THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

DISPLAY TECHNOLOGIES, LLC,

Plaintiff,

v.

WONDERSHARE TECHNOLOGY 

GROUP CO LTD, 

Defendant.

 CIVIL ACTION NO. 2:24-cv-00046

 JURY TRIAL DEMANDED

COMPLAINT

Plaintiff files this complaint for patent infringement against defendant and alleges as 

follows:

PARTIES

1. Plaintiff is a Texas limited liability company with an office at 1 East Broward 

Boulevard, Suite 700, Ft. Lauderdale, FL 33301.

2. Defendant Wondershare Technology Group Co Ltd. is a foreign entity to the State 

of Texas. 

3. Venue is proper in the Eastern District of Texas as to Defendant pursuant to at least 

28 U.S.C. §§ 1391 and 1400. 

PATENT FAMILY

4. Display Technologies is the owner of U.S. Patent Numbers 9,300,723 and 8,671, 

195. 

5. The ’723 Patent claims priority to a Continuation-in-Part of U.S. application Serial

No. 11/999,570, filed on Dec. 7, 2007, which is incorporated by reference in its entirety to the ’723 

patent specification.

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6. According to Google Patents, the ’723 Patent has an anticipated expiration date of 

no earlier than January 8, 2029. See website page, as last visited on January 24, 2029, at 

https://patents.google.com/patent/US9300723B2/en?oq=9%2c300%2c723.

7. The examiner performed a thorough examination that included searching in eleven 

categories, including these:

a. “H04W4/80 Services using short range communication, e.g. nearfield communication [NFC], radio-frequency identification [RFID] or low 

energy communication.”

b. “H04W12/086 Access security using security domains”

c. “H04W12/08 Access security,”

d. “H04M1/72412 User interfaces specially adapted for cordless or mobile 

telephones with means for local support of applications that increase the 

functionality by interfacing with external accessories using two-way shortrange wireless interfaces,”

e. “H04M1/724098 Interfacing with an on-board device of a vehicle,”

f. “H04L67/06 Protocols specially adapted for file transfer, e.g. file transfer 

protocol [FTP],”

g. “H04L65/75 Media network packet handling,”

h. “H04L63/20 Network architectures or network communication protocols for 

network security for managing network security; network security policies in 

general,”

i. “H04L63/10 Network architectures or network communication protocols for 

network security for controlling access to devices or network resources,”

j. “H04L63/0209 Architectural arrangements, e.g. perimeter networks or 

demilitarized zones,”

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k. “H04B1/3822 Transceivers, i.e. devices in which transmitter and receiver form 

a structural unit and in which at least one part is used for functions of 

transmitting and receiving specially adapted for use in vehicles.”

8. The ’723 Patent is cited by large electronic suppliers, including Sony Mobile 

Communications, Inc. in its publication US20160337303A1, titled “Method and system for 

approving or disapproving connection requests.”

COUNT I

(INFRINGEMENT OF UNITED STATES PATENT NO. 9,300,723)

9. Plaintiff incorporates above paragraphs herein by reference. 

10. The ’723 Patent does not expire under January 8, 2029.

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

U.S.C. §§ 271, et seq. 

12. Plaintiff is the owner by assignment of the ’723 Patent with sole rights to enforce 

the ’723 Patent and sue infringers. 

13. A copy of the ’723 Patent, titled “Enabling social interactive wireless 

communications,” is attached hereto as Exhibit A.

14. The ’723 Patent is valid, enforceable, and was duly issued in full compliance with 

Title 35 of the United States Code.

15. Defendant has infringed and continues to infringe one or more claims, including 

at least Claim 22 of the ’723 Patent by making, using, and/or selling its Accused Instrumentality.

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Figure 1 - Source: https://mobiletrans.wondershare.com/app/phone-to-phone-transfer-app.html, 

as last visited on January 24, 2024.

16. Defendant Wondershare performs and/or induces others to perform a method of 

transferring a media file from a wireless mobile device to a media system over a communication 

network, the media system including a security measure (“Accused Functionality”).

17. Defendant’s MobileTrans App, the Accused Instrumentality, provida a data 

transfer application installed on both Android phone and iPhone. As an example, the 

MobileTrans App utilizes a wireless internet connection (“communication network”) that allows 

the iPhone (“wireless mobile device”) to send files (“transferring a media file”) to the Android 

phone (“media system”). 

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Figure 2 – Source: https://www.youtube.com/watch?v=WuBk-YjJll4, at 0:07, as last visited on 

January 24, 2024.

18. Furthermore, the Android phone and the iPhone do not require users to input the 

email and the password every time they communicate. Instead, the email and password input are 

necessary ("security measure") during the initial connection process, and thereafter, the devices 

automatically exchange data without requiring users to re-enter the email and password. 

Additional description is of infringement is contained in Exhibit B.

19. Defendant’s actions complained of herein will continue unless Defendant is 

enjoined by this court. 

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20. Defendant’s actions complained of herein are causing irreparable harm and 

monetary damage to Plaintiff and will continue to do so unless and until Defendant is enjoined 

and restrained by this Court. 

21. Plaintiff is in compliance with 35 U.S.C. § 287.

DEMAND FOR JURY TRIAL 

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

jury of any issues so triable by right.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff asks the Court to:

(a) Enter judgment for Plaintiff on this Complaint on all cases of action asserted herein;

(b) Enter an Order enjoining Defendant, its agents, officers, servants, employees, 

attorneys, and all persons in active concert or participation with Defendant who receives notice of 

the order from further infringement of Patents (or, in the alternative, awarding Plaintiff running 

royalty from the time judgment going forward);

(c) Award Plaintiff damages resulting from Defendants infringement in accordance with 

35 U.S.C. § 284;

(d) Award Plaintiff such further relief to which the Court finds Plaintiff entitled under law 

or equity.

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Dated: January 25, 2024 Respectfully Submitted,

/s/ Randall T. Garteiser

Randall Garteiser 

 Texas Bar No. 24038912

 rgarteiser@ghiplaw.com

Christopher A. Honea

 Texas Bar No. 24059967

 chonea@ghiplaw.com

M. Scott Fuller

 Texas Bar No. 24036607

 rgarteiser@ghiplaw.com

GARTEISER HONEA, PLLC

119 W. Ferguson Street

Tyler, Texas 75702

Telephone: (903) 705-7420

Facsimile: (903) 405-3999

COUNSEL FOR PLAINTIFF

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