Roku, Inc. v. Universal Electronics Inc.

Overview. This matter is formally an inter partes review — IPR2022-00943, Roku, Inc. v. Universal Electronics Inc., before the USPTO Patent Trial and Appeal Board — rather than a standalone district-court infringement suit, and it sits inside a much larger patent war. Roku, Inc., the petitioner, is the large operating company behind streaming players, Roku TVs (built with TCL, Hisense, and others), voice-enabled remotes, and the Roku OS. Universal Electronics Inc. (UEI) is the patent owner — a long-time designer/maker of universal remotes and control software (e.g., QuickSet) for pay-TV operators and CE brands, which is also an aggressive licensor/assertor of its large remote-control and voice-control portfolio. UEI has sued Roku (and TV makers TCL, Hisense, Funai) in overlapping Central District of California actions and ITC investigations; per UEI's mandatory-notice disclosures in this IPR, the related litigation included Universal Electronics, Inc. v. Roku, Inc., No. 8:18-cv-01580-JVS-ADS and No. 8:20-cv-00701-JVS-ADS, and Roku, Inc. v. Universal Electronics, Inc., No. 8:21-cv-00658-JVS-ADS, all before Judge James V. Selna in the Santa Ana (Southern) Division of the C.D. Cal. Roku filed this IPR on April 29, 2022, challenging all claims (1–16) of U.S. Patent No. 10,930,276, "Apparatus, System and Method for Directing Voice Input in a Controlling Device" (Appl. 15/861,298, filed Jan. 2, 2018, granted Feb. 22, 2021; inventor Arsham Hatambeiki).

Technology and posture. The '276 patent concerns a voice-controlled "controlling device" (e.g., a voice remote, smart speaker, or streaming device with a microphone): the system establishes a noise threshold for the device's operating environment, and when a speech input is received it measures ambient noise and, if the measured noise exceeds the threshold, automatically issues commands to duck the volume of a controllable appliance (TV, soundbar, etc.) — in essence, improving voice-command capture/signal-to-noise by quieting the room. UEI's assertion of the patent implicates Roku's voice-control ecosystem (Roku streaming players, voice remotes, and Roku TVs/OS); the precise accused product lists in the parallel district case were not detailed in the materials reviewed here, but UEI's campaign has consistently targeted Roku's streaming players, remotes, and Roku TV integrations. Procedurally: the Board (Administrative Patent Judges Sharon Fenick — author of the Final Written Decision — and Patrick M. Boucher, with panel changes in mid-2023) instituted review on November 30, 2022; UEI responded through expert Dr. Michael S. Scordilis while Roku relied on expert Bruce McNair; oral argument was held October 30, 2023; and on November 28, 2023 the Board issued its Final Written Decision (2023 WL 8242606), holding claims 1–7, 9–13, 15, and 16 (14 claims) unpatentable as obvious over Hart-787 (U.S. Pat. No. 9,251,787), Fu (U.S. Pat. App. Pub. 2017/0126192), and Rosenberg (U.S. Pat. No. 9,509,269) — with Hart-286 added for claim 12 — while declining to invalidate claims 8 and 14 (which were not pursued on appeal). UEI appealed to the Federal Circuit (No. 24-1426, notice filed January 29, 2024), and on April 10, 2026 a nonprecedential panel affirmed, rejecting UEI's arguments that the Board adopted a combination first raised in Roku's reply and that there was no motivation to combine. Universal Electronics, Inc. v. Roku, Inc., No. 24-1426 (Fed. Cir. Apr. 10, 2026).

Why it matters. The case is notable for several reasons. First, it is one node in a sustained, multi-forum campaign: UEI has pursued Roku and Chinese smart-TV makers in the C.D. Cal. (Judge Selna) and at the ITC (including a 2021 ITC limited exclusion order against Roku), while Roku responded with waves of IPRs — UEI's own 10-Q reporting described roughly a dozen granted and a dozen-plus denied Roku IPRs against its portfolio, with the district court matters stayed pending those PTAB outcomes. Second, the subject matter — voice-activated volume ducking in response to ambient noise — is commercially central to today's smart TVs, streaming devices, and voice remotes, making the PTAB's obviousness ruling (and its affirmance) a meaningful precedent-adjacent data point on combining references to solve a known noise/SNR problem, including the "suitable option" standard for motivation to combine discussed in Intel Corp. v. Qualcomm. Third, the Federal Circuit's affirmance confirms a complete IPR win for Roku on the challenged '276 claims, which feeds back into the stayed California litigation through estoppel and invalidity of the asserted claims. One caveat: I could not independently confirm from public sources exactly which district-court docket first asserted the '276 patent or the precise accused-product list for that patent, so those details should be verified against PACER before being relied on.

Key Legal Developments and Outcome — Roku, Inc. v. Universal Electronics Inc.

Threshold clarification on "case" scope

The captioned matter — Roku, Inc. v. Universal Electronics Inc., IPR2022-00943 (P.T.A.B.) — is a patent office inter partes review, not a district-court infringement case. There is no separate "complaint / answer / Markman / trial / verdict" track inside an IPR; its procedural analogues are the petition, patent-owner response, reply, oral hearing, and Final Written Decision, followed by a Federal Circuit appeal. The district-court infringement backdrop is the UEI-v.-Roku campaign in the Central District of California, discussed below with sourcing caveats, because the public record I could verify does not tie the '276 patent to a specific case number with certainty.

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1. Filing & initial pleadings (IPR and related litigation)

• 2018-09-05 — UEI sued Roku for patent infringement in C.D. Cal., Universal Electronics Inc. v. Roku, Inc., No. 8:18-cv-01580 (C.D. Cal., Judge James V. Selna; Magistrate Autumn D. Spaeth), asserting nine UEI patents (the '642, '389, '325, '853, '309, '504, '505, '532, and '446 patents). A First Amended Complaint followed 2018-12-07. Roku answered by way of motion to dismiss on 2018-12-24 (Dkt. 32). (Source: Unicourt/Unified Patents docket summaries of 8:18-cv-01580.)
• 2020-04-09 — UEI filed a second C.D. Cal. case, 8:20-cv-00701 (C.D. Cal., Judge Selna); it was stayed within weeks (terminated/stayed docket flag as of 2020-06-18). UEI's 2021-12-15 press release describes 8:18-cv-01580 and 8:20-cv-00701 as collectively asserting "fourteen UEI patents," stayed "pending the final resolution of Roku's Inter Partes Review (IPR) challenges … and pending final resolution of the ITC investigation."
• 2022-04-29 — Roku filed its IPR petition in IPR2022-00943 challenging all of claims 1–16 of U.S. Patent No. 10,930,276 ("Apparatus, System and Method for Directing Voice Input in a Controlling Device," application 15/861,298, issued 2021-03-23), with the McNair declaration (Ex. 1003) and a 20+-reference prior-art set led by Hart-787 (US 9,251,787), Fu (US 2017/0126192 A1), Rosenberg (US 9,509,269), and Hart-286 (US 9,466,286). (Sources: Unified Patents PTAB portal; PTAB docket; IPR petition documents.)

2. Claim construction / institution stage (the IPR analogue to Markman)

• UEI's Patent Owner Preliminary Response (Paper 6) argued, among other things, that claim 1 should be construed to require "separate" sound captures at different times — a construction the Board rejected at institution.
• 2022-11-30 — Institution Decision (Paper 7) granted IPR on all challenged claims under 35 U.S.C. § 314, preliminarily finding that Hart-787 in the proposed combination taught the "second sound data … at the time speech input is received" limitation and rejecting UEI's "separate capture" argument. (Sources: PTAB docket entries; Roku reply at Paper 20, citing Paper 7 at 23–24.)
• No formal district-court Markman occurred for the '276 patent in the record I verified. (The 2019-08-07 Selna claim-construction order, 2019-08-07, covered nine different patents in 8:18-cv-01580, not the '276 patent.)

3. Discovery-style milestones (IPR evidence phase)

• 2023-01-10 — UEI noticed the deposition of Roku's expert, Bruce McNair; deposition taken 2023-02-10 (Ex. 2006).
• 2023-03-09 — UEI filed its Patent Owner Response (Paper 17) with the declaration of Dr. Michael S. Scordilis (Ex. 2005), arguing that Rosenberg's "volume threshold" does not adjust during the method, that the combination would render Hart-787/Fu inoperable, and that the grounds were hindsight-driven; it also moved to accord Roku's expert declaration little weight.
• 2023-04-11 — Roku noticed the deposition of Dr. Scordilis (Paper 19).
• 2023-06-16 — Roku filed its Reply (Paper 20), emphasizing that the petition's theory from the start was Hart-787 + Fu's predetermined threshold + Rosenberg's dynamic/ambient-noise-derived threshold, and that Scordilis's declaration merely parroted the response.
• 2023-07-21 — Both parties requested oral argument; 2023-07-31 — panel change order (Fenick/Boucher panel, with Judge Fenick authoring); 2023-08-31 — demonstratives exchanged; 2023-10-30 — oral hearing transcript (Paper 29). (Sources: DocketAlarm and Unified Patents PTAB docket chronology.)

4. "Trial-equivalent" event: Final Written Decision

• *2023-11-28 — Final Written Decision (Paper 30), Roku, Inc. v. Universal Elecs., Inc., IPR2022-00943, 2023 WL 8242606 (P.T.A.B. Nov. 28, 2023):*
  • Claims 1–7, 9–13, 15, and 16 (14 claims) held unpatentable as obvious over Hart-787 in view of Fu and Rosenberg (Ground 1), with claim 12 additionally over Hart-286 (Ground 2).
  • Claims 8 and 14 held not proven unpatentable.
  • The Board expressly grounded its obviousness finding on the combination as pleaded in the petition: Hart-787's audio-control device with Fu's "predetermined threshold" comparison and Rosenberg's teaching that the threshold "may be determined based on the volume of an ambient audio signal" (Decision at *11, *13).
  • (Sources: 2023 WL 8242606; Fed. Cir. slip op. at 5–9; Fed Circuit Blog, 2026-04-10.)

5. Appeal / final disposition

• 2024-01-29 — UEI filed its Notice of Appeal (Paper 31) to the Federal Circuit; appeal docketed as Universal Electronics, Inc. v. Roku, Inc., No. 24-1426 (Fed. Cir.). Claims 8 and 14 were not at issue on appeal.
• On appeal UEI argued (a) the Board improperly adopted a "new" modification advanced first in Roku's reply, and (b) the motivation-to-combine finding lacked substantial evidence.
• 2026-04-10 — Federal Circuit affirmed in a non-precedential opinion (per curiam panel; opinion available at CAFC No. 24-1426, 2026 WL __; summarized by Fed Circuit Blog and VitalLaw/IP Law Daily, 2026-04-14). The court held the Board's reasoning tracked the petition itself (rejecting the "new theory" argument), that UEI's "timing" argument attacked references in isolation rather than the combination (citing In re Merck, 800 F.2d 1091 (Fed. Cir. 1986)), and that substantial evidence supported the motivation to combine — Roku need only show the combination was a "suitable option," not the best option.
• Present posture: Fully resolved against UEI at the PTAB and Federal Circuit — the 14 claims stand cancelled; the two surviving claims (8, 14) were not before the appellate court. No further petition for certiorari is reflected in the sourced record.

6. Parallel PTAB / ITC / district-court proceedings and their effect

The '276 IPR was one thread in a larger Roku–UEI validity war, with these verified parallel tracks:

• Parallel IPRs by Roku against other UEI remote-control patents asserted in the C.D. Cal. cases (e.g., IPR2019-01608 on the '853 patent, among others). Outcomes were mixed: in Roku, Inc. v. Universal Electronics, Inc., No. 2022-1058 (Fed. Cir. 2023-03-31, precedential), the Federal Circuit affirmed the Board's holding that Roku had not shown claims 1, 3, 5, and 7 of the '853 patent unpatentable — UEI won that one. A further voice-control IPR, IPR2022-01289 (Roku v. UEI, U.S. Patent No. 9,847,083, "Voice Command Augmented Codeset Record," filed 2022-07-20), was also pending in the same campaign.
• ITC Investigation No. 337-TA-1263 (UEI v. Roku): Final determination issued 2021-12-15, finding infringement of UEI's '196 patent and issuing a limited exclusion order; the companion district court cases (8:18-cv-01580, 8:20-cv-00701) were stayed pending resolution of the ITC matter and the IPR challenges, per UEI's 2021-12-15 release and the 2021-06-03 stay order in related Roku-initiated No. 8:21-cv-00658 (stayed pending ITC 337-TA-1263).
• Effect on the '276 litigation: consistent with UEI's stated practice, the district-court cases were stayed pending IPR finality; with the Federal Circuit's 2026-04-10 affirmance, estoppel and finality now favor Roku on the 14 cancelled '276 claims.

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Candid sourcing caveats

• The specific district-court case number in which the '276 patent itself was asserted (versus the broader UEI–Roku C.D. Cal. campaign) could not be confirmed from the search results available to me. UEI's press materials identify only 8:18-cv-01580 and 8:20-cv-00701 as the stayed district cases, and the '276 patent issued in March 2021 — after both were filed — so its assertion presumably came by later amendment or a later-filed case. Treat any specific "UEI v. Roku" case number for the '276 patent as unverified pending PACER review.
• No Markman order, trial, verdict, or post-trial motion exists for the '276 patent in a district court on this record; those stages belong to the pre-'276 district-court cases (e.g., the 2019-08-07 Selna claim-construction order covering nine other UEI patents).
• Counsel details verified only in part: Roku was represented at the Federal Circuit by Scott McKeown (Wolf Greenfield; also PTAB petitioner counsel of record), and UEI's PTAB counsel included James Lukas and Erik Bokar (pro hac vice declarations) — not a complete counsel list.

Bottom line: Roku's IPR on the '276 patent was instituted 2022-11-30; the Board's 2023-11-28 Final Written Decision cancelled 14 of 16 claims as obvious; UEI's appeal (No. 24-1426) was affirmed by the Federal Circuit on 2026-04-10 — leaving the PTAB invalidation of the '276 patent's primary claims intact, within a broader UEI–Roku war where UEI nonetheless prevailed in other arenas (ITC exclusion order on the '196 patent; the '853-patent IPR appeal).

I'll start by clarifying the nature of this matter and locating the actual counsel of record. Let me run several searches.

The metadata describes a PTAB IPR, not a district-court infringement action. Let me dig deeper to (1) confirm the full counsel lists on the PTAB record and (2) check whether there is an underlying district-court infringement case between these parties involving the '276 patent, since "plaintiff" terminology typically maps to a district court case.

I now have a clearer procedural picture. This is a PTAB IPR (Roku = petitioner, UEI = patent owner), with a parallel Federal Circuit appeal. Let me verify the full petitioner-side counsel list from the PTAB filings and check the related district court actions where "plaintiff" terminology would actually apply.

Important threshold clarification

This matter is not a patent infringement case, and there is no "plaintiff." IPR2022-00943 is an inter partes review before the PTAB: Roku, Inc. is the Petitioner (the party the case metadata here labels "plaintiff"), and Universal Electronics Inc. ("UEI") is the Patent Owner/Respondent (the party that would be the infringement plaintiff in the parallel district-court litigation). The proceeding ended in a Final Written Decision (Nov. 28, 2023) that UEI appealed to the Federal Circuit as Universal Electronics, Inc. v. Roku, Inc., No. 2024-1426 (affirmed Apr. 10, 2026, nonprecedential). No filings in the IPR are sealed; all counsel designations below are from the public PTAB record.

Treating Roku (the metadata "plaintiff," and the IPR petitioner) as the party of interest, counsel of record on the PTAB docket were:

Roku's counsel in IPR2022-00943 (Petitioner)

Sources: Petitioner's Power of Attorney and Petition (filed 4/29/2022) signed by Scott A. McKeown, Reg. 42,866, Ropes & Gray LLP, Washington, DC (PTACTS/PTAB public filings); Dec. 14, 2022 filing listing McKeown, Rizzolo, McLaughlin (Ropes & Gray, Washington, DC) and Gentilli (Ropes & Gray, Boston) as Petitioner's counsel; PTAB oral-hearing transcript (PTACTS) identifying "Scott McKeown, Wolf, Greenfield & Sacks, P.C." with Rizzolo and McLaughlin at Ropes & Gray; Unified Patents and IPVerve case portals listing "Petitioner Counsel: McKeown, Scott, et al."; CourtListener/CAFC materials showing McKeown argued for Roku (appellee) in No. 2024-1426.

If you actually meant the district-court infringement plaintiff

If your question targets the infringement litigation rather than the IPR, the roles flip: in the related C.D. Cal. actions identified in UEI's mandatory notices — Universal Electronics, Inc. v. Roku, Inc., 8:18-cv-01580-JVS-ADS and 8:20-cv-00701-JVS-ADS — UEI is the plaintiff, not Roku. UEI's PTAB-side lead counsel was James J. Lukas, Jr. (Greenberg Traurig LLP, Chicago), with Erik A. Bokar admitted pro hac vice only as back-up counsel for UEI by Board order in these proceedings. UEI's separate district-court counsel in those C.D. Cal. actions, and whether the '276 patent is actually asserted in any of them (note Roku also filed a C.D. Cal. action as plaintiff, Roku, Inc. v. Universal Electronics, Inc., 8:21-cv-00658-JVS-ADS), would need to be verified on PACER — I could not confirm those district-court appearances from the available record, and I have not invented any.

Bottom line: For the PTAB matter in your metadata, Roku's counsel of record was led by Scott A. McKeown (Ropes & Gray, later Wolf Greenfield), with Matthew J. Rizzolo, Brendan F. McLaughlin, and Rebecca Gentilli (Ropes & Gray) as back-up counsel. No true "plaintiff" or "defendant" exists in an IPR.

Preliminary framing note (important)

The case you've flagged — Roku, Inc. v. Universal Electronics Inc., IPR2022-00943 (PTAB) — is an inter partes review, not a patent infringement case. There are no "plaintiffs/defendants" in an IPR in the formal sense; the parties are Petitioner (Roku) and Patent Owner / Respondent (Universal Electronics Inc., "UEI"). The caption metadata you supplied lists Roku as "plaintiff" and Universal Electronics as "defendant," so below I treat Universal Electronics Inc. as the party whose counsel you want, and I cover both (1) UEI's counsel in the IPR itself and the related Federal Circuit appeal, and (2) UEI's counsel in the parallel C.D. Cal. infringement action that matches the "Roku v. Universal Electronics" caption (where UEI is literally a defendant).

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1. UEI's counsel of record in IPR2022-00943 (patent owner/respondent)

Sources: PTAB filings and mandatory notices in the case and its companion UEI IPRs; Unified Patents PTAB portal entry for IPR2022-00943; ipverse/greyb case page; Federal Circuit docket for the appeal of this FWD.

Caveat on the GT/Alston back-up roster: The full back-up list above appears in UEI's updated mandatory notices in companion IPR2022-01289 (the same UE–Roku representation team). For IPR2022-00943 itself, the public documents I could verify directly confirm Lukas as lead (e.g., the Dec. 14, 2022 Patent Owner filing, and the ipverse/Unified Patents counsel listings showing "Respondent Counsel: Lukas, James, et al."). The docket also shows UEI filed updated mandatory notices and an updated power of attorney in this IPR on Dec. 12, 2022 (entries 9–10) — those exact filings would confirm the identical roster, but I could not pull their full text in this session. I did not find evidence of in-house UEI counsel of record in the PTAB filings from the available sources.

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2. UEI as an actual "defendant": the parallel district court action

The underlying infringement suit matching your metadata caption — Roku, Inc. v. Universal Electronics, Inc. et al., No. 8:21-cv-00658 (C.D. Cal., Judge James V. Selna) — was filed by Roku (asserting Roku patents, e.g., U.S. Patent No. 8,378,875) against Universal Electronics, Inc. and affiliates (C.G. Development Ltd., C.G. Mexico Remote Controls, Gemstar Technology Qinzhou/Yangzhou, UEI Brasil Controles Remotos, Universal Electronics BV). Per the Justia docket, the case was stayed pending ITC Investigation No. 337-TA-1263 and administratively closed on June 3–4, 2021 (Docket Nos. 22–23), so defendants' merits pleadings were never filed.

Counsel for UEI (defendant) identified from public sources:

Because the case was stayed almost immediately and administratively terminated, there is no full set of "attorney appearance" docket entries for each UEI affiliate defendant that I could verify; the above is the best-sourced defense counsel set for UEI itself. If you need the exact appearance list, PACER for 8:21-cv-00658 (C.D. Cal.) would show all filers on Docket Nos. 20–22.

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3. Federal Circuit appeal of the IPR FWD (for completeness)

UEI appealed the Final Written Decision (which found 14 claims of U.S. Patent No. 10,930,276 unpatentable) to the Federal Circuit — appeal docket No. 24-1426, Universal Electronics, Inc. v. Roku, Inc. The Federal Circuit affirmed on April 10, 2026 (opinion available on Justia). UEI's appellate counsel of record (per Federal Circuit appearance entries) were James J. Lukas, Jr., Gary R. Jarosik, and Benjamin P. Gilford of Greenberg Traurig. Roku was represented on appeal by Scott A. McKeown and colleagues of Ropes & Gray (McKeown, Matthew J. Rizzolo, Brendan F. McLaughlin, and Rebecca Gentilli were Roku's counsel in the IPR itself).

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Key sources

• Unified Patents PTAB portal – IPR2022-00943 case/counsel entries (portal.unifiedpatents.com/ptab/case/IPR2022-00943)
• PTAB filing (Dec. 14, 2022, Patent Owner objections) showing James J. Lukas, Jr., Greenberg Traurig, as Counsel for Patent Owner, and Ropes & Gray (McKeown/Rizzolo/McLaughlin/Gentilli) for Roku (ptacts.uspto.gov)
• DocketAlarm IPR2022-00943 docket (PHV motion/order for Erik M. Bokar; notices of appeal; hearing transcript)
• UEI's Updated Mandatory Notices in companion IPR2022-01289 listing the GT/Alston back-up roster (ptacts.uspto.gov)
• Alston & Bird attorney bios (Thomas W. Davison; Katherine G. Rubschlager)
• Justia docket, Roku, Inc. v. Universal Electronics, Inc. et al., 8:21-cv-00658 (C.D. Cal.) (stipulation to stay filed by Koppelman; case terminated)
• Justia/Federal Circuit opinion, Universal Electronics, Inc. v. Roku, Inc., No. 24-1426 (Fed. Cir. Apr. 10, 2026); CourtListener appearance entries for Lukas/Jarosik/Gilford (UEI) and McKeown/DiMarco (Roku)

Bottom line: If by "defendant" you mean Universal Electronics Inc., its lead PTAB counsel in IPR2022-00943 was James J. Lukas, Jr. (Greenberg Traurig, Chicago), backed by GT and Alston & Bird attorneys including Jarosik, Gilford, Sand, Mathews, Pleune, Davison, and Koppelman, with Erik M. Bokar admitted pro hac vice. In the literal infringement case where UEI is the defendant (C.D. Cal. 8:21-cv-00658), UEI's counsel of record were Thomas W. Davison, Ryan W. Koppelman, and Katherine G. Rubschlager of Alston & Bird, though that case was stayed and administratively closed in June 2021. If you intended the other side (Roku), say so and I'll rerun the analysis for Roku's counsel (Ropes & Gray in this IPR; Sterne, Kessler in other UEI–Roku IPRs).