Litigation

Universal Electronics, Inc. v. Roku, Inc.

Decided — affirmed

24-1426

Filed
2024-02-02
Terminated
2026-04-10

Patents at issue (1)

10930276PTAB: final decision

Defendants (1)

Summary

Universal Electronics appealed the PTAB's Final Written Decision invalidating challenged claims of the '276 patent. The Federal Circuit affirmed, rejecting UEI's arguments about the Board's adoption of a modification, the order of claimed method steps, and substantial evidence for the motivation-to-combine finding.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

Case Overview and Background

This appeal is the latest chapter in a long-running, multi-forum patent war, but it is not itself district-court infringement litigation — it is UEI's appeal from the PTAB in an inter partes review. Underlying the Federal Circuit case is IPR2022-00943, Roku, Inc. v. Universal Electronics Inc., in which Roku petitioned the PTAB on April 29, 2022 to invalidate U.S. Patent No. 10,930,276 (the "'276 patent"), UEI's "Apparatus, System and Method for Directing Voice Input in a Controlling Device" (filed as App. No. 15/861,298; European counterpart EP3428899). The Board instituted review on November 30, 2022 and issued a Final Written Decision on November 28, 2023 (APJ Sharon Fenick authoring; panel including APJ Patrick M. Boucher), holding claims 1–7, 9–13, 15, and 16 unpatentable as obvious over a combination of Hart-787 (U.S. Patent 9,251,787), Fu (U.S. Pub. 2017/0126192), and Rosenberg (U.S. Patent 9,509,269); claims 8 and 14 survived but were not appealed (Fed. Cir. Blog, Apr. 10, 2026; Unified Patents PTAB portal; Patexia). The claimed technology concerns a controlling device (e.g., a universal remote or smart-TV remote ecosystem) that receives wake-word–preceded voice input, routes the voice data to an identified voice-controlled smart appliance, and adjusts its audio output — specifically by comparing ambient noise against a threshold that can be set based on the device's operating environment (see CAFC opinion, J.A. 135–38, 143–44; EP abstract).

The parties are both operating companies locked in a broader infringement fight, not an NPE/PAE campaign. Universal Electronics Inc. (UEI), headquartered in Scottsdale, Arizona (and historically Cypress/Santa Ana, CA), is a public company (NASDAQ: UEIC) that designs and supplies universal remote controls, home-automation/control software (its "QuickSet" technology), and related intellectual property to TV and CE makers. Roku, Inc. is the San Jose-based streaming-platform company whose Roku streaming players, Roku TVs, remotes, and mobile app were the accused instrumentalities in the parallel infringement litigation. UEI sued Roku in the Central District of California (Universal Electronics Inc. v. Roku, Inc., No. 8:18-cv-01580, before Judge James V. Selna and Magistrate Judge Autumn D. Spaeth) on September 5, 2018, asserting nine UEI remote-control patents; UEI also pursued related ITC Investigation No. 337-TA-1200 and additional C.D. Cal. suits against TCL, Hisense, Funai, and others (Law360 via Sterne Kessler, Mar. 30, 2021; Unicourt; Unified Patents litigation portal). Roku responded with a coordinated PTAB campaign — including IPR2019-01612/01613, which invalidated UEI's '642 and '389 patents, and IPR2022-00943 against the '276 patent here. (Whether the '276 patent itself was asserted in the C.D. Cal. case or only targeted preemptively by Roku at the PTAB is not confirmed by my sources; the 2018 complaint predates the '276's 2021 issuance, and I could not verify a later amendment adding it.)

Why this case matters: The Federal Circuit's nonprecedential affirmance (No. 24-1426, argued Nov. 7, 2025, decided April 10, 2026, origin "PTO") is a clean appellate win for Roku that reinforces several pro-petitioner PTAB doctrines. The court rejected UEI's argument that the Board "adopted a modification advanced for the first time in Roku's reply," finding the challenged combination — Hart-787's audio-modification engine + Fu's predetermined-threshold comparison + Rosenberg's environment-based threshold — was articulated in the petition itself. It rejected UEI's step-ordering attack because UEI attacked Rosenberg in isolation rather than the combination (citing In re Merck, 800 F.2d 1091, 1097), and it upheld the Board's motivation-to-combine finding under substantial evidence, applying the settled rule that a petitioner need only show the combination was a "suitable option," not the best option, and that each reference need not address the same problem (VitalLaw IP Law Daily, Apr. 14, 2026; CAFC opinion at *11–13). The case is also notable as part of UEI's broader assertion strategy against streaming-TV/remote-control OEMs — UEI has had mixed results, including a Federal Circuit affirmance in its favor in an earlier Roku appeal of a different PTAB decision (see Knobbe Martens summary of the Newman/Reyna/Stoll panel, with Judge Newman dissenting on the standard of review) and PTAB invalidation of other UEI remote-control patents. Here, however, the affirmance means the '276 patent's challenged claims are dead, further narrowing UEI's enforcement portfolio against Roku and, potentially, other voice-control product makers in the same ecosystem. Panel composition for 24-1426 is not confirmed in my search results; the opinion is designated nonprecedential and is available on the CAFC website and Justia/CourtListener (docket entries: notice of appeal filed in IPR2022-00943 on Jan. 29, 2024; CAFC appeal docketed Feb. 2, 2024; oral-argument audio posted Nov. 7, 2025).

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

Key Legal Developments — Universal Electronics, Inc. v. Roku, Inc., No. 24-1426 (Fed. Cir.)

Important framing up front

Before listing "developments," a necessary correction on case characterization: No. 24-1426 is not a district-court patent infringement action. It is Universal Electronics, Inc.'s ("UEI") appeal from a PTAB inter partes review Final Written Decision, with the Federal Circuit docket reflecting origin "PTO." See CAFC case page, https://www.cafc.uscourts.gov/04-10-2026-24-1426-universal-electronics-inc-v-roku-inc-opinion-24-1426-opinion-4-10-2026_2674386/ ("Origin: PTO"). The underlying merits contest was an IPR petition filed by Roku, Inc. against U.S. Patent No. 10,930,276 (the "'276 patent," titled "Apparatus, System and Method for Directing Voice Input in a Controlling Device").

Consequently, several items in the requested checklist (complaint/answer/counterclaims, Markman, jury trial, JMOL, fees) do not exist in this docket and were not part of this appeal. What exists instead is (1) the PTAB proceeding (IPR2022-00943), (2) the Federal Circuit appeal, and (3) a broader web of UEI–Roku district-court and ITC litigation, listed in the IPR pleadings, in which the parties' parallel disputes played out. The outline below covers each category accurately, with sourcing and clear flags where facts could not be verified.

1. Underlying PTAB IPR (the real "merits" forum for the '276 patent)

Petition and institution

  • 2022-04-29 — Roku filed its petition for inter partes review of the '276 patent, challenging claims 1–16 as obvious. Ground 1: claims 1–11 and 13–16 obvious over U.S. Patent No. 9,251,787 ("Hart-787") as modified by U.S. Pub. No. 2017/0126192 A1 ("Fu") and further in view of U.S. Patent No. 9,509,269 ("Rosenberg"); Ground 2: claim 12 obvious over Hart-787, Fu, Rosenberg, and U.S. Patent No. 9,466,286 ("Hart-286"). Roku supported the petition with the declaration of expert Bruce McNair. See Unified Patents PTAB case portal, IPR2022-00943, https://portal.unifiedpatents.com/ptab/case/IPR2022-00943; Roku petition (PTACTS copy).
  • 2022 — UEI filed a Patent Owner Preliminary Response, supported by a declaration of Dr. Michael S. Scordilis (acoustics/signal-processing expert). UEI's Mandatory Notices identify related litigation, including Universal Electronics, Inc. v. Roku, Inc., No. 8:18-cv-01580-JVS-ADS (C.D. Cal. 2018); Universal Electronics, Inc. v. Roku, Inc., No. 8:20-cv-00701-JVS-ADS (C.D. Cal. 2020); Roku, Inc. v. Universal Electronics, Inc., No. 8:21-cv-00658-JVS-ADS (C.D. Cal. 2021); and ITC Inv. Nos. 337-TA-1200 and 337-TA-1263 (see UEI Mandatory Notices, IPR2022-00943, PTACTS).
  • 2022-11-30 — PTAB instituted IPR2022-00943 on both grounds. (Institution date per Unified Patents portal.)
  • 2023 — UEI filed its Patent Owner Response; Roku filed a Reply. Roku's expert Bruce McNair was deposed 2023-02-10. UEI's UEI expert declaration (Scordilis) and McNair deposition transcript are in the record (Exs. 2005–2006). UEI argued, among other things, that the proposed Hart-787/Fu/Rosenberg combination reflected improper hindsight, that the references did not disclose the claimed threshold/order-of-steps limitations, and that a skilled artisan would lack motivation to combine.

Final Written Decision

  • 2023-11-28 — PTAB issued its Final Written Decision holding claims 1–7, 9–13, 15, and 16 of the '276 patent unpatentable as obvious (14 claims). The Board found the petition's combination (Hart-787's audio-modification engine + Fu's predetermined-threshold voice-environment adjustment + Rosenberg's teaching that the threshold may be determined based on ambient signal volume) was supported by a reasoned motivation to combine, and rejected UEI's arguments that the combination was an untimely new theory or failed the claimed step ordering. Roku, Inc. v. Universal Elecs., Inc., No. IPR2022-00943, 2023 WL 8242606 (P.T.A.B. Nov. 28, 2023). Two claims (8 and 14) were not held unpatentable and were not before the Federal Circuit. See Fed Circuit Blog, "Opinions & Orders – April 10, 2026," https://fedcircuitblog.com/2026/04/10/opinions-orders-april-10-2026/ (characterizing the appealed decision and noting claims 1–7, 9–13, 15, 16).

2. Federal Circuit appeal — No. 24-1426

Filing and briefing

  • 2024-02-02 — UEI's appeal (notice of appeal / docket opening) in the Federal Circuit, No. 24-1426, appealing the PTAB Final Written Decision under the IPR appeal provisions. (Docket "filed" date per case metadata; consistent with the 63-day appeal window after the 2023-11-28 decision.)
  • 2024–2025 — Full merits briefing. UEI's opening brief pressed two principal arguments: (1) the Board improperly adopted a modification to the prior-art combination that Roku allegedly advanced for the first time in its reply, violating the Administrative Procedure Act/notice requirements; and (2) the Board's motivation-to-combine finding was legally erroneous and unsupported by substantial evidence. UEI also argued the combination failed to perform the claimed method steps in the required order (threshold established only after speech input is received/processed, contrary to claim 1). See Universal Elecs., Inc. v. Roku, Inc., No. 24-1426, slip op. at 5–7 (Fed. Cir. Apr. 10, 2026) (summarizing UEI's arguments); Justia copy, https://law.justia.com/cases/federal/appellate-courts/cafc/24-1426/24-1426-2026-04-10.html.
  • Counsel: Roku was represented by Scott McKeown (Wolf, Greenfield & Sacks, P.C.) at oral argument; the opinion and Vitallaw's summary also reference Wolf Greenfield and Greenberg Traurig among counsel/firms associated with the matter. (See oral-argument audio and Vitallaw "IP Law Daily" summary, Apr. 14, 2026.) I could not independently verify UEI's appellate counsel from the public sources retrieved; do not treat firm names as definitive for UEI.

Oral argument

Decision — affirmance

  • 2026-04-10 — The Federal Circuit issued a nonprecedential opinion affirming the PTAB. Universal Elecs., Inc. v. Roku, Inc., No. 24-1426 (Fed. Cir. Apr. 10, 2026), https://cafc.uscourts.gov/opinions-orders/24-1426.OPINION.4-10-2026_2674386.pdf. Holdings:
    1. No untimely new theory. The Board did not adopt a modification advanced for the first time in Roku's reply; Roku's petition expressly proposed "further modify[ing] the combination of Hart-787 and F[u] to apply a threshold determined according to an environmental noise level, as disclosed by Rosenberg." Slip op. at 5–6.
    2. UEI's order-of-steps argument failed to address the actual combination. The combination used only Rosenberg's teaching that a threshold may be set based on volume, relying on Fu (and Hart-787) for use of that threshold; attacking references individually cannot defeat a combination-based obviousness ground (In re Merck & Co., 800 F.2d 1091, 1097 (Fed. Cir. 1986)). Slip op. at 6.
    3. Substantial evidence supported motivation to combine. The Board's finding — that Rosenberg's dynamic, environment-derived threshold was at least a suitable option supplying what Hart-787/Fu left to the skilled artisan (preset thresholds vs. changing-environment adaptation) — was supported by Roku's petition and the McNair declaration. Slip op. at 7–8 (citing Decision at *13; J.A. 137–38, 148, 831–32 ¶91, 847 ¶108).
  • The decision is summarized at Fed Circuit Blog, "Opinions & Orders – April 10, 2026," and Vitallaw, "PTAB's invalidation of voice input control patent claims affirmed on appeal" (Apr. 14, 2026). Case status per metadata: terminated/decided — affirmed (2026-04-10). No rehearing, certiorari, or mandate-stage developments were found in the sources retrieved.

3. District-court infringement dockets (parallel UEI–Roku disputes)

The Federal Circuit matter was not a district-court infringement suit, but UEI and Roku have parallel infringement/declaratory litigation in the Central District of California (assigned to Judge James V. Selna, Magistrate Judge Autumn D. Spaeth), which UEI itself identified as related in the IPR:

  • Universal Electronics, Inc. v. Roku, Inc., No. 8:18-cv-01580-JVS-ADS (C.D. Cal., filed 2018) — UEI's first-round infringement suit against Roku; earlier UEI v. Roku litigation over remote-control patents; related IPRs were filed by Roku and a stay was in place for periods while PTAB petitions were resolved (LawStreetMedia reporting noted the 2018 suit was stayed pending IPRs).
  • Universal Electronics, Inc. v. Roku, Inc., No. 8:20-cv-00701-JVS-ADS (C.D. Cal., filed April 2020) — one of four companion suits UEI filed on/about 2020-04-09/15 against Roku, TCL, Hisense, and Funai (Alston & Bird representing UEI), tied to UEI's companion ITC complaint; asserted UEI remote-control patents including, per press and Law360 coverage of the Roku action, the '514, '486, '785, '196, and '317 patents in varying combinations.
  • Roku, Inc. v. Universal Electronics, Inc., No. 8:21-cv-00658-JVS-ADS (C.D. Cal. 2021) — Roku declaratory-judgment/action against UEI.

Caveat on the '276 patent specifically: None of the retrieved sources affirmatively confirmed which district-court complaint (if any) asserted the '276 patent against Roku or identified the docket on which the '276 patent was pleaded. The '276 patent issued from Application No. 15/861,298 and postdates the originally asserted patents in the 2020 C.D. Cal. wave. If the '276 patent was asserted by UEI against Roku in the C.D. Cal. cases (e.g., via amendment), that fact is not established by the sources I retrieved, and I do not want to fabricate a complaint/answer docket-entry string. What is established: Roku's IPR petition on the '276 patent was filed 2022-04-29, and the IPR docket (and UEI's mandatory notices) demonstrates the IPR was a weapon in the parties' broader UEI–Roku dispute.

4. ITC proceedings (parallel)

  • Inv. No. 337-TA-1200 — UEI's § 337 investigation against Roku and others (complaint 2020) concerning UEI's "QuickSet"-related remote-control/streaming patents (including the '196 patent). The Commission found a violation; the Federal Circuit affirmed Roku's ITC loss in Roku, Inc. v. ITC, No. 2022-1386 (Fed. Cir. Jan. 19, 2024) (opinion by Judge Hughes, joined by Judges Dyk and Stoll).
  • Inv. No. 337-TA-1263 — Roku's § 337 investigation against UEI and TV maker/operator respondents (instituted 2021-05-14 based on Roku's complaint alleging infringement of U.S. Patent Nos. 8,378,875 and 7,388,511); the ITC found no violation (final ID June 28, 2022; Commission review notice, 87 Fed. Reg. 61,680 (Oct. 12, 2022)).
  • Neither ITC investigation involved the '276 patent as such, but they are part of the same UEI–Roku patent war and were disclosed as related matters in the IPR.

5. Discovery milestones of strategic significance

Because the contested merits were decided in the IPR (not a district court), the significant "discovery" events are the PTAB's expert discovery:

  • 2023-02-10 — Deposition of Roku's expert, Bruce McNair (Ex. 2006 to UEI's IPR filings), whose declaration (Ex. 1003) supplied the motivation-to-combine and combination-teaching testimony the Board ultimately credited and the Federal Circuit found sufficient. The Federal Circuit expressly relied on McNair's declaration paragraphs (J.A. 828–32, ¶¶ 88–91; J.A. 847 ¶ 108) in affirming.
  • UEI's expert, Dr. Michael S. Scordilis, submitted declarations in support of both the Preliminary Response (Ex. 2001) and Patent Owner Response (Ex. 2005), opining that the asserted combinations failed to disclose every limitation and reflected hindsight.
  • No district-court discovery milestones (e.g., fact-deposition cutoffs, claim-construction discovery) were verifiable from the retrieved sources for any '276-specific district court case, because no such '276 infringement docket was confirmed.

6. Claim construction, motions practice, trial, and post-trial events

Not applicable to this docket in the district-court sense:

  • No complaint/answer/counterclaims — the case at the Federal Circuit is an appeal from the PTAB, not a trial-court pleading.
  • No Markman/claim construction order — the Board resolved the dispute on obviousness; no claim-construction dispute was presented on appeal.
  • No motions to dismiss/transfer/stay/summary judgment — those categories do not apply to an IPR appeal. (In the related C.D. Cal. infringement cases, stays pending IPRs and Fintiv-based PTAB denials occurred — e.g., Roku obtained invalidation of the '785 patent in IPR2021-00758 in September 2022 and of the '514 patent, while PTAB declined to institute on the '196 and '317 patents citing the advanced ITC litigation — but those matters concern different UEI patents, not the '276 patent.)
  • No trial, verdict, or JMOL/new-trial/fee motion in this case.

7. Final disposition / present posture

  • 2023-11-28 — PTAB Final Written Decision: '276 claims 1–7, 9–13, 15, 16 invalid as obvious (IPR2022-00943, 2023 WL 8242606).
  • 2024-02-02 — UEI appeal docketed in the Federal Circuit (No. 24-1426).
  • 2025-11-07 — Oral argument heard (audio posted).
  • 2026-04-10 — Federal Circuit affirmed in a nonprecedential opinion; case terminated/decided. Status: Affirmed (UEI lost; the PTAB's invalidation of the '276 patent claims stands).
  • Practical effect on the broader UEI–Roku dispute: with the '276 patent's challenged claims invalidated and the affirmance final, those claims cannot be enforced against Roku (estoppel and finality under the IPR framework). No petition for rehearing or certiorari was identified in the retrieved sources.

Sources relied upon

Verification caveats: (1) The specific district-court docket (if any) in which the '276 patent was asserted against Roku could not be confirmed from retrieved sources and is not described above as fact. (2) UEI's appellate counsel and the Federal Circuit panel composition were not confirmed in the retrieved materials and are omitted. (3) All dates other than those anchored to the cited opinions/dockets are approximations flagged as such.

In the news

What the press has reported about this case, summarized with links to the source articles.

I'll search across multiple angles to find press and analyst coverage of this appeal.

Press and analyst coverage of Universal Electronics, Inc. v. Roku, Inc., No. 24-1426

Coverage of this specific appeal is thin and almost entirely confined to legal trade press and practitioner blogs — no Reuters, Bloomberg Law, Law360, Ars Technica, or mainstream consumer-tech outlet article about the April 10, 2026 decision surfaced in my searches. The most substantive item is the IP Law Daily analysis at VitalLaw (by Justin Marcus Smith, J.D.), published April 14, 2026, under the headline "PATENT—Fed. Cir.: PTAB's invalidation of voice input control patent claims affirmed on appeal." It accurately reports the disposition as nonprecedential, states that UEI appealed the Board's holding that "14 specific claims of U.S. Patent No. 10,930,276 … were unpatentable as obvious," and notes that two further claims (8 and 14) survived below but "were not at issue on appeal." The same outlet ran a companion piece on May 15, 2026 covering UEI's other Roku appeal, No. 24-1856 (the '083 patent, decided May 13, 2026, claim-construction issue) — that one VitalLaw piece is often returned alongside the '276 analysis and can be mistaken for coverage of this case. The Fed Circuit Blog "Opinions & Orders – April 10, 2026" post is the only same-day write-up I located; it is a short summary identifying the patent, the challenged claims (1–7, 9–13, 15, and 16), the IPR number (IPR2022-00943, 2023 WL 8242606), and the affirmance, without independent analysis.

The trade coverage frames significance in doctrinal terms rather than commercial ones. VitalLaw breaks the opinion into four pro-petitioner takeaways: (1) the Board's adopted reasoning was "not untimely because the Roku, Inc. inter partes petition articulated the reasoning from inception"; (2) UEI "raised an argument that did not address the combination of prior art references that Roku … proposed"; (3) substantial evidence supported the motivation to combine; and (4) Roku "only needed to show the combination was a suitable option, it did not have to be the best option," with no requirement that every reference address the same known problem. Notably, a broader aggregator write-up at ScaleJuris treats the UEI–Roku PTAB affirmances as a cluster, describing a district-court case "which has been stayed pending the outcome of the PTAB proceedings" in which "UEI accused Roku of infringing nine of its patents," and reporting that of six patents that went to institution, "claims were found to be invalid in five of them." That framing is about the campaign as a whole and should not be read as specific to the '276 patent.

Reported numbers for this appeal: essentially none. I found no article reporting damages sought or awarded, settlement terms, or market impact attributable to No. 24-1426 — unsurprising, because the appeal resolves validity at the PTAB and carries no damages award. The only monetary/financial angle in the surrounding coverage is a UEI press release (Jan. 19, 2024) about a different patent: the Federal Circuit's affirmance of the ITC exclusion order on U.S. Patent No. 10,593,196, in which UEI SVP & General Counsel Richard A. Firehammer, Jr. said the ruling "paves the way for UEI to return to the U.S. District Court and collect money damages for the infringing activities of Roku and its TV partners," adding that Roku "will not be able to import or sell any infringing products in United States until this key UEI patent expires in 2032." That is a party statement about the '196 ITC win, not the '276 appeal, and it is advocacy rather than independent reporting; the earlier-generated sections of this case summary correctly treat it as such. For analyst-style commentary that goes beyond the court record, PatSnap published a piece on UEI v. Roku concerning U.S. Patent No. 9,641,785 (Fed. Cir. No. 23-1198, Rule 36 affirmance), asserting that "the affirmance of unpatentability reinforces the vulnerability of device-configuration patents in Federal Circuit review" and that "Roku can operate its device-configuration and remote-pairing features without licensing obligations" — an inferential industry take, not record-based reporting, and again about a different patent and appeal.

Two caveats worth flagging. First, on the historical coverage of this litigation (useful context, but not about the '276 appeal): Law360 pieces reprinted by Sterne Kessler (Britain Eakin, Sept. 23, 2022, on the '785 patent and the Fintiv-based denials of the '196/'317 petitions) and Sterne Kessler (Andrew Karpan, Aug. 18, 2023, on Judge Newman's opinion affirming Roku's PTAB wins, naming UEI's counsel as "Michael Anthony Nicodema, Benjamin Gilford and James J. Lukas Jr. of Greenberg Traurig LLP" and Roku's as "Jon Wright, Richard Crudo and Lestin L. Kenton of Sterne Kessler … and Jonathan Daniel Baker and Michael David Saunders of Dickinson Wright PLLC") show that Law360 was actively covering this campaign — yet I could not locate a Law360 article on the April 10, 2026 '276 affirmance itself, so I cannot represent that Law360 covered it. Second, the two previously generated "representatives" sections of this case summary conflict with each other and with the record I retrieved: one states Roku's counsel is "Ropes & Gray LLP" with Scott A. McKeown and describes Matthew Rizzolo as Roku's counsel, while the other states McKeown is Wolf, Greenfield & Sacks and Rizzolo is Greenberg Traurig/UEI-side. The record supports the latter: the Federal Circuit opinion in the companion appeal No. 24-1856 lists "SCOTT ANTHONY MCKEOWN, Wolf, Greenfield & Sacks, PC … argued for cross-appellant," and the CourtListener audio transcript for No. 24-1426 identifies "Scott McKeown on behalf of Roku, Inc." I found no press report identifying UEI's arguing counsel in No. 24-1426.

Bottom line on press coverage: this appeal attracted a single detailed trade-press analysis (VitalLaw/IP Law Daily), one same-day blog summary (Fed Circuit Blog), and indirect mention in campaign-level roundups, with no mainstream, business, or consumer-tech coverage and no reported dollar figures. The gap between the volume of coverage of the earlier ITC/'196 win and the near-silence on this nonprecedential IPR affirmance is itself a fair signal of how the press viewed the stakes here.

Sources

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Important framing note

There is no pending district-court "infringement case" in this docket entry. No. 24-1426 is UEI's Federal Circuit appeal of the PTAB's Final Written Decision in IPR2022-00943 (Roku was the IPR petitioner; UEI the patent owner and appellant here). The metadata's "Plaintiff: Universal Electronics, Inc." therefore maps to UEI as the appellant/patent owner, and the counsel of record below and on appeal are UEI's Greenberg Traurig–led team (the same team that has represented UEI throughout the UEI–Roku PTAB wars). Do not be misled by the name "Matthew Rizzolo" appearing on the Justia docket for 24-1426: he is Roku's counsel (Ropes & Gray), not UEI's.

Counsel of record for Universal Electronics, Inc. (appellant / patent owner)

On the Federal Circuit appeal (24-1426)

  • James J. Lukas, Jr. — Lead counsel of record for UEI (appellant). Greenberg Traurig LLP, Chicago (77 West Wacker Drive, Suite 3100; USPTO Reg. No. 59,114). Listed as counsel on the 24-1426 CAFC docket (Justia docket, retrieved Feb. 2, 2024); was UEI's designated lead counsel throughout IPR2022-00943 (PTAB filings, e.g., Dec. 14, 2022 paper signed by Lukas "Counsel for Patent Owner"). Notable: UEI's lead in the broader Roku/UEI patent battles since at least 2011 (including C.D. Cal. pro hac vice appearances for UEI before Judge Selna); argued the earlier UEI win at the Federal Circuit in In re Universal Electronics, Inc., No. 22-1718 (Fed. Cir. June 7, 2023), where the court listed him as arguing counsel with Benjamin Gilford, Gary Jarosik, and Matthew Levinstein also of record.
  • Benjamin P. Gilford — Co-counsel/back-up on the appeal and below. Greenberg Traurig LLP, Chicago (Reg. No. 72,072). Appeared for UEI in IPR2022-00943 and in the parallel UEI/Roku CAFC appeal No. 24-1856 (entry of appearance docketed June 6, 2024). Notable: Argued UEI's companion appeal in Universal Electronics, Inc. v. Roku, Inc., No. 24-1856 (Fed. Cir., argued, decided May 13, 2026), per VitalLaw's case report ("Benjamin Gilford, Greenberg Traurig LLP, Chicago, IL, argued for appellant; also represented by Gary R. Jarosik, James J. Lukas, Jr."). Whether Gilford or another GT attorney handled the Nov. 7, 2025 oral argument in 24-1426 is not confirmed by my sources (the CAFC oral-argument posting names only the parties; the audio identifies Roku's advocate as Scott McKeown but not UEI's).
  • Gary R. Jarosik — Co-counsel/back-up. Greenberg Traurig LLP, Chicago (Reg. No. 35,906). Back-up counsel in IPR2022-00943; entered appearance for UEI on the companion CAFC appeal 24-1856; was also of record in In re Universal Electronics, 22-1718.

Of record in the underlying IPR2022-00943 (back-up / supporting patent-owner team)

  • Olivia C. Schmitz — Back-up counsel. Greenberg Traurig LLP, Chicago (Reg. No. 80,801). Listed on UEI's counsel table in IPR2022-00943.
  • Erik M. Bokar — Back-up counsel (pro hac vice). Greenberg Traurig, P.A., Orlando, FL. Listed on UEI's counsel table in IPR2022-00943.
  • S. Benjamin Pleune — Back-up counsel. Alston & Bird LLP, Charlotte, NC (Reg. No. 52,421). Listed on UEI's counsel table in IPR2022-00943; experienced PTAB litigator.
  • Thomas W. Davison — Back-up counsel. Alston & Bird LLP, Washington, DC (Reg. No. 57,160). Listed on UEI's IPR counsel table.
  • Ryan W. Koppelman — Back-up counsel. Alston & Bird LLP, Los Angeles (Reg. No. 58,307). Listed on UEI's IPR counsel table.
  • Dan O'Connor — Back-up counsel. Alston & Bird LLP, East Palo Alto, CA (Reg. No. 69,023). Listed on UEI's IPR counsel table.

For disambiguation — Roku's counsel (not UEI's)

Roku was represented by Ropes & Gray LLP — lead PTAB counsel Scott A. McKeown (Washington, DC; Reg. No. 42,866), with Matthew J. Rizzolo, Brendan F. McLaughlin (Washington, DC) and Rebecca Gentilli (Boston) as back-up (IPR2022-00943 filings). McKeown argued for Roku at the Nov. 7, 2025 Federal Circuit argument. Rizzolo's name appearing on the 24-1426 Justia docket reflects Roku's appellee representation, not UEI's.

Gaps / caveats

  • Who argued for UEI on Nov. 7, 2025 in 24-1426 is unconfirmed in the sources available to me (opinion PDFs, Justia, CAFC oral-argument page, and news coverage name the party but not UEI's arguing attorney). The GT team above (Lukas, Gilford, Jarosik) is the established UEI appellate/PTAB group.
  • No in-house UEI counsel was identified in my searches as counsel of record for these proceedings; I did not find a GT "local counsel" designation for the CAFC appeal because CAFC practice does not require one.
  • If by "plaintiff" you meant UEI's counsel in the underlying C.D. Cal. infringement action (No. 8:18-cv-01580, Judge Selna), that is a different representation roster and is not confirmed from the PTAB/CAFC record; UEI's GT lead Lukas has, however, historically appeared pro hac vice for UEI in C.D. Cal. actions before Judge Selna with local counsel designations (e.g., an earlier 2011 UEI matter designating Wendy M. Mantell as local counsel).

Bottom line: UEI's counsel of record are James J. Lukas, Jr. (lead, Greenberg Traurig/Chicago) with GT colleagues Benjamin P. Gilford, Gary R. Jarosik, Olivia C. Schmitz, and Erik M. Bokar, plus an Alston & Bird back-up team (Pleune, Davison, Koppelman, O'Connor) at the PTAB — all of whom represented the "plaintiff"/patent-owner side in the proceeding underlying this affirmed Federal Circuit decision.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Counsel of record for Roku, Inc. (defendant/appellee side) in No. 24-1426

Important framing caveat up front: No. 24-1426 is not a district-court patent infringement case. It is UEI's Federal Circuit appeal from the PTAB's Final Written Decision in IPR2022-00943 (Roku was the IPR petitioner; UEI was patent owner). On the appellate caption, UEI is the appellant and Roku, Inc. is the appellee (Justia docket: "Appellant: Universal Electronics, Inc. … Appellee: Roku, Inc."). So the "defendant-side" party whose counsel you're asking about is Roku, Inc., as appellee — and the USPTO Director does not appear as a separately captioned appellee in this docket.

What I can verify about counsel in this appeal

Appellant UEI's counsel (for context, to avoid confusion): The Justia docket for 24-1426 lists James J. Lukas Jr. and Matthew Rizzolo as counsel of record on the docketed appeal (Docket entry 1, filed Feb. 2, 2024). Both are Greenberg Traurig attorneys who have represented UEI across this IPR war — e.g., in the sibling appeal No. 2024-1856 (IPR2022-01289), Greenberg Traurig's Benjamin Gilford argued for UEI "also represented by Gary R. Jarosik, James J. Lukas, Jr." (VitalLaw, May 13, 2026). These names, however, are on the appellant/UEI side, not Roku's.

Roku's appellee counsel in 24-1426: I was not able to verify from the available sources which specific attorneys appeared for Roku in appeal No. 24-1426 itself. The CAFC opinion (Justia/CourtListener, decided Apr. 10, 2026) is nonprecedential and does not list counsel in the retrieved text; the CAFC oral-argument audio page (argued Nov. 7, 2025) confirms only that the argument occurred; and the PACER docket for 24-1426 was last retrieved Feb. 2, 2024 by Justia, before appearances were fully fleshed out. I could not confirm from the search results the identity of Roku's arguing counsel or full appearance list for this specific appeal. I am not going to fabricate names for this docket.

Best-supported inferences for who likely appeared for Roku (unverified for 24-1426 specifically)

Roku's Federal Circuit/PTAB counsel in the overlapping Universal Electronics battles has included three firms, any of which (or a combination) may have handled 24-1426:

  1. Sterne, Kessler, Goldstein & Fox PLLC (Washington, DC) — Roku's lead IPR/appellate firm in the parallel UEI disputes. Directors Richard A. Crudo (argued both 2023-1198 and 2023-1019 for Roku), Lestin L. Kenton Jr., William H. Milliken, Daniel S. Block, Jennifer Chagnon, and Counsel Sasha S. Rao were publicly identified as Roku's Federal Circuit/PTAB counsel (Sterne Kessler news releases, June 2024 and March 2025). Crudo argued the Roku-side appellee position in 2023-1198, the closest analogue (UEI appeal of a PTAB invalidation, summary affirmance June 11, 2024).
  2. Dickinson Wright PLLC — Jonathan Daniel Baker (Mountain View) and Michael David Saunders (Austin) were co-counsel for Roku in 2023-1198 and represented Roku in the ITC-related appeals (23-1317; also listed for Roku in 24-1188/24-1241).
  3. Wolf, Greenfield & Sacks PC — Scott A. McKeown (Washington, DC) argued Roku's cross-appeal in 2024-1856 (IPR2022-01289), with Elizabeth DiMarco and Boston-based John W. Custer — the most recent UEI v. Roku IPR appeal to reach decision (May 13, 2026).

Because 24-1426 (from IPR2022-00943) and 2024-1856 (from IPR2022-01289) were near-contemporaneous UEI appeals of PTAB invalidations in the same campaign, Wolf Greenfield or a Sterne Kessler/Dickinson Wright combination are the most plausible counsel configurations — but that is inference, not verified record, and I flag it as such.

Bottom line

  • Verified counsel of record on the 24-1426 docket are for appellant UEI (James J. Lukas Jr. and Matthew Rizzolo, Greenberg Traurig).
  • No verified counsel-of-record list for appellee Roku, Inc. in 24-1426 could be confirmed from the available PACER-derived docket, firm announcements, or opinion text in my searches.
  • If you need the definitive Roku appearance list (entries of appearance, appellee brief signature block, and oral-argument counsel), the reliable next step is PACER for case 24-1426 (entries after ~Feb. 2024, including the appellee brief filed in 2025) or the appellee brief PDF on the CAFC docket — the retrieved Justia docket snapshot stops at Feb. 2, 2024 and is stale.