; and T. John Ward Jr. and Claire Abernathy Henry of Ward & Smith Law Firm in Longview" — as IDT's representation for ZTE Corp. et al., Case No. 2:13-cv-00527.
• Corroboration: Docket data for the related IDT v. Sprint case (2:14-cv-00721) lists plaintiff attorneys "Thomas William Kennedy, Jr." and "Jeffrey Ray Bragalone," consistent with the above.
• Not verified: Whether any attorney formally withdrew or additional appearances were filed later in 2:13-cv-00527; the case status is shown as Closed, and the ultimate disposition/settlement paperwork for this specific docket was not retrievable in this session. I also could not confirm a formal "lead counsel" designation on the docket — the "lead counsel" characterization for Mr. Bragalone is inferred from his role as founding/signature counsel on the IDT complaints.
• No in-house counsel identified: IDT is an Acacia (now Dominion Harbor) NPE subsidiary; no individual in-house attorney for the plaintiff appears in the sources retrieved. I did not find evidence of an in-house appearance, and I will not invent one.

Suggested verification steps

If you need docket-verified designations, pull the PACER docket for 2:13-cv-00527 and check (a) the complaint signature block, (b) any Notice of Attorney Appearance entries, and (c) the Notice of Attorney Withdrawal / final judgment or dismissal order, which will show which counsel remained of record at disposition.

Bottom line: The plaintiff's counsel of record on the complaint are Bragalone Conroy PC (Dallas) — Bragalone, Conroy, Kimble, Kennedy, and Olejko — with Ward & Smith Law Firm (Longview) — T. John Ward, Jr. and Claire Abernathy Henry — acting as E.D. Tex. local counsel.

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

Bottom line up front

I was unable to verify any defense-side counsel of record for ZTE from the sources I could reach in this research pass. What the available public sources surface is overwhelmingly plaintiff-side counsel. Rather than guess at names, here is what is confirmed, what is not, and exactly where the answer lives.

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1. What IS confirmed (plaintiff's counsel of record — for contrast)

The Southeast Texas Record's filing report for the June 28, 2013 Marshall Division filings (Case No. 2:13-cv-00527, "Innovative Display Technologies v. ZTE Corp. et al") identifies only the plaintiff's representation:

Source: Southeast Texas Record, "Recent patent infringement cases filed in the Eastern District of Texas," setexasrecord.com/stories/510621652.

I flag this because it is a common failure mode in these case summaries: filing-report coverage of E.D. Tex. complaints routinely prints the plaintiff's firm list (drawn from the complaint signature block) and never mentions defense counsel — defense counsel do not exist until an answer or an AT-1 notice of appearance is filed, often weeks or months later.

2. What is NOT confirmed (defendant's counsel — the actual question)

I could not verify any attorney who appeared for ZTE Corp. or the co-defendants in 2:13-cv-00527. Specifically:

• No PACER docket text, RECAP entry, or firm biography I retrieved named a ZTE-side attorney in this docket.
• The aggregate databases (Stanford NPE Litigation Database, npe.law.stanford.edu; ExParte's E.D. Tex. case page, ai-lab.exparte.com/case/dct/txed/2:13-cv-00527) both render this case with empty/gated "Attorney" fields for the defendant party, which is consistent with counsel data not being exposed on the free tier rather than with no counsel having appeared.
• No notice of appearance, answer, corporate disclosure statement, or scheduling-order signature block for a ZTE-side firm surfaced in my searches.

I am therefore declining to name any defense attorney. Inventing or half-recalling a firm here would be exactly the error the assignment asks me to avoid.

3. Two structural points worth flagging before someone else fills this gap

(a) This is a multi-defendant case. The caption is Innovative Display Technologies LLC v. ZTE Corporation et al (Stanford NPE database; Avvo case list for Jeffrey Bragalone, which spells the caption and number "2:13cv527-JRG"). "et al." means ZTE was one of several accused infringers, and multi-defendant E.D. Tex. patent cases of this vintage typically had separate counsel per defendant group, sometimes a joint-defense arrangement. Any single "ZTE counsel" list should be checked against which defendant entity actually answered.

(b) ZTE's corporate structure matters. ZTE Corp. (the Chinese parent) and ZTE (USA) Inc. are separate entities with historically separate litigation counsel. The complaint named the parent; service and appearance practice on the U.S. subsidiary can diverge. Confirm which entity filed the answer.

(c) The docket is closed. Both Stanford and ExParte list the case status as Closed. That means the full attorney roster is fixed and retrievable — there is no "counsel hasn't appeared yet" ambiguity to resolve. The information exists; I just could not extract it with the search tools available to me.

4. How to close this out definitively (recommended next steps)

1. PACER, E.D. Tex., 2:13-cv-00527 — open the docket sheet and use the "Attorneys" tab / party-attorney report. Look for Local Rule AT-1 notices of appearance, the answer signature block, and the corporate disclosure statement. Those four document types will name every defense attorney and firm, alphabetically, including local counsel.
2. RECAP / CourtListener — search the docket number directly; RECAP often holds the answer and scheduling order even when the attorney metadata layer is gated.
3. Judge's docket — the case was assigned to a "JRG" suffix (Judge Rodney Gilstrap) per the Avvo caption; the court's own Docket Management / CM-ECF party-attorney query is authoritative.
4. Firm-side confirmation — once you have firm names from PACER, verify role (lead vs. local vs. of counsel) on the firms' own attorney bios, and cross-check for parallel PTAB IPR filings on the seven patents (6,755,547; 7,300,194; 7,384,177; 7,404,660; 7,434,974; 7,537,370; 8,215,816) where defense IPR counsel may differ from district-court counsel.

5. Accuracy statement

• Verified: plaintiff-side counsel of record and the case's closed status and multi-defendant posture.
• Not verified / not asserted: every element of the requested defense-counsel table (name, role, firm, office, experience note). No defense attorney is named in this section because I have a source for none.
• No sealed filings were encountered in the sources I reached; the gap here is a tool-access gap, not a sealing issue.