UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

UNIVERSAL CONNECTIVITY 

TECHNOLOGIES INC.,

Plaintiff,

v.

LENOVO GROUP LIMITED,

Defendant.

Case No. 2:23-cv-449

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT 

AGAINST LENOVO GROUP LIMITED

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 Universal Connectivity Technologies Inc.

(“Plaintiff”) makes the following allegations against Defendant Lenovo Group Limited 

(“Defendant” or “Lenovo”):

INTRODUCTION

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

United States patents owned by Plaintiff: United States Patent Nos. 7,154,905 (“the ’905 Patent”),

7,187,307 (“the ’307 Patent”), 7,746,798 (“the ’798 Patent”), 9,232,265 (“the ’265 Patent”),

8,680,712 (“the ’712 Patent”), 7,856,520 (“the ’520 Patent”), 7,921,231 (“the ’231 Patent”), and 

9,852,103 (“the ’103 Patent”) (collectively, the “Asserted Patents”).

PARTIES

2. Plaintiff Universal Connectivity Technologies Inc. (“UCT”) is a Delaware 

corporation, with its principal place of business at 1891 Robertson Road, Suite 100, Ottawa, ON 

K2H 5B7, Canada. UCT is a wholly-owned subsidiary of Wi-LAN Technologies Inc., which is a 

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wholly-owned subsidiary of Wi-LAN Inc. (“WiLAN”) and is a Canadian corporation with a 

principal place of business at 1891 Robertson Road, Suite 100, Ottawa, ON K2H 5B7, Canada. 

UCT is the sole owner by assignment of all right, title, and interest in the Asserted Patents, 

including the right to recover for past, present, and future infringement. 

3. Defendant Lenovo Group Limited is a foreign company organized and existing 

under the laws of China, with its headquarters at 23rd Floor, Lincoln House, Taikoo Place, 979 

King’s Road, Quarry Bay, Hong Kong S.A.R. of China. Lenovo does business in Texas and in 

the Eastern District of Texas, directly or through intermediaries, such as its wholly-owned 

subsidiaries. Lenovo is responsible for importing, making, marketing, distributing, offering for 

sale, and/or selling Lenovo-branded laptops, desktops, monitors, docking stations, and adapters in 

the United States (directly or through its wholly-owned subsidiaries), including in this District. 

4. Lenovo induces its subsidiaries, affiliates, retail partners, and customers in the

making, using, selling, offering for sale, and/or importing throughout the United States, including

within this District, infringing products (such as Lenovo-branded laptops, desktops, monitors, 

docking stations, and adapters) and placing such products into the stream of commerce via

established distribution channels knowing or understanding that such products would be sold

and used in the United States, including in the Eastern District of Texas. Lenovo purposefully

directs the Accused Products into established distribution channels within this District and the U.S.

nationally. For example, Lenovo sells and offers to sell the Accused Products through its website, 

Lenovo.com, which may be accessed throughout the United States, the State of Texas, and this 

District. Additionally, Lenovo has authorized sellers and sales representatives that offer for sale 

and sell the Accused Products throughout the State of Texas and to consumers throughout this 

District, such as: Best Buy, 422 West Loop 281, Suite 100, Longview, Texas 75605; Costco 

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Wholesale, 3650 West University Drive, McKinney, Texas 75071; Office Depot, 422 West Loop 

281, Suite 300, Longview, Texas 75605; Target, 3092 North Eastman Road, Suite 100, Longview, 

Texas 75605; and Wal-Mart, 1701 East End Boulevard North, Marshall, Texas 75670.

5. Lenovo maintains a corporate presence in the United States via at least its whollyowned subsidiaries, including Lenovo (United States) Inc. (“Lenovo US”) and Lenovo Global 

Technology (United States) Inc. (“Lenovo Tech.”). 

6. Lenovo US is a corporation organized and existing under the laws of Delaware, 

with a corporate headquarters located at 1009 Think Place, Morrisville, NC 27560. Lenovo US is 

registered to do business in the State of Texas and may be served through CT Corporation System, 

1999 Bryan St., Ste. 900, Dallas, TX 75201. 

7. Lenovo Tech. is a corporation organized and existing under the laws of Delaware, 

with a corporate headquarters located at 1009 Think Place, Morrisville, NC 27560. Lenovo Tech.

is registered to do business in the State of Texas and may be served through CT Corporation 

System, 1999 Bryan St., Ste. 900, Dallas, TX 75201.

8. Lenovo and its U.S.-based subsidiaries (which act as part of a global network of 

sales and manufacturing subsidiaries) operate as agents of one another and vicariously as parts of 

the same business group to work in concert together. For example, in its 2022/23 Annual Report, 

Lenovo describes itself and its subsidiaries as follows: 

Ex. 1 at 192 (https://investor.lenovo.com//en/publications/reports.php). Lenovo identifies U.S.-

based subsidiaries (including but not limited to Lenovo US and Lenovo Tech.) in its list of 

“principal subsidiaries.” Id. at 279, 281. Lenovo describes its “principal subsidiaries” as follows: 

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Id. at 276. Lenovo identifies its 2023 “percentage of issued share capital held” for Lenovo US and 

Lenovo Tech. as “100%.” Id. at 279, 281. Further, Lenovo identifies the “principal activities” for 

Lenovo US as “[d]istribution of IT products” and the “principal activities” for Lenovo Tech. as 

“[p]rovision of IT services and distribution of IT products.” Id. As such, Lenovo US and Lenovo 

Tech. are agents of Lenovo. At the direction and control of Lenovo, U.S.-based subsidiaries

(including but not limited to Lenovo US and Lenovo Tech.) make, use, import, offer to sell, and/or

sell Lenovo-branded laptops, desktops, monitors, docking stations, and adapters that infringe the 

Asserted Patents, including in the State of Texas and this District. 

9. Lenovo, alone and through its U.S.-based subsidiaries (such as Lenovo US and 

Lenovo Tech.), places such infringing products into the stream of commerce via established 

distribution channels knowing or understanding that such products would be sold and used in the 

United States, including in the Eastern District of Texas. Lenovo has derived substantial revenue 

from infringing acts in the United States, including from the sale and use of infringing products.

See Ex. 1 at 225 (showing revenues for “Americas”)

(https://investor.lenovo.com//en/publications/reports.php). 

JURISDICTION AND VENUE

10. 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).

11. This Court has personal jurisdiction over Lenovo in this action because Lenovo has 

committed acts within Texas (and this District) giving rise to this action and has established 

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

offend traditional notions of fair play and substantial justice. Lenovo, directly and/or through 

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

District by, among other things, making, using, importing, offering to sell, and/or selling products 

that infringe the Asserted Patents. Courts in Texas have concluded that Lenovo is subject to 

personal jurisdiction in the State of Texas. See ACQIS LLC v. Lenovo Grp. Ltd., 572 F. Supp. 3d 

291, 307 (W.D. Tex. 2021) (“this Court finds that the exercise of personal jurisdiction over 

[Lenovo Group Limited] is both reasonable and fair.”); see also AX Wireless LLC v. Lenovo Grp. 

Ltd., No. 2:22-cv-00280-RWS-RSP, Dkt. No. 110 (report and recommendation) (E.D. Tex. Sept. 

6, 2023) (“exercising personal jurisdiction [over Lenovo Grp. Ltd.] would not offend traditional 

notions of fair place and substantial justice.”). 

12. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). Lenovo, 

directly and/or through subsidiaries or intermediaries, has transacted business in this District and 

has committed acts of direct infringement in this District by, among other things, making, using, 

offering to sell, selling, and importing products that infringe the Asserted Patents. Venue is also 

proper as to Lenovo because it is a foreign corporation organized under the laws of China and suits 

against foreign entities are proper in any judicial district. See 28 U.S.C. § 1391(c)(3); In re HTC 

Corp., 889 F.3d 1349 (Fed. Cir. 2018). 

COUNT I

INFRINGEMENT OF U.S. PATENT NO. 7,154,905

13. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

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14. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,154,905, titled 

“Method and system for nesting of communications packets.” The ’905 Patent was duly and 

legally issued by the United States Patent and Trademark Office on December 26, 2006. A true 

and correct copy of the ’905 Patent is attached as Exhibit 2.

15. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, monitors, and docking stations) that support DisplayPort 1.2 or later, such as 

the Qreator 27 UHD Smart Crystal Sound Wireless Charging Monitor, ThinkCentre M75s Gen 2 

Small Form Factor Desktop, ThinkPad USB-C Dock Gen 2 Docking Station, and Legion 7 Gen 6 

& 7 Gaming Laptop (“Accused Products”), that directly infringe, literally and/or under the doctrine 

of equivalents, one or more claims of the ’905 Patent. Identification of the Accused Products will 

be provided in Plaintiff’s infringement contentions disclosed pursuant to the Court’s scheduling 

order. Plaintiff’s identification of the Accused Products is not intended to accuse products where 

the infringement accusations are directed at products that are licensed by the license between Intel 

Corporation and WiLAN.

16. The Accused Products satisfy all claim limitations of one or more claims of the ’905

Patent. A claim chart comparing exemplary independent claim 21 of the ’905 Patent to 

representative Accused Products is attached as Exhibit 3.

17. On June 30, 2022, WiLAN sent Lenovo a letter indicating that certain Lenovo

products infringe at least claim 21 of the ’905 Patent and proposed times to discuss a potential 

license from UCT to practice the ’905 Patent. Ex. 4. On July 11, 2022, Lenovo’s licensing 

department confirmed receipt of the June 30 letter and indicated that it “would be happy to engage 

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in discussions” with WiLAN regarding a potential license. Ex. 5. Thereafter, WiLAN and Lenovo 

exchanged various emails and held numerous calls to discuss the UCT patents (including 

substantive discussions regarding the alleged infringement and validity of the patents), including 

calls on July 26, 2022, November 1, 2022, November 8, 2022, November 29, 2022, December 20, 

2022, January 24, 2023, January 31, 2023, February 14, 2023, and March 7, 2023. After extensive 

discussions between the parties, Lenovo ultimately declined to take a license, or even hear UCT’s 

offer for a license, on a call held on March 30, 2023. 

18. Lenovo knowingly and intentionally induces infringement of one or more claims 

of the ’905 Patent in violation of 35 U.S.C. § 271(b). As of at least July 11, 2022, Lenovo has 

knowledge of the ’905 Patent and the infringing nature of the Accused Products. Despite this 

knowledge of the ’905 Patent, Lenovo continues to actively encourage and instruct its customers 

and end users (for example, through online instruction and other online publications cited in 

Exhibit 3) to use the Accused Products in ways that directly infringe the ’905 Patent. For example, 

Lenovo advertises that its products are compatible with DisplayPort. See, e.g.,

https://www.lenovo.com/us/en/p/desktops/thinkcentre/m-series-sff/thinkcentre-m75s-gen2/11tc1mdm75s?orgRef=https%253A%252F%252Fwww.google.com%252F#tech_specs

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – Product Specification); 

https://www.lenovo.com/us/en/p/laptops/legion-laptops/legion-7-series/legion-7-gen-6-(16-inchamd)/len101g0011?orgRef=https%253A%252F%252Fwww.google.com%252F (Legion 7 Gen 6 

Gaming Laptop – Product Specification). Lenovo also instructs its customers and end users on 

how to use the Accused Products in an infringing manner, including through the use of 

DisplayPort. See, e.g., 

https://download.lenovo.com/pccbbs/thinkcentre_pdf/m75s_gen2_ug_en.pdf (ThinkCenter M75s 

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Gen 2 Small Form Factor Desktop – User Manual); 

https://download.lenovo.com/pccbbs/pubs/legion_7_16_6/html_en/index.html#t=EN%2Fcover.h

tml (Legion 7 Gen 6 Gaming Laptop – User Manual). Lenovo provides these instructions and 

materials knowing and intending (or with willful blindness to the fact) that its customers and end 

users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, sell, 

and/or import the Accused Products, despite its knowledge of the ’905 Patent, thereby specifically 

intending for and inducing its customers to infringe the ’905 Patent through the customers’ normal 

and customary use of the Accused Products.

19. Lenovo has also infringed, and continues to infringe, one or more claims of the ’905

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’905

Patent, are especially made or adapted to infringe the ’905 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least July 11, 2022, Lenovo

has knowledge of the ’905 Patent and the infringing nature of the Accused Products. Lenovo has 

been, and currently is, contributorily infringing the ’905 Patent in violation of 35 U.S.C. §§ 271(c) 

and/or (f). For example, the identified hardware and/or software components in Lenovo’s laptops, 

desktops, monitors, and docking stations that support DisplayPort 1.2 constitute a material part of 

the inventions claimed in the ’905 Patent, are especially made or adapted to infringe the ’905 

Patent, and are not staple articles or commodities of commerce suitable for non-infringing use, as 

demonstrated by the evidence cited above and in Exhibit 3. 

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’905 Patent 

pursuant to 35 U.S.C. § 271.

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21. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’905 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

22. As described above, Lenovo obtained knowledge of the ’905 Patent and that certain 

products infringe the ’905 Patent as of at least July 11, 2022, but has not ceased its infringing 

activities. Lenovo’s infringement of the ’905 Patent has been and continues to be willful and 

deliberate. Lenovo also has knowledge of the ’905 Patent by way of this complaint and, to the 

extent they do not cease their infringing activities, their infringement is and continues to be willful 

and deliberate.

23. As a result of Lenovo’s direct and indirect infringement of the ’905 Patent, Plaintiff 

is entitled to monetary damages (past, present, and future) in an amount adequate to compensate 

for Lenovo’s infringement, but in no event less than a reasonable royalty for the use made of the 

invention by Lenovo, together with interest and costs as fixed by the Court.

COUNT II

INFRINGEMENT OF U.S. PATENT NO. 7,187,307

24. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

25. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,187,307, titled 

“Method and system for encapsulation of multiple levels of communication protocol functionality 

within line codes.” The ’307 Patent was duly and legally issued by the United States Patent and 

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Trademark Office on March 6, 2007. A true and correct copy of the ’307 Patent is attached as 

Exhibit 6.

26. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, monitors, and docking stations) that support DisplayPort Version 1.0 or later,

such as the Qreator 27 UHD Smart C1ystal Sound Wireless Charging Monitor, ThinkCentre M75s 

Gen 2 Small Form Factor Desktop, Legion 7 Gen 6 & 7 Gaming Laptop, and ThinkPad USB-C 

Dock Gen 2 Docking Station (“Accused Products”), that directly infringe, literally and/or under 

the doctrine of equivalents, one or more claims of the ’307 Patent. Identification of the Accused 

Products will be provided in Plaintiff’s infringement contentions disclosed pursuant to the Court’s 

scheduling order. Plaintiff’s identification of the Accused Products is not intended to accuse 

products where the infringement accusations are directed at products that are licensed by the 

license between Intel Corporation and WiLAN.

27. The Accused Products satisfy all claim limitations of one or more claims of the ’307 

Patent. A claim chart comparing exemplary independent claim 68 of the ’307 Patent to 

representative Accused Products is attached as Exhibit 7.

28. On June 30, 2022, WiLAN sent Lenovo a letter indicating that certain Lenovo

products infringe at least claims 53 and 68 of the ’307 Patent and proposed times to discuss a 

potential license from UCT to practice the ’307 Patent. Ex. 4. On July 11, 2022, Lenovo’s 

licensing department confirmed receipt of the June 30 letter and indicated that it “would be happy 

to engage in discussions” with WiLAN regarding a potential license. Ex. 5. Thereafter, WiLAN 

and Lenovo exchanged various emails and held numerous calls to discuss the UCT patents 

(including substantive discussions regarding the alleged infringement and validity of the patents), 

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including calls on July 26, 2022, November 1, 2022, November 8, 2022, November 29, 2022, 

December 20, 2022, January 24, 2023, January 31, 2023, February 14, 2023, and March 7, 2023. 

After extensive discussions between the parties, Lenovo ultimately declined to take a license, or 

even hear UCT’s offer for a license, on a call held on March 30, 2023. 

29. Lenovo knowingly and intentionally induces infringement of one or more claims 

of the ’307 Patent in violation of 35 U.S.C. § 271(b). As of at least July 11, 2022, Lenovo has 

knowledge of the ’307 Patent and the infringing nature of the Accused Products. Despite this 

knowledge of the ’307 Patent, Lenovo continues to actively encourage and instruct its customers 

and end users (for example, through online instruction and other online publications cited in 

Exhibit 7) to use the Accused Products in ways that directly infringe the ’307 Patent. For example, 

Lenovo advertises that its products are compatible with DisplayPort. See, e.g.,

https://www.lenovo.com/us/en/p/desktops/thinkcentre/m-series-sff/thinkcentre-m75s-gen2/11tc1mdm75s?orgRef=https%253A%252F%252Fwww.google.com%252F#tech_specs

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – Product Specification); 

https://www.lenovo.com/us/en/p/laptops/legion-laptops/legion-7-series/legion-7-gen-6-(16-inchamd)/len101g0011?orgRef=https%253A%252F%252Fwww.google.com%252F (Legion 7 Gen 6 

Gaming Laptop – Product Specification). Lenovo also instructs its customers and end users on 

how to use the Accused Products in an infringing manner, including through the use of 

DisplayPort. See, e.g., 

https://download.lenovo.com/pccbbs/thinkcentre_pdf/m75s_gen2_ug_en.pdf (ThinkCenter M75s 

Gen 2 Small Form Factor Desktop – User Manual); 

https://download.lenovo.com/pccbbs/pubs/legion_7_16_6/html_en/index.html#t=EN%2Fcover.h

tml (Legion 7 Gen 6 Gaming Laptop – User Manual). Lenovo provides these instructions and 

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materials knowing and intending (or with willful blindness to the fact) that its customers and end 

users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, sell, 

and/or import the Accused Products, despite its knowledge of the ’307 Patent, thereby specifically 

intending for and inducing its customers to infringe the ’307 Patent through the customers’ normal 

and customary use of the Accused Products.

30. Lenovo has also infringed, and continues to infringe, one or more claims of the ’307

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’307

Patent, are especially made or adapted to infringe the ’307 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least July 11, 2022, Lenovo

has knowledge of the ’307 Patent and the infringing nature of the Accused Products. Lenovo has 

been, and currently is, contributorily infringing the ’307 Patent in violation of 35 U.S.C. §§ 271(c) 

and/or (f). For example, the identified hardware and/or software components in Lenovo’s laptops, 

desktops, monitors, and docking stations that support DisplayPort constitute a material part of the 

inventions claimed in the ’307 Patent, are especially made or adapted to infringe the ’307 Patent, 

and are not staple articles or commodities of commerce suitable for non-infringing use, as 

demonstrated by the evidence in Exhibit 7.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’307 Patent 

pursuant to 35 U.S.C. § 271.

32. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

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and any licensees did not make, offer for sale, or sell products that practice(d) the ’307 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

33. As described above, Lenovo obtained knowledge of the ’307 Patent and that certain 

products infringe the ’307 Patent as of at least July 11, 2022, but has not ceased its infringing 

activities. Lenovo’s infringement of the ’307 Patent has been and continues to be willful and 

deliberate. Lenovo also has knowledge of the ’307 Patent by way of this complaint and, to the 

extent they do not cease their infringing activities, their infringement is and continues to be willful 

and deliberate.

34. As a result of Lenovo’s direct and indirect infringement of the ’307 Patent, Plaintiff 

is entitled to monetary damages (past, present, and future) in an amount adequate to compensate 

for Lenovo’s infringement, but in no event less than a reasonable royalty for the use made of the 

invention by Lenovo, together with interest and costs as fixed by the Court.

COUNT III

INFRINGEMENT OF U.S. PATENT NO. 7,746,798

35. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

36. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,746,798, titled 

“Method and system for integrating packet type information with synchronization symbols.” 

The ’798 Patent was duly and legally issued by the United States Patent and Trademark Office on 

June 29, 2010. A true and correct copy of the ’798 Patent is attached as Exhibit 8.

37. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

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(laptops, desktops, monitors, and docking stations) that support USB 3.0 and later, such as the 

ThinkVision Ml4t USB-C Mobile Monitor, ThinkStation P620 Workstation, ThinkPad T14 Gen 3

Laptop, and Legion 7 Gen 6 & 7 Gaming Laptop (“Accused Products”), that directly infringe, 

literally and/or under the doctrine of equivalents, one or more claims of the ’798 Patent. 

Identification of the Accused Products will be provided in Plaintiff’s infringement contentions 

disclosed pursuant to the Court’s scheduling order. Plaintiff’s identification of the Accused 

Products is not intended to accuse products where the infringement accusations are directed at 

products that are licensed by the license between Intel Corporation and WiLAN.

38. The Accused Products satisfy all claim limitations of one or more claims of the ’798

Patent. A claim chart comparing exemplary independent claim 19 of the ’798 Patent to 

representative Accused Products is attached as Exhibit 9.

39. On June 30, 2022, WiLAN sent Lenovo a letter indicating that certain Lenovo

products infringe at least claim 19 of the ’798 Patent and proposed times to discuss a potential 

license from UCT to practice the ’798 Patent. Ex. 4. On July 11, 2022, Lenovo’s licensing 

department confirmed receipt of the June 30 letter and indicated that it “would be happy to engage 

in discussions” with WiLAN regarding a potential license. Ex. 5. Thereafter, WiLAN and Lenovo 

exchanged various emails and held numerous calls to discuss the UCT patents (including 

substantive discussions regarding the alleged infringement and validity of the patents), including 

calls on July 26, 2022, November 1, 2022, November 8, 2022, November 29, 2022, December 20, 

2022, January 24, 2023, January 31, 2023, February 14, 2023, and March 7, 2023. After extensive 

discussions between the parties, Lenovo ultimately declined to take a license, or even hear UCT’s 

offer for a license, on a call held on March 30, 2023. 

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40. Lenovo knowingly and intentionally induces infringement of one or more claims 

of the ’798 Patent in violation of 35 U.S.C. § 271(b). As of at least July 11, 2022, Lenovo has 

knowledge of the ’798 Patent and the infringing nature of the Accused Products. Despite this 

knowledge of the ’798 Patent, Lenovo continues to actively encourage and instruct its customers 

and end users (for example, through online instruction and other online publications cited in 

Exhibit 9) to use the Accused Products in ways that directly infringe the ’798 Patent. For example, 

Lenovo advertises that its products are compatible with USB. See, e.g.,

https://www.lenovo.com/us/en/p/desktops/thinkcentre/m-series-sff/thinkcentre-m75s-gen2/11tc1mdm75s?orgRef=https%253A%252F%252Fwww.google.com%252F#tech_specs

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – Product Specification);

https://www.lenovo.com/us/en/p/workstations/thinkstation-p-series/thinkstationp620/wmd00000429?orgRef=https%253A%252F%252Fwww.google.com%252F&cid=us:sem|s

e|google|subbrand_pc_thinkstation|commercial_premium_workstation_amd_generic|thinkstation

%20p620%20tower%20workstation|b|20493766441|153601625180|aud-959187040766:kwd1285462112330|search||commercialconsumer&gclid=CjwKCAjwyNSoBhA9EiwA5aYlb1cQapty8e-hnPQGpkrda-BU8_gs9BFYgpcbtbAm2P2inMd01D17hoCBL4QAvD_BwE

(ThinkStation P620 Workstation – Product Specification). Lenovo also instructs its customers and 

end users on how to use the Accused Products in an infringing manner, including through the use 

of USB. See, e.g., https://download.lenovo.com/pccbbs/thinkcentre_pdf/m75s_gen2_ug_en.pdf

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – User Manual); 

https://download.lenovo.com/pccbbs/thinkcentre_pdf/p620_ug_en.pdf (ThinkStation P620 

Workstation – User Manual). Lenovo provides these instructions and materials knowing and 

intending (or with willful blindness to the fact) that its customers and end users will commit these 

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

Products, despite its knowledge of the ’798 Patent, thereby specifically intending for and inducing 

its customers to infringe the ’798 Patent through the customers’ normal and customary use of the 

Accused Products.

41. Lenovo has also infringed, and continues to infringe, one or more claims of the ’798

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’798

Patent, are especially made or adapted to infringe the ’798 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least July 11, 2022, Lenovo

has knowledge of the ’798 Patent and the infringing nature of the Accused Products. Lenovo has 

been, and currently is, contributorily infringing the ’798 Patent in violation of 35 U.S.C. §§ 271(c) 

and/or (f). For example, the identified hardware and/or software components in Lenovo’s laptops,

desktops, monitors, and docking stations that support USB 3.0 and later constitute a material part 

of the inventions claimed in the ’798 Patent, are especially made or adapted to infringe the ’798 

Patent, and are not staple articles or commodities of commerce suitable for non-infringing use, as 

demonstrated by the evidence in Exhibit 9.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’798 Patent 

pursuant to 35 U.S.C. § 271.

43. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’798 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 16 of 36 PageID #: 16
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44. As described above, Lenovo obtained knowledge of the ’798 Patent and that certain 

products infringe the ’798 Patent as of at least July 11, 2022, but has not ceased its infringing 

activities. Lenovo’s infringement of the ’798 Patent has been and continues to be willful and 

deliberate. Lenovo also has knowledge of the ’798 Patent by way of this complaint and, to the 

extent they do not cease their infringing activities, their infringement is and continues to be willful 

and deliberate.

45. As a result of Lenovo’s direct and indirect infringement of the ’798 Patent, Plaintiff 

is entitled to monetary damages (past, present, and future) in an amount adequate to compensate 

for Lenovo’s infringement, but in no event less than a reasonable royalty for the use made of the 

invention by Lenovo, together with interest and costs as fixed by the Court.

COUNT IV

INFRINGEMENT OF U.S. PATENT NO. 9,232,265

46. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

47. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 9,232,265, titled 

“Method, apparatus and system for transitioning an audio/video device between a source mode 

and a sink mode.” The ’265 Patent was duly and legally issued by the United States Patent and 

Trademark Office on January 5, 2016. A true and correct copy of the ’265 Patent is attached as 

Exhibit 10.

48. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, and monitors) that support USB-C Revision 1.0 or later, such as the 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 17 of 36 PageID #: 17
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ThinkVision M14t USB-C Mobile Monitor, ThinkCentre M75s Gen 2 Small Form Factor Desktop,

and the Legion 7 Gen 6 & 7 Gaming Laptop (“Accused Products”), that directly infringe, literally 

and/or under the doctrine of equivalents, one or more claims of the ’265 Patent. Identification of 

the Accused Products will be provided in Plaintiff’s infringement contentions disclosed pursuant 

to the Court’s scheduling order. Plaintiff’s identification of the Accused Products is not intended 

to accuse products where the infringement accusations are directed at products that are licensed by 

the license between Intel Corporation and WiLAN.

49. The Accused Products satisfy all claim limitations of one or more claims of the ’265

Patent. A claim chart comparing exemplary independent claim 8 of the ’265 Patent to 

representative Accused Products is attached as Exhibit 11.

50. On June 30, 2022, WiLAN sent Lenovo a letter indicating that certain Lenovo

products infringe at least claim 8 of the ’265 Patent and proposed times to discuss a potential 

license from UCT to practice the ’265 Patent. Ex. 4. On July 11, 2022, Lenovo’s licensing 

department confirmed receipt of the June 30 letter and indicated that it “would be happy to engage 

in discussions” with WiLAN regarding a potential license. Ex. 5. Thereafter, WiLAN and Lenovo 

exchanged various emails and held numerous calls to discuss the UCT patents (including 

substantive discussions regarding the alleged infringement and validity of the patents), including 

calls on July 26, 2022, November 1, 2022, November 8, 2022, November 29, 2022, December 20, 

2022, January 24, 2023, January 31, 2023, February 14, 2023, and March 7, 2023. After extensive 

discussions between the parties, Lenovo ultimately declined to take a license, or even hear UCT’s 

offer for a license, on a call held on March 30, 2023.

51. Lenovo knowingly and intentionally induces infringement of one or more claims 

of the ’265 Patent in violation of 35 U.S.C. § 271(b). As of at least July 11, 2022, Lenovo has 

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knowledge of the ’265 Patent and the infringing nature of the Accused Products. Despite this 

knowledge of the ’265 Patent, Lenovo continues to actively encourage and instruct its customers 

and end users (for example, through online instruction and other online publications cited in 

Exhibit 11) to use the Accused Products in ways that directly infringe the ’265 Patent. For 

example, Lenovo advertises that its products are compatible with USB-C. See, e.g.,

https://www.lenovo.com/us/en/p/desktops/thinkcentre/m-series-sff/thinkcentre-m75s-gen2/11tc1mdm75s?orgRef=https%253A%252F%252Fwww.google.com%252F#tech_specs

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – Product Specification); 

https://www.lenovo.com/us/en/p/laptops/legion-laptops/legion-7-series/legion-7-gen-6-(16-inchamd)/len101g0011?orgRef=https%253A%252F%252Fwww.google.com%252F (Legion 7 Gen 6 

Gaming Laptop – Product Specification). Lenovo also instructs its customers and end users on 

how to use the Accused Products in an infringing manner, including through the use of USB-C. 

See, e.g., https://download.lenovo.com/pccbbs/thinkcentre_pdf/m75s_gen2_ug_en.pdf

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – User Manual); 

https://download.lenovo.com/pccbbs/pubs/legion_7_16_6/html_en/index.html#t=EN%2Fcover.h

tml (Legion 7 Gen 6 Gaming Laptop – User Manual). Lenovo provides these instructions and 

materials knowing and intending (or with willful blindness to the fact) that its customers and end 

users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, sell, 

and/or import the Accused Products, despite its knowledge of the ’265 Patent, thereby specifically 

intending for and inducing its customers to infringe the ’265 Patent through the customers’ normal 

and customary use of the Accused Products.

52. Lenovo has also infringed, and continues to infringe, one or more claims of the ’265

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 19 of 36 PageID #: 19
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knowing that the Accused Products constitute a material part of the inventions claimed in the ’265

Patent, are especially made or adapted to infringe the ’265 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least July 11, 2022, Lenovo

has knowledge of the ’265 Patent and the infringing nature of the Accused Products. Lenovo has 

been, and currently is, contributorily infringing the ’265 Patent in violation of 35 U.S.C. §§ 271(c) 

and/or (f). For example, the identified hardware and/or software components in Lenovo’s laptops, 

desktops, and monitors that support USB-C Release 1.0 or later constitute a material part of the 

inventions claimed in the ’265 Patent, are especially made or adapted to infringe the ’265 Patent,

and are not staple articles or commodities of commerce suitable for non-infringing use, as 

demonstrated by the evidence in Exhibit 11.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’265 Patent 

pursuant to 35 U.S.C. § 271.

54. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’265 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

55. As described above, Lenovo obtained knowledge of the ’265 Patent and that certain 

products infringe the ’265 Patent as of at least July 11, 2022, but has not ceased its infringing 

activities. Lenovo’s infringement of the ’265 Patent has been and continues to be willful and 

deliberate. Lenovo also has knowledge of the ’265 Patent by way of this complaint and, to the 

extent they do not cease their infringing activities, their infringement is and continues to be willful 

and deliberate.

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 20 of 36 PageID #: 20
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56. As a result of Lenovo’s direct and indirect infringement of the ’265 Patent, Plaintiff 

is entitled to monetary damages (past, present, and future) in an amount adequate to compensate 

for Lenovo’s infringement, but in no event less than a reasonable royalty for the use made of the 

invention by Lenovo, together with interest and costs as fixed by the Court.

COUNT V

INFRINGEMENT OF U.S. PATENT NO. 8,680,712

57. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

58. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 8,680,712, titled 

“Power delivery over digital interaction interface for video and audio (DiiVA).” The ’712 Patent 

was duly and legally issued by the United States Patent and Trademark Office on March 25, 2014. 

A true and correct copy of the ’712 Patent is attached as Exhibit 12.

59. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products

(laptops, desktops, monitors, docking stations, and power adapters) that support USB-C Version

1.0 and later, such as the ThinkVision M14t USB-C Mobile Monitor, ThinkVision P27pz-30 MiniLED Monitor, ThinkCentre M75s Gen 2 Small Form Factor Desktop, and Legion 7 Gen 6 & 7 

Gaming Laptop (“Accused Products”), that directly infringe, literally and/or under the doctrine of 

equivalents, one or more claims of the ’712 Patent. Identification of the Accused Products will be 

provided in Plaintiff’s infringement contentions disclosed pursuant to the Court’s scheduling 

order. Plaintiff’s identification of the Accused Products is not intended to accuse products where 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 21 of 36 PageID #: 21
22

the infringement accusations are directed at products that are licensed by the license between Intel 

Corporation and WiLAN.

60. The Accused Products satisfy all claim limitations of one or more claims of the ’712 

Patent. A claim chart comparing exemplary independent claim 1 of the ’712 Patent to 

representative Accused Products is attached as Exhibit 13.

61. On June 30, 2022, WiLAN sent Lenovo a letter indicating that certain Lenovo

products infringe at least claim 1 of the ’712 Patent and proposed times to discuss a potential 

license from UCT to practice the ’712 Patent. Ex. 4. On July 11, 2022, Lenovo’s licensing 

department confirmed receipt of the June 30 letter and indicated that it “would be happy to engage 

in discussions” with WiLAN regarding a potential license. Ex. 5. Thereafter, WiLAN and Lenovo 

exchanged various emails and held numerous calls to discuss the UCT patents (including 

substantive discussions regarding the alleged infringement and validity of the patents), including 

calls on July 26, 2022, November 1, 2022, November 8, 2022, November 29, 2022, December 20, 

2022, January 24, 2023, January 31, 2023, February 14, 2023, and March 7, 2023. After extensive 

discussions between the parties, Lenovo ultimately declined to take a license, or even hear UCT’s 

offer for a license, on a call held on March 30, 2023. 

62. Lenovo also knowingly and intentionally induces infringement of one or more 

claims of the ’712 Patent in violation of 35 U.S.C. § 271(b). As of at least July 11, 2022, Lenovo

has knowledge of the ’712 Patent and the infringing nature of the Accused Products. Despite this 

knowledge of the ’712 Patent, Lenovo continues to actively encourage and instruct its customers 

and end users (for example, through online instruction and other online publications cited in 

Exhibit 13) to use the Accused Products in ways that directly infringe the ’712 Patent. For 

example, Lenovo advertises that its products are compatible with USB-C. See, e.g.,

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 22 of 36 PageID #: 22
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https://www.lenovo.com/us/en/p/desktops/thinkcentre/m-series-sff/thinkcentre-m75s-gen2/11tc1mdm75s?orgRef=https%253A%252F%252Fwww.google.com%252F#tech_specs

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – Product Specification); 

https://www.lenovo.com/us/en/p/laptops/legion-laptops/legion-7-series/legion-7-gen-6-(16-inchamd)/len101g0011?orgRef=https%253A%252F%252Fwww.google.com%252F (Legion 7 Gen 6 

Gaming Laptop – Product Specification). Lenovo also instructs its customers and end users on 

how to use the Accused Products in an infringing manner, including through the use of USB-C. 

See, e.g., https://download.lenovo.com/pccbbs/thinkcentre_pdf/m75s_gen2_ug_en.pdf

(ThinkCenter M75s Gen 2 Small Form Factor Desktop – User Manual); 

https://download.lenovo.com/pccbbs/pubs/legion_7_16_6/html_en/index.html#t=EN%2Fcover.h

tml (Legion 7 Gen 6 Gaming Laptop – User Manual). Lenovo provides these instructions and 

materials knowing and intending (or with willful blindness to the fact) that its customers and end 

users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, sell, 

and/or import the Accused Products, despite its knowledge of the ’712 Patent, thereby specifically 

intending for and inducing its customers to infringe the ’712 Patent through the customers’ normal 

and customary use of the Accused Products.

63. Lenovo has also infringed, and continues to infringe, one or more claims of the ’712

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’712

Patent, are especially made or adapted to infringe the ’712 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least July 11, 2022, Lenovo

has knowledge of the ’712 Patent and the infringing nature of the Accused Products. Lenovo has 

been, and currently is, contributorily infringing the ’712 Patent in violation of 35 U.S.C. §§ 271(c) 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 23 of 36 PageID #: 23
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and/or (f). For example, the identified hardware and/or software components in Lenovo’s laptops, 

desktops, monitors, docking stations, and power adapters that support USB-C Release 1.0 and later 

constitute a material part of the inventions claimed in the ’712 Patent, are especially made or 

adapted to infringe the ’712 Patent, and are not staple articles or commodities of commerce suitable 

for non-infringing use, as demonstrated by the evidence in Exhibit 13.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’712 Patent 

pursuant to 35 U.S.C. § 271.

65. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’712 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

66. As described above, Lenovo obtained knowledge of the ’712 Patent and that certain 

products infringe the ’712 Patent as of at least July 11, 2022, but has not ceased its infringing 

activities. Lenovo’s infringement of the ’712 Patent has been and continues to be willful and 

deliberate. Lenovo also has knowledge of the ’712 Patent by way of this complaint and, to the 

extent they do not cease their infringing activities, their infringement is and continues to be willful 

and deliberate.

67. As a result of Lenovo’s direct and indirect infringement of the ’712 Patent, Plaintiff 

is entitled to monetary damages (past, present, and future) in an amount adequate to compensate 

for Lenovo’s infringement, but in no event less than a reasonable royalty for the use made of the 

invention by Lenovo, together with interest and costs as fixed by the Court.

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 24 of 36 PageID #: 24
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COUNT VI

INFRINGEMENT OF U.S. PATENT NO. 7,856,520

68. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

69. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,856,520, titled 

“Control bus for connection of electronic devices.” The ’520 Patent was duly and legally issued 

by the United States Patent and Trademark Office on December 21, 2010. A true and correct copy 

of the ’520 Patent is attached as Exhibit 14.

70. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, monitors, docking stations, and USB-C to DP/HDMI adapters) that support 

DisplayPort Alt Mode on USB Type-C Version 1.0 and later or HDMI Alt Mode for USB-C, such 

as the ThinkPad T16 Gen 2 (AMD) Laptop and Legion 7 Gen 7 Laptop (“Accused Products”), that 

directly infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’520

Patent. Identification of the Accused Products will be provided in Plaintiff’s infringement 

contentions disclosed pursuant to the Court’s scheduling order. Plaintiff’s identification of the 

Accused Products is not intended to accuse products where the infringement accusations are 

directed at products that are licensed by the license between Intel Corporation and WiLAN.

71. The Accused Products satisfy all claim limitations of one or more claims of the ’520

Patent. A claim chart comparing exemplary independent claim 12 of the ’520 Patent to 

representative Accused Products is attached as Exhibit 15.

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72. Lenovo also knowingly and intentionally induces infringement of one or more 

claims of the ’520 Patent in violation of 35 U.S.C. § 271(b). As of at least the filing and service 

of this complaint, Lenovo has knowledge of the ’520 Patent and the infringing nature of the 

Accused Products. Despite this knowledge of the ’520 Patent, Lenovo continues to actively 

encourage and instruct its customers and end users (for example, through online instruction and 

other online publications cited in Exhibit 15) to use the Accused Products in ways that directly 

infringe the ’520 Patent. For example, Lenovo advertises that its products provide DisplayPort 

Alternative Mode connections over USB-C. See, e.g., 

https://most.lenovo.com/api/v2/library/pdf/device2pager/Device_ThinkPad_T16_Gen_2_AMD?l

ocale=en (ThinkPad T16 Gen 2 (AMD) – Product Specification). Lenovo also instructs its 

customers and end users on how to use the Accused Products in an infringing manner, including 

through the use of DisplayPort Alternative Mode. See, e.g., 

https://download.lenovo.com/pccbbs/mobiles_pdf/t14_gen4_p14s_gen4_t16_gen2_p16s_gen2_li

nux_ug.pdf (ThinkPad T16 Gen 2 (AMD) – User Manual). Lenovo provides these instructions 

and materials knowing and intending (or with willful blindness to the fact) that its customers and 

end users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, 

sell, and/or import the Accused Products, despite its knowledge of the ’520 Patent, thereby 

specifically intending for and inducing its customers to infringe the ’520 Patent through the 

customers’ normal and customary use of the Accused Products.

73. Lenovo has also infringed, and continues to infringe, one or more claims of the ’520

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’520

Patent, are especially made or adapted to infringe the ’520 Patent, and are not staple articles or 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 26 of 36 PageID #: 26
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commodities of commerce suitable for non-infringing use. As of at least the filing and service of 

this complaint, Lenovo has knowledge of the ’520 Patent and the infringing nature of the Accused 

Products. Lenovo has been, and currently is, contributorily infringing the ’520 Patent in violation 

of 35 U.S.C. §§ 271(c) and/or (f). For example, the identified hardware and/or software 

components in Lenovo’s laptops, desktops, docking stations, USB-C to DP/HDMI adapters, and 

monitors that support DisplayPort Alt Mode on USB Type-C Version 1.0 and later constitute a 

material part of the inventions claimed in the ’520 Patent, are especially made or adapted to 

infringe the ’520 Patent and are not staple articles or commodities of commerce suitable for noninfringing use, as demonstrated by the evidence in Exhibit 15.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’520 Patent 

pursuant to 35 U.S.C. § 271.

75. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’520 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

76. As a result of Lenovo’s direct infringement of the ’520 Patent, Plaintiff is entitled 

to monetary damages (past, present, and future) in an amount adequate to compensate for Lenovo’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by 

Lenovo, together with interest and costs as fixed by the Court.

77. As a result of Lenovo’s indirect infringement of the ’520 Patent, Plaintiff is entitled 

to monetary damages (present and future) in an amount adequate to compensate for Lenovo’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 27 of 36 PageID #: 27
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Lenovo, together with interest and costs as fixed by the Court, accruing as of the time Lenovo

obtained knowledge of the ’520 Patent. 

COUNT VII

INFRINGEMENT OF U.S. PATENT NO. 7,921,231

78. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

79. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,921,231, titled 

“Discovery of electronic devices utilizing a control bus.” The ’231 Patent was duly and legally 

issued by the United States Patent and Trademark Office on April 5, 2011. A true and correct 

copy of the ’231 Patent is attached as Exhibit 16.

80. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, and monitors) that support DisplayPort Alt Mode on USB Type-C Version 1.0 

and later, such as the ThinkPad T16 Gen 2 (AMD) Laptop, Legion 7 Gen 7 Laptop, and Qreator 

27in Monitor (“Accused Products”), that directly infringe, literally and/or under the doctrine of 

equivalents, one or more claims of the ’231 Patent. Identification of the Accused Products will be 

provided in Plaintiff’s infringement contentions disclosed pursuant to the Court’s scheduling 

order. Plaintiff’s identification of the Accused Products is not intended to accuse products where 

the infringement accusations are directed at products that are licensed by the license between Intel 

Corporation and WiLAN.

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 28 of 36 PageID #: 28
29

81. The Accused Products satisfy all claim limitations of one or more claims of the ’231

Patent. A claim chart comparing exemplary independent claim 10 of the ’231 Patent to 

representative Accused Products is attached as Exhibit 17.

82. Lenovo also knowingly and intentionally induces infringement of one or more 

claims of the ’231 Patent in violation of 35 U.S.C. § 271(b). As of at least the filing and service 

of this complaint, Lenovo has knowledge of the ’231 Patent and the infringing nature of the 

Accused Products. Despite this knowledge of the ’231 Patent, Lenovo continues to actively 

encourage and instruct its customers and end users (for example, through online instruction and 

other online publications cited in Exhibit 17) to use the Accused Products in ways that directly 

infringe the ’231 Patent. For example, Lenovo advertises that its products provide DisplayPort 

Alternative Mode connections over USB-C. See, e.g., 

https://most.lenovo.com/api/v2/library/pdf/device2pager/Device_ThinkPad_T16_Gen_2_AMD?l

ocale=en (ThinkPad T16 Gen 2 (AMD) – Product Specification). Lenovo also instructs its 

customers and end users on how to use the Accused Products in an infringing manner, including 

through the use of DisplayPort Alternative Mode. See, e.g., 

https://download.lenovo.com/pccbbs/mobiles_pdf/t14_gen4_p14s_gen4_t16_gen2_p16s_gen2_li

nux_ug.pdf (ThinkPad T16 Gen 2 (AMD) – User Manual). Lenovo provides these instructions 

and materials knowing and intending (or with willful blindness to the fact) that its customers and 

end users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, 

sell, and/or import the Accused Products, despite its knowledge of the ’231 Patent, thereby 

specifically intending for and inducing its customers to infringe the ’231 Patent through the 

customers’ normal and customary use of the Accused Products.

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 29 of 36 PageID #: 29
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83. Lenovo has also infringed, and continues to infringe, one or more claims of the ’231

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’231

Patent, are especially made or adapted to infringe the ’231 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least the filing and service of 

this complaint, Lenovo has knowledge of the ’231 Patent and the infringing nature of the Accused 

Products. Lenovo has been, and currently is, contributorily infringing the ’231 Patent in violation 

of 35 U.S.C. §§ 271(c) and/or (f). For example, the identified hardware and/or software 

components in Lenovo’s laptops, desktops, and monitors that support DisplayPort Alt Mode on 

USB Type-C Version 1.0 and later constitute a material part of the inventions claimed in the ’231

Patent, are especially made or adapted to infringe the ’231 Patent and are not staple articles or 

commodities of commerce suitable for non-infringing use, as demonstrated by the evidence in 

Exhibit 17.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’231 Patent 

pursuant to 35 U.S.C. § 271.

85. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’231 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

86. As a result of Lenovo’s direct infringement of the ’231 Patent, Plaintiff is entitled 

to monetary damages (past, present, and future) in an amount adequate to compensate for Lenovo’s 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 30 of 36 PageID #: 30
31

infringement, but in no event less than a reasonable royalty for the use made of the invention by

Lenovo, together with interest and costs as fixed by the Court.

87. As a result of Lenovo’s indirect infringement of the ’231 Patent, Plaintiff is entitled 

to monetary damages (present and future) in an amount adequate to compensate for Lenovo’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by

Lenovo, together with interest and costs as fixed by the Court, accruing as of the time Lenovo

obtained knowledge of the ’231 Patent. 

COUNT VIII

INFRINGEMENT OF U.S. PATENT NO. 9,852,103

88. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

89. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 9,852,103, titled 

“Bidirectional transmission of USB data using audio/video data channel.” The ’103 Patent was 

duly and legally issued by the United States Patent and Trademark Office on December 26, 2017. 

A true and correct copy of the ’103 Patent is attached as Exhibit 18.

90. On information and belief, Lenovo has and continues to make, use, offer for sale, 

sell, and/or import certain products and services, including without limitation Lenovo products 

(laptops, desktops, monitors, and docking stations) that support USB 4 Version 1.0 and later, such 

as the ThinkPad T16 Gen 2 & 3 (AMD) Laptop, ThinkPad Z13, Lenovo Legion 7 Gen 7 AMD 

Laptop, and ThinkVision P27pz-30 Mini-LED Monitor (“Accused Products”), that directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims of the ’103 Patent. 

Identification of the Accused Products will be provided in Plaintiff’s infringement contentions 

Case 2:23-cv-00449-JRG Document 1 Filed 09/28/23 Page 31 of 36 PageID #: 31
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disclosed pursuant to the Court’s scheduling order. Plaintiff’s identification of the Accused 

Products is not intended to accuse products where the infringement accusations are directed at 

products that are licensed by the license between Intel Corporation and WiLAN.

91. The Accused Products satisfy all claim limitations of one or more claims of the ’103

Patent. A claim chart comparing exemplary independent claim 21 of the ’103 Patent to 

representative Accused Products is attached as Exhibit 19.

92. Lenovo also knowingly and intentionally induces infringement of one or more 

claims of the ’103 Patent in violation of 35 U.S.C. § 271(b). As of at least the filing and service 

of this complaint, Lenovo has knowledge of the ’103 Patent and the infringing nature of the 

Accused Products. Despite this knowledge of the ’103 Patent, Lenovo continues to actively 

encourage and instruct its customers and end users (for example, through online instruction and 

other online publications cited in Exhibit 19) to use the Accused Products in ways that directly 

infringe the ’103 Patent. For example, Lenovo advertises that its products are compatible with 

USB. See, e.g., 

https://most.lenovo.com/api/v2/library/pdf/device2pager/Device_ThinkPad_T16_Gen_2_AMD?l

ocale=en (ThinkPad T16 Gen 2 (AMD) – Product Specification). Lenovo also instructs its 

customers and end users on how to use the Accused Products in an infringing manner, including 

through the use of USB. See, e.g., 

https://download.lenovo.com/pccbbs/mobiles_pdf/t14_gen4_p14s_gen4_t16_gen2_p16s_gen2_li

nux_ug.pdf (ThinkPad T16 Gen 2 (AMD) – User Manual). Lenovo provides these instructions 

and materials knowing and intending (or with willful blindness to the fact) that its customers and 

end users will commit these infringing acts. Lenovo also continues to make, use, offer for sale, 

sell, and/or import the Accused Products, despite its knowledge of the ’103 Patent, thereby 

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specifically intending for and inducing its customers to infringe the ’103 Patent through the 

customers’ normal and customary use of the Accused Products.

93. Lenovo has also infringed, and continues to infringe, one or more claims of the ’103

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

knowing that the Accused Products constitute a material part of the inventions claimed in the ’103

Patent, are especially made or adapted to infringe the ’103 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. As of at least the filing and service of 

this complaint, Lenovo has knowledge of the ’103 Patent and the infringing nature of the Accused 

Products. Lenovo has been, and currently is, contributorily infringing the ’103 Patent in violation 

of 35 U.S.C. §§ 271(c) and/or (f). For example, the identified hardware and/or software 

components in Lenovo’s laptops, desktops, monitors, and docking stations that support USB 4 

Version 1.0 and later constitute a material part of the inventions claimed in the ’103 Patent, are 

especially made or adapted to infringe the ’103 Patent and are not staple articles or commodities 

of commerce suitable for non-infringing use, as demonstrated by the evidence in Exhibit 19.

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

the Accused Products, Lenovo has injured Plaintiff and is liable for infringement of the ’103 Patent 

pursuant to 35 U.S.C. § 271.

95. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. § 287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’103 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

96. As a result of Lenovo’s direct infringement of the ’103 Patent, Plaintiff is entitled 

to monetary damages (past, present, and future) in an amount adequate to compensate for Lenovo’s 

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infringement, but in no event less than a reasonable royalty for the use made of the invention by 

Lenovo, together with interest and costs as fixed by the Court.

97. As a result of Lenovo’s indirect infringement of the ’103 Patent, Plaintiff is entitled 

to monetary damages (present and future) in an amount adequate to compensate for Lenovo’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by 

Lenovo, together with interest and costs as fixed by the Court, accruing as of the time Lenovo

obtained knowledge of the ’103 Patent. 

COUNT IX

DECLARATORY JUDGMENT THAT PLAINTIFF HAS NEGOTIATED IN GOOD 

FAITH TOWARD A LICENSE WITH LENOVO, HAS NOT VIOLATED THE VESA OR 

USB-IF IPR POLICIES, AND HAS NOT VIOLATED COMPETITION LAW

98. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

99. Plaintiff’s ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents were 

previously assigned to Lattice Semiconductor Corporation (“Lattice”), which is a member of the 

Video Electronics Standards Association (“VESA”) and the USB Implementers Forum, Inc. 

(“USB-IF”). Lattice was required to comply with the VESA and USB-IF IPR policies to the extent 

the ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents contain Necessary Claims as defined 

in the VESA and USB-IF IPR policies.

100. Plaintiff has fully performed its obligations under the VESA and USB-IF IPR 

policies, to the extent they apply to Plaintiff’s ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 

Patents, but Lenovo disagrees and has refused to license these patents, even refusing to entertain 

an offer from Plaintiff. Plaintiff has at all times been prepared to grant Lenovo a license to 

the ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents. There is a dispute between Plaintiff 

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and Lenovo concerning whether Plaintiff has negotiated in good faith towards a license to 

Plaintiff’s ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents, and whether Plaintiff or its 

predecessors-in-interest have complied with the VESA and USB-IF IPR policies. There is a case 

or controversy of sufficient immediacy, reality, and ripeness to warrant the issuance of declaratory 

judgment.

101. Plaintiff requests a declaratory judgment that its negotiations toward a license with 

Lenovo were conducted in good faith, are not in violation of the VESA or USB-IF IPR policies, 

and are consistent with competition law requirements.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter:

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

under the doctrine of equivalents, the ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents;

b. A judgment and order requiring Lenovo to pay Plaintiff its damages (past, present, 

and future), costs, expenses, and pre-judgment and post-judgment interest for Lenovo’s 

infringement of the ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents; 

c. A judgment that Lenovo’s infringement of the ’905, ’307, ’798, ’265, and ’712 

Patents has been willful and order requiring Lenovo to pay treble damages for willful infringement; 

d. A judgment and order requiring Lenovo to pay Plaintiff compulsory ongoing 

licensing fees, as determined by the Court; 

e. A judgment and order requiring Lenovo to provide an accounting and to pay 

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

interest and compensation for infringing products released after the filing of this case that are not 

colorably different from the Accused Products; 

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f. A declaration that Plaintiff has negotiated in good faith with Lenovo towards a 

license for the ’905, ’307, ’798, ’265, ’712, ’520, ’231, and ’103 Patents, has not violated the 

VESA or USB-IF IPR policies, and has not violated competition law.

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

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

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

circumstances.

DEMAND FOR JURY TRIAL

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

any issues so triable by right.

Dated: September 28, 2023 Respectfully submitted,

/s/ Brett Cooper

Brett E. Cooper (NY SBN 4011011) 

bcooper@bc-lawgroup.com

Seth Hasenour (TX SBN 24059910)

shasenour@bc-lawgroup.com

Jonathan Yim (TX SBN 24066317)

jyim@bc-lawgroup.com

Drew B. Hollander (NY SBN 5378096)

dhollander@bc-lawgroup.com

BC LAW GROUP, P.C. 

200 Madison Avenue, 24th Floor

New York, NY 10016 

Phone: 212-951-0100

Attorneys for Plaintiff Universal Connectivity 

Technologies Inc.

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