RPX Weekly Newsletter

An Update on Patent Litigation, the Patent Marketplace, and New Cases

Monday, December 8, 2025

Top Insight

Stakeholders Spar over USPTO Proposal to Limit AIA Reviews

On October 17, the USPTO published a Notice of Proposed Rulemaking (NPRM) that would place significant new limits on America Invents Act (AIA) reviews, barring institution unless petitioners stipulate not to raise invalidity challenges under Section 102 or 103 in parallel litigation, where the parallel forum would likely address validity on that basis before the Patent Trial and Appeal Board (PTAB) issues its final written decision, or where the patent’s validity has already been upheld by another forum. Public comments submitted by the December 2 deadline included feedback from a number of notable petitioner-defendants, licensors, NPEs, and other entities engaged in patent monetization. Meanwhile, the USPTO also received a letter in support of its proposal from some of the cosponsors of a PTAB reform bill before Congress—and a competing letter opposing the proposal from former legislators that either voted for the AIA or have since supported it.

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Patent Litigation Feature

California Judge Takes an Alice Scythe to Seven Patents Asserted by “Serial Litigant”

Central District of California Judge Serena R. Murillo recently marched through seven unrelated former Intellectual Ventures LLC (IV) patents asserted by Empire IP LLC plaintiff IoT Innovations LLC against Lutron Electronics, invalidating them one by one under Alice. Lutron quickly notified Southern District of Florida Judge Melissa Damian, who presides over the other case filed by IoT Innovations against Lutron, of the development, arguing that the ruling bolsters its arguments in a pending motion in that court for transfer to California. IoT Innovations counters that the invalidation order came “in a different case involving different patents, different claim language, different technological fields, and” different controlling law, the plaintiff urging Judge Damian therefore to “ignore it”.

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Patent Watch

Largest Bulk Filing Operation Scoops Up More Patents

Patent assignments recently made public by the USPTO show assets on the move from a plaintiff that appears to have just ended its most cantankerous set of litigation disputes, from multiple sources to entities linked to an ever-growing monetization operation, from an established Texas assertion firm to newer entrants, and from a company operating in the AI space to an entity with a curious address.

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New Patent Litigation

Autonomous Vehicle Systems the Focus of Perrone Robotics Campaign

Perrone Robotics, Inc., together with its subsidiary Perrone Robotics Innovations LLC (PRI), has filed separate lawsuits against Hyundai (3:25-cv-00981), Mazda (3:25-cv-00983), Nissan (3:25-cv-00982), Tesla (3:25-cv-00974), and Volkswagen (3:25-cv-00984) in the Eastern District of Virginia, as well as against Kia (2:25-cv-01151) and Toyota (2:25-cv-01150) in the Eastern District of Texas. The plaintiff characterizes the five patents in suit against each defendant as “generally describ[ing] a GPROS [general purpose robotics operating system] to manage an autonomous vehicle service”, with infringement allegations targeting the provision of vehicles with certain advanced driver assistance systems (ADASes, e.g., Hyundai SmartSense, Mazda i-ACTIVSENSE, Nissan ProPILOT Assist, Volkswagen IQ.DRIVE, etc.).

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After Earlier Indefiniteness Invalidations, TVnGO Returns to Court with Reissued Patents

In a Western District of Texas complaint, TVnGO Ltd. has accused Samsung (7:25-cv-00549) of infringing two reissued patents described by the plaintiff as disclosing the “ability to merge broadcast TV signals with IP packet data at a user’s home”. Targeted is the provision of smart TVs, including the Samsung 55” QN90C Neo QLED 4K Smart TV, that incorporate/support the Tizen Operating System, as well as the Smart Hub, Samsung TV Plus, and Multi View services. The components, taken together, are alleged to function as a “TV-Internet Integration Box”.

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From Broadcom to NXP for K.Mizra

K.Mizra LLC accuses NXP Semiconductors (7:25-cv-00557) in a Western District of Texas complaint of infringing the same two former Intel patents asserted against Broadcom there in April. That earlier suit is already over, dismissed with prejudice last month after the parties noticed a settlement. The plaintiff again targets provision of devices (i.e., chipsets and Systems-on-Chip (SoCs)) that support Wi-Fi 5, 6, and/or 7. K.Mizra received the two asserted wireless communications patents in a July 2024 assignment from Daedalus Prime LLC.

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In First Litigation, Topwire Targets Apple and Samsung

Topwire LLC has begun litigating a single semiconductor packaging patent with separate cases against Apple (7:25-cv-00551) in the Western District of Texas and Samsung (2:25-cv-01183) in the Eastern District of Texas. The defendants are accused of infringement through the provision of smartphones that include a “double-layered logic board with two substrates”; for Apple, of the iPhone X-series smartphones and later; and for Samsung, of certain Galaxy 10-series smartphones and later.

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Inventor-Controlled Plaintiff Initiates Litigation over “3D Memory” Products

Inventor-controlled MonolithIC 3D Inc. has filed its first litigation with cases against KIOXIA (2:25-cv-01160) and SK hynix (2:25-cv-01167; 2:25-cv-01176) in the Eastern District of Texas. The 18 patents-in-suit, asserted in overlapping sets, are described by the plaintiff as generally related to “semiconductor memory devices and fabrication methods”. The defendants are accused of infringement through the provision of “products comprising 3D memory”, including at least all “3D NAND memory” and/or “high bandwidth memory”.

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TIR Technologies’s Media Campaign Hits Disney

Disney (and its various subsidiaries, including BAMTech, ESPN, fuboTV, and Hulu) (8:25-cv-02652) is the latest defendant to be added to the sole litigation campaign of TIR Technologies Limited, which has seen Amazon, Comcast, and Meta Platforms sued since its start in June 2025. In the new Central District of California complaint, the plaintiff—linked to Dublin-based monetization firm Atlantic IP Services Limited—asserts four patents broadly directed to various aspects of media technologies. Disney is accused of infringement through the provision of the “Disney+, Hulu, Hulu+ Live TV, ESPN+, ESPN Select, ESPN Unlimited, and fuboTV video streaming services using multiple content delivery networks (‘CDNs’), including those of Amazon Web Services”. At issue are features related to media playback, video optimization, and traffic monitoring.

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Array Cache Technologies Sues NVIDIA

Array Cache Technologies LLC, a funded plaintiff, has filed a Western District of Texas case against NVIDIA (7:25-cv-00547), asserting five patents received from the portfolio that the plaintiff received from Eta Scale AB this past April. Targeted is the provision of various graphical processing units (GPUs), systems-on-chip (SoCs), and processors, “including, but not limited to, DGX Systems, Grace Systems, HGX Systems, IGX Systems, MGX Systems, OVX Systems, Jetson Systems, AGX Systems, and GeForce Graphics Cards since November, 2019”. The complaint focuses on the Grace Hopper GH200, an NVIDIA AI “superchip”, as the exemplary accused product.

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Superior Communications Follows Its District Court Case with an ITC Complaint

In October, Superior Communications, Inc. filed a Central District of California case against Hon Hai Precision Industry (Belkin) (2:25-cv-09759), targeting the provision of various screen protectors and related tray products for applying such screen protectors to devices with eight patents. Now, Superior has asserted four of those patents in a new complaint before the International Trade Commission (ITC) that names Belkin (337-TA-3861) as a proposed respondent.

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In Case You Missed It

Longtime Collector Appears to Have Divested More Patents

In late October, Information Exchange Technologies LLC (IET), an Empire IP LLC plaintiff, launched a new campaign. The Texas entity accused Entertainment Benefits Group (7:25-cv-00491) in a Western District of Texas complaint of infringing two metasearch engine patents, targeting the provision of the Undercover Tourist app, which allows users to “compare and book theme park tickets, cruises, hotels, and tickets to other attractions and live events”. The suit marked the second time that patents held by a previous collector have appeared in US litigation.

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