1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

 

 

 

Gamehancement LLC,

 Plaintiff, 

 v. 

Renesas Electronics Corporation,

 Defendant. 

 

 Case No. 2:23-cv-599 

 Patent Case 

 Jury Trial Demanded 

 

 

COMPLAINT FOR PATENT INFRINGEMENT

1. Plaintiff Gamehancement LLC (“Plaintiff”), through its attorneys, complains of 

Renesas Electronics Corporation (“Defendant”), and alleges the following: 

PARTIES

2. Plaintiff Gamehancement LLC is a corporation organized and existing under the 

laws of Delaware that maintains its principal place of business at 261 West 35th Street, Suite 

1003 New York, New York 10001. 

3. Defendant Renesas Electronics Corporation is a corporation organized and 

existing under the laws of Japan that maintains an established place of business at 3-2-24, 

Toyosu Toyosu Foresia Koto-Ku, Tokyo, 135-0061 Japan. 

JURISDICTION

4. This is an action for patent infringement arising under the patent laws of the 

United States, Title 35 of the United States Code. 

Case 2:23-cv-00599-JRG-RSP Document 1 Filed 12/13/23 Page 1 of 4 PageID #: 1
2 

5. This Court has exclusive subject matter jurisdiction under 28 U.S.C. §§ 1331 and 

1338(a). 

6. This Court has personal jurisdiction over Defendant because it has engaged in 

systematic and continuous business activities in this District. As described below, Defendant has 

committed acts of patent infringement giving rise to this action within this District. 

VENUE

7. Venue is proper in this District under 28 U.S.C. § 1391(c) because Defendant is a 

foreign corporation. In addition, Defendant has committed acts of patent infringement in this 

District, and Plaintiff has suffered harm in this district. 

PATENT-IN-SUIT

8. Plaintiff is the assignee of all right, title and interest in United States Patent No. 

7,046,252 (the “Patent-in-Suit”); including all rights to enforce and prosecute actions for 

infringement and to collect damages for all relevant times against infringers of the Patent-in-Suit. 

Accordingly, Plaintiff possesses the exclusive right and standing to prosecute the present action 

for infringement of the Patent-in-Suit by Defendant. 

THE ’252 PATENT

9. The ’252 Patent is entitled “Method and system for adaptive color and contrast for 

display devices,” and issued 2006-05-16. The application leading to the ’252 Patent was filed on 

2004-03-26. A true and correct copy of the ’252 Patent is attached hereto as Exhibit 1 and 

incorporated herein by reference. 

COUNT 1: INFRINGEMENT OF THE ’252 PATENT

10. Plaintiff incorporates the above paragraphs herein by reference. 

11. Direct Infringement. Defendant directly infringed one or more claims of the 

’252 Patent in at least this District by making, using, offering to sell, selling and/or importing, 

Case 2:23-cv-00599-JRG-RSP Document 1 Filed 12/13/23 Page 2 of 4 PageID #: 2
3 

without limitation, at least the Defendant products identified in the charts incorporated into this 

Count below (among the “Exemplary Defendant Products”) that infringed at least the exemplary 

claims of the ’252 Patent also identified in the charts incorporated into this Count below (the 

“Exemplary ’252 Patent Claims”) literally or by the doctrine of equivalents. On information and 

belief, numerous other devices that infringed the claims of the ’252 Patent have been made, used, 

sold, imported, and offered for sale by Defendant and/or its customers. 

12. Defendant also directly infringed, literally or under the doctrine of equivalents, 

the Exemplary ’252 Patent Claims, by having its employees internally test and use these 

Exemplary Products. 

13. Exhibit 2 includes charts comparing the Exemplary ’252 Patent Claims to the 

Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant Products 

practice the technology claimed by the ’252 Patent. Accordingly, the Exemplary Defendant 

Products incorporated in these charts satisfy all elements of the Exemplary ’252 Patent Claims. 

14. Plaintiff therefore incorporates by reference in its allegations herein the claim 

charts of Exhibit 2. 

15. Plaintiff is entitled to recover damages adequate to compensate for Defendant's 

infringement. 

JURY DEMAND

16. Under Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff respectfully 

requests a trial by jury on all issues so triable. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests the following relief: 

A. A judgment that the ’252 Patent is valid and enforceable 

Case 2:23-cv-00599-JRG-RSP Document 1 Filed 12/13/23 Page 3 of 4 PageID #: 3
4 

B. A judgment that Defendant has infringed directly one or more claims of the ’252 

Patent; 

C. An accounting of all damages not presented at trial; 

D. A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284 

for Defendant's past infringement at least with respect to the ’252 Patent. 

E. And, if necessary, to adequately compensate Plaintiff for Defendant's 

infringement, an accounting: 

i. that this case be declared exceptional within the meaning of 35 U.S.C. § 285 

and that Plaintiff be awarded its reasonable attorneys fees against Defendant 

that it incurs in prosecuting this action; 

ii. that Plaintiff be awarded costs, and expenses that it incurs in prosecuting 

this action; and 

iii. that Plaintiff be awarded such further relief at law or in equity as the Court 

deems just and proper. 

 

Dated: December 13, 2023 Respectfully submitted, 

 

 /s/ Isaac Rabicoff 

 Isaac Rabicoff 

 Rabicoff Law LLC 

 600 Mamaroneck Ave STE 400 

 Harrison, NY 10528 

 7736694590 

 isaac@rabilaw.com 

 

 

 Counsel for Plaintiff

Gamehancement LLC

Case 2:23-cv-00599-JRG-RSP Document 1 Filed 12/13/23 Page 4 of 4 PageID #: 4