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UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

NEODRON, LTD., 

 Plaintiff, 

 v. 

APPLE, INC., 

 Defendant. 

Case No. 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

AGAINST APPLE, INC. 

This is an action for patent infringement arising under the Patent Laws of the United States 

of America, 35 U.S.C. §1 et seq., in which Plaintiff Neodron, Ltd. (“Plaintiff” or “Neodron”) 

makes the following allegations against Defendant Apple, Inc. (“Defendant”): 

INTRODUCTION 

1. This complaint arises from Defendant’s unlawful infringement of the following 

United States patents owned by Neodron, each of which generally relate to touchscreen 

technology: United States Patent Nos. 9,823,784 (“’784 Patent”); 7,821,502 (“’502 Patent”); and 

10,146,351 (“’351 Patent”) (collectively, the “Asserted Patents”). 

2. Touchscreen technology plays a ubiquitous and important role in countless 

electronic devices today. Beyond just providing greater usability to smartphones, tablets and 

notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars 

to the restaurants and stores we visit. 

3. But just a few decades ago, touchscreen technology could only be found in science 

fiction books and film. Although the underlying science behind touch technology can be traced 

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back to the 1940s, working touchscreens were not conceived and feasible until the mid-1960s, 

when the first finger-driven touchscreen was invented by E.A. Johnson in 1965 at the Royal Radar 

Establishment in Malvern, United Kingdom. Since then, it took several generations and major 

technological advancements for touchscreens to achieve the level of complexity—and 

convenience—we see and enjoy today.

4. Built on the fundamental breakthrough that our hands and fingers can form changes 

in the capacitance of electrodes and electrode-connections when they are in close proximity to 

them, touch technology has developed rapidly over the years. Along the way, engineers have 

worked tirelessly to try to overcome the limitations and roadblocks touch technology presents. 

From conceiving various ways to detect (and correctly ignore) unintentional touches, to 

minimizing signal “noise,” to reducing the latency and power consumption that comes with any 

complex, multi-part electrical process, there have been many advances to various aspects of the 

technology—each building a little on a related advancement before it—to get us to the highly 

advanced state we enjoy today.

5. These advancements range from fundamental ones, which make basic touch 

technology work, to optional improvements, which typically represent one technological option 

that improves aspects of the user experience and functionality of a touchscreen. This infringement 

action is about the latter: several patented improvements—which took years of research and 

millions of dollars in U.S. investments to develop, and which are infringed by Defendant’s accused 

products. 

PARTIES

6. Plaintiff Neodron, Ltd. is an Irish company, having its principal place of business 

at Unit 4-5, Burton Hall Road, Sandyford, Dublin 18, D18a094. Neodron is the sole owner by 

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assignment of all right, title, and interest in each Asserted Patent.

7. On information and belief, Defendant Apple Inc. is a publicly traded corporation 

organized under the laws of the State of California, with its principal place of business at One 

Apple Park Way, Cupertino, CA 95014.

JURISDICTION AND VENUE

8. This action arises under the patent laws of the United States, Title 35 of the United 

States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 

1338 (a).

9. This Court has personal jurisdiction over Defendant in this action because 

Defendant has committed acts within this District giving rise to this action, and has established 

minimum contacts with this forum such that the exercise of jurisdiction over Defendant would not 

offend traditional notions of fair play and substantial justice. Defendant, directly and through 

subsidiaries or intermediaries, has committed and continues to commit acts of infringement in this 

District by, among other things, importing, offering to sell, and selling products that infringe the 

asserted patents.

10. Venue is proper in this District under 28 U.S.C. §1400 (b). Defendant is registered 

to do business in Texas, and upon information and belief, Defendant has transacted business in 

this District and has committed acts of direct and indirect infringement in this District by, among 

other things, importing, offering to sell, and selling products that infringe the asserted patents. 

Defendant has regular and established places of businesses in this District, including at 12545 

Riata Vista Cir., Austin, Texas 78727; 12801 Delcour Dr., Austin, Texas 78727; and 3121 Palm 

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Way, Austin, Texas 78758.

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COUNT I

INFRINGEMENT OF U.S. PATENT NO. 9,823,784

11. Neodron realleges and incorporates by reference the foregoing paragraphs as if 

fully set forth herein.

12. Neodron owns by assignment all rights, title, and interest in U.S. Patent No. 

9,823,784, entitled “Capacitive Touch Screen with Noise Suppression.” The ’784 Patent was duly 

and legally issued by the United States Patent and Trademark Office on November 21, 2017. A 

true and correct copy of the ’784 Patent is attached as Exhibit 1.

13. On information and belief, Defendant makes, uses, offers for sale, sells, and/or 

imports certain products (“Accused Products”), including smartphones and tablets such as the 

Apple iPhone 11 Pro Max and Apple iPad Pro 3rd Gen 12.9, that directly infringe, literally and/or 

under the doctrine of equivalents, claims 1-3 of the ’784 Patent. 

14. Defendant also knowingly and intentionally induces infringement of claims 1-3 of 

the ’784 Patent in violation of 35 U.S.C. §271 (b). Through the filing and service of this Complaint, 

Defendant has had knowledge of the ’784 Patent and the infringing nature of the Accused Products. 

Despite this knowledge of the ’784 Patent, Defendant continues to actively encourage and instruct 

its customers and end users (for example, through user manuals and online instruction materials 

on its website) to use the Accused Products in ways that directly infringe the ’784 Patent. 

Defendant does so knowing and intending that its customers and end users will commit these 

1 See, e.g., https://www.apple.com/newsroom/2019/11/apple-expands-in-austin/; 

https://goo.gl/maps/8Cr3zaxvwpePsWwL6; https://goo.gl/maps/UWFYdgUfZVFr8FG26;

https://www.apple.com/retail/domainnorthside/. 

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infringing acts. Defendant also continues to make, use, offer for sale, sell, and/or import the 

Accused Products, despite its knowledge of the ’784 Patent, thereby specifically intending for and 

inducing its customers to infringe the ’784 Patent through the customers’ normal and customary 

use of the Accused Products.

15. The Accused Products satisfy all claim limitations of claims 1-3 of the ’784 Patent. 

Claim charts comparing independent claim 1 of the ’784 Patent to representative Accused 

Products, the Apple iPhone 11 Pro Max and Apple iPad Pro 3rd Gen 12.9, are attached as Exhibits

2 and 3.

16. By making, using, offering for sale, selling and/or importing into the United States 

the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’784

Patent pursuant to 35 U.S.C. §271.

17. As a result of Defendant’s infringement of the ’784 Patent, Neodron is entitled to 

monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no 

event less than a reasonable royalty for the use made of the invention by Defendant, together with 

interest and costs as fixed by the Court.

18. Defendant’s infringing activities have injured and will continue to injure Neodron, 

unless and until this Court enters an injunction prohibiting further infringement of the ’784 Patent, 

and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that 

come within the scope of the patent claims.

COUNT II

INFRINGEMENT OF U.S. PATENT NO. 7,821,502

19. Neodron realleges and incorporates by reference the foregoing paragraphs as if 

fully set forth herein.

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20. Neodron owns by assignment all rights, title, and interest in U.S. Patent No. 

7,821,502 (the “’502 Patent”), entitled “Two-Dimensional Position Sensor.” The ’502 Patent was 

duly and legally issued by the United States Patent and Trademark Office on October 26, 2010. A 

true and correct copy of the ’502 Patent is attached as Exhibit 4.

21. On information and belief, Defendant makes, uses, offers for sale, sells, and/or 

imports certain products (“Accused Products”), including smartphones and tablets such as the 

Apple iPad Pro 3rd Gen 12.9, that directly infringe, literally and/or under the doctrine of 

equivalents, claims 1-24 of the ’502 Patent.

22. Defendant also knowingly and intentionally induces infringement of claims 1-24 of 

the ’502 Patent in violation of 35 U.S.C. §271 (b). Through the filing and service of this Complaint, 

Defendant has had knowledge of the ’502 Patent and the infringing nature of the Accused Products.

Despite this knowledge of the ’502 Patent, Defendant continues to actively encourage and instruct 

its customers and end users (for example, through user manuals and online instruction materials 

on its website) to use the Accused Products in ways that directly infringe the ’502 Patent. 

Defendant does so knowing and intending that its customers and end users will commit these 

infringing acts. Defendant also continues to make, use, offer for sale, sell, and/or import the 

Accused Products, despite its knowledge of the ’502 Patent, thereby specifically intending for and 

inducing its customers to infringe the ’502 Patent through the customers’ normal and customary 

use of the Accused Products.

23. The Accused Products satisfy all claim limitations of claims 1-24 of the ’502 Patent. 

A claim chart comparing independent claim 1 of the ’502 Patent to representative Accused 

Product, the Apple iPad Pro 3rd Gen 12.9, is attached as Exhibit 5.

24. By making, using, offering for sale, selling and/or importing into the United States 

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the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’502

Patent pursuant to 35 U.S.C. §271.

25. As a result of Defendant’s infringement of the ’502 Patent, Neodron is entitled to 

monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no 

event less than a reasonable royalty for the use made of the invention by Defendant, together with 

interest and costs as fixed by the Court.

26. Defendant’s infringing activities have injured and will continue to injure Neodron, 

unless and until this Court enters an injunction prohibiting further infringement of the ’502 Patent, 

and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that 

come within the scope of the patent claims.

COUNT III

INFRINGEMENT OF U.S. PATENT NO. 10,146,351

27. Neodron realleges and incorporates by reference the foregoing paragraphs as if 

fully set forth herein.

28. Neodron owns by assignment all rights, title, and interest in U.S. Patent No. 

10,146,351 (the “’351 Patent”), entitled “Position-Sensing and Force Detection Panel.” The ’351

Patent was duly and legally issued by the United States Patent and Trademark Office on December 

4, 2018. A true and correct copy of the ’351 Patent is attached as Exhibit 6.

29. On information and belief, Defendant makes, uses, offers for sale, sells, and/or 

imports certain products (“Accused Products”), including smartphones and laptops such as the 

Apple iPhone Xs and Apple Macbook Pro 13, that directly infringe, literally and/or under the 

doctrine of equivalents, claims 1-10 of the ’351 Patent. 

30. Defendant also knowingly and intentionally induces infringement of claims 1-10 of 

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the ’351 Patent in violation of 35 U.S.C. §271 (b). Through the filing and service of this Complaint, 

Defendant has had knowledge of the ’351 Patent and the infringing nature of the Accused Products. 

Despite this knowledge of the ’351 Patent, Defendant continues to actively encourage and instruct 

its customers and end users (for example, through user manuals and online instruction materials 

on its website) to use the Accused Products in ways that directly infringe the ’351 Patent. 

Defendant does so knowing and intending that its customers and end users will commit these 

infringing acts. Defendant also continues to make, use, offer for sale, sell, and/or import the 

Accused Products, despite its knowledge of the ’351 Patent, thereby specifically intending for and 

inducing its customers to infringe the ’351 Patent through the customers’ normal and customary 

use of the Accused Products.

31. The Accused Products satisfy all claim limitations of claims 1-10 of the ’351 Patent. 

Claim charts comparing independent claim 1 of the ’351 Patent to representative Accused 

Products, the Apple iPhone Xs and Apple Macbook Pro 13, are attached as Exhibits 7-8.

32. By making, using, offering for sale, selling and/or importing into the United States 

the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’351

Patent pursuant to 35 U.S.C. §271.

33. As a result of Defendant’s infringement of the ’351 Patent, Neodron is entitled to 

monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no 

event less than a reasonable royalty for the use made of the invention by Defendant, together with 

interest and costs as fixed by the Court.

34. Defendant’s infringing activities have injured and will continue to injure Neodron, 

unless and until this Court enters an injunction prohibiting further infringement of the ’351 Patent, 

and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that 

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come within the scope of the patent claims.

PRAYER FOR RELIEF

WHEREFORE, Neodron respectfully requests that this Court enter:

a. A judgment in favor of Neodron that Defendant has infringed, either literally and/or 

under the doctrine of equivalents, the ’784 Patent, the ’502 Patent, and the ’351 Patent;

b. A permanent injunction prohibiting Defendant from further acts of infringement of

the ’784 Patent, the ’502 Patent, and the ’351 Patent;

c. A judgment and order requiring Defendant to pay Neodron its damages, costs, 

expenses, and pre-judgment and post-judgment interest for Defendant’s infringement of the ’784 

Patent, the ’502 Patent, and the ’351 Patent; and

d. A judgment and order requiring Defendant to provide an accounting and to pay 

supplemental damages to Neodron, including without limitation, pre-judgment and post-judgment 

interest; 

e. A judgment and order finding that this is an exceptional case within the meaning 

of 35 U.S.C. §285 and awarding to Neodron its reasonable attorneys’ fees against Defendant; and

f. Any and all other relief as the Court may deem appropriate and just under the 

circumstances.

DEMAND FOR JURY TRIAL

Neodron, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of 

any issues so triable by right.

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Dated: March 23, 2020 Respectfully submitted,

/s/ Reza Mirzaie

Reza Mirzaie (CA SBN 246953)

rmirzaie@raklaw.com

Paul A. Kroeger (CA SBN 229074)

pkroeger@raklaw.com

Philip X. Wang (CA SBN 262239)

pwang@raklaw.com

Kent N. Shum (CA SBN 259189)

kshum@raklaw.com

RUSS AUGUST & KABAT

12424 Wilshire Blvd. 12th Floor

Los Angeles, CA 90025

Phone: (310) 826-7474

Attorneys for Plaintiff Neodron, Ltd.

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