RPX Weekly Newsletter

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

Monday, October 6, 2025

Top Insight

German Court and UPC Issue First-Ever Anti-Interim-License Injunctions in SEP Dispute

Earlier this year, the UK Court of Appeal issued a series of decisions holding that a standard essential patent (SEP) licensor must offer an interim license to an accused infringer that applies until a UK court sets the final terms of a fair, reasonable and non-discriminatory (FRAND) license—and that the SEP owner will be deemed unwilling if it fails to offer such a license. This prompted a response from Germany’s Munich I Regional Court, which in July issued guidance arguing that the UK approach threatened the jurisdiction of other European courts—and warning that injunctions could result if parties seek interim licenses. That has now occurred: The Munich court has just issued the first-ever “anti-interim-license injunction” (AILI) in response to a request from InterDigital, Inc., barring Amazon from seeking an interim license or a declaration that InterDigital had breached its FRAND obligations by declining to grant one. Soon after, the Mannheim Local Division (Mannheim LD) of the Unified Patent Court (UPC) issued a similar, parallel AILI, in the process detailing its own rejection of the UK approach. Both orders were issued on an ex parte basis (without a hearing for the opposing party).

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Patent Litigation Feature

“These Unique Facts” Prompt Unexpected Transfers, DWOPs, and Refilings

In 2024, Advanced Coding Technologies LLC (ACT) sued Apple in a pair of Eastern District of Texas suits, asserting in each three media encoding patents. Shortly thereafter, Avant Location Technologies LLC (ALT) sued Apple in the same district, asserting seven patents of its own. Motions to dismiss or transfer (for improper venue or, alternatively, for convenience) focused, in large part, on Apple Shops inside Best Buy stores. Late last month, District Judge Rodney Gilstrap granted the motions as modified, ruling “[u]nder these unique facts” that the cases should be sent to the Northern District of Texas, not to the Northern District of California (as requested). ACT and ALT promptly dismissed the cases opened there, ACT refiling a single lawsuit asserting the same six patents and ALT refiling its case—both in the Western District of Texas.

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Patent Watch

Touch Display, Image Sensor Campaigns Likely Coming

A review of recently released patent assignments recorded with the USPTO strongly suggests forthcoming patent litigation, from each of two Texas LLCs. One of those entities received a touch technologies portfolio; the other, an image sensor portfolio (broadly speaking). Each LLC is part of a different, established monetization operation, one of them with multiple ties to a prominent litigation funder.

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Hedge Fund Disclosed as Empire Technology’s Third-Party Litigation Funder

In early September, RPX flagged a “Supplemental Corporate Disclosure Statement” naming more than 30 nonpersons (including multiple universities) and individuals “as members and owners” of Empire Technology Development LLC, “including the individuals and corporations with a direct or indirect interest” in the firm. Now, via a “Statement Regarding Third-Party Litigation Funding Arrangements”, the plaintiff has disclosed a notable funding source—a hedge fund that RPX research has tied to a significant number of patent holders to date.

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New Patent Litigation

New ITC Complaint Added to Long-Running, Complicated Netlist Campaign

Netlist, Inc. has filed a complaint before the International Trade Commission (ITC), naming as proposed respondents Alphabet (Google), Samsung, and Super Micro Computer (337-TA-3854). Six patents are asserted, with infringement allegations focused on certain Samsung DDR5 generation Dual In-line Memory Modules (DIMMs) and certain Samsung HBM2/2E, HBM3/3E, and HBM4/4E high bandwidth memory (“HBM”) packages; "Google’s fifth, sixth and seventh generation Tensor Processing Units (TPUs) utilizing Samsung HBMs”, as well as “Google’s Google Cloud Platform (GCP) virtual machines and cloud storage services utilizing Samsung DIMMs and HBMs”; and certain Super Micro “servers and computing systems utilizing Samsung’s HBMs” and DIMMs.

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Cybersecurity Litigation Opens Against Cisco

Privakey, Inc. has filed an Eastern District of Texas complaint against Cisco (2:25-cv-00984). It asserts three patents broadly directed to authorizing user access to “internet services” or “remote services”, alleging infringement through the provision of Cisco Duo, which as well as the related Duo Mobile App, Duo Advantage, and Duo Premier platforms, as well as related components. The plaintiff includes requests for preliminary and permanent injunctions in its prayer for relief.

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K.Mizra Faces Second DJ Complaint in the Northern District of California

In response to a June 2025 complaint filed by Netskope in the Northern District of California against it, K.Mizra LLC has moved to dismiss for lack of personal jurisdiction, in the alternative asking District Judge Richard Seeborg to decline the exercise of declaratory judgment jurisdiction. The court has granted a Netskope request for limited relevant discovery, pushing a ruling to later this year. Already a K.Mizra defendant in the Western District of Texas, Alphabet (Google) (3:25-cv-08107) has filed its own declaratory judgment complaint in the Northern District of California.

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Having Survived an Earlier Alice Invalidation, Peer-to-Peer Media Delivery Plaintiff Navigates Unauthorized Practice of Law Challenges

This past June, citing multiple emails from William P. Ramey III concerning settlement, Alibaba moved the Northern District of California for sanctions against Cooperative Entertainment, Inc., asking the court to dismiss the case against it for Ramey’s continued unauthorized practice of law in California. Within a couple of weeks of that motion, the parties stipulated to a dismissal with prejudice. Since then, Cooperative Entertainment has filed three cases, against Vocal Technologies (1:25-cv-00466) in the Western District of New York, Cloudflare (7:25-v-00392) in the Western District of Texas, and IBM (2:25-cv-01004) in the Eastern District of Texas. The plaintiff’s list of interested nonparties has shifted over the years of this campaign.

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From Every Angle, New Litigation Campaign Looks Familiar

Iridescence LLC, a plaintiff apparently controlled by a prolific figure in patent monetization, has filed its first cases, one against each of Amazon (2:25-cv-00991) and Shelly Group (2:25-cv-00992) in the Eastern District of Texas. The sole asserted patent generally relates to a certain “Smart Gateway Power Control (SGPC) system”, with infringement allegations targeting the provision of smart plugs that include a wireless switch.

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Polaris Wireless Launches Litigation

In an Eastern District of Texas complaint, Polaris Wireless, Inc. has accused Samsung (2:25-cv-00980) of infringing six patents broadly directed to measuring “signals” to determine the location of a “wireless terminal”. The accused products are devices (i.e., Galaxy-series smartphones, tablets, and watches) that support location-based services such as the SmartThings Find service and Samsung Knox Asset Intelligence feature. District Judge Rodney Gilstrap has been assigned to preside.

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Dominion’s SPV One-Twos NXP

Sovereign Peak Ventures, LLC (SPV) has filed a pair of Western District of Texas complaints against NXP Semiconductors (1:25-cv-01573, 1:25-cv-01574). Across the two, the Dominion Harbor Enterprises, LLC plaintiff asserts a dozen former Panasonic patents, accusing NXP of infringement through the provision of NXP Application processors that support features for decoding/encoding the H.265/HEVC compression standard, Wi-Fi SoCs that support IEEE 802.11k/r, Access Point Systems that support the CAPWAP protocol, and wireless charging receivers and/or transmitters that support the Qi specification.

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ContactWave Files Round of September Suits

Last month, ContactWave LLC filed separate cases against Booking Holdings (Kayak Software) (1:25-cv-01189), GoBrands (1:25-cv-01190), TripAdvisor (1:25-cv-01187), and Yelp (1:25-cv-01186) in the District of Delaware. The plaintiff asserts a single patent broadly directed to sending messages from vendors to “mobile communication addresses of mobile users” after verifying that the user has provided “acceptance information”, with the defendants accused of infringement through the provision of their respective platforms and related digital advertisement services.

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Corent Technology Sues Microsoft over “Cloud Migration and Cloud Orchestration” Patents

Corent Technology, Inc. has filed its first apparent litigation with a suit against Microsoft (8:25-cv-02182) in the Central District of California. The four patents-in-suit are described by the plaintiff as “enabl[ing] cloud migration and cloud orchestration”. Microsoft is accused of infringement through the provision of “software for migration services, cloud orchestration, agile database connector enables SaaS database systems, and metering systems”, including “Microsoft Azure, Microsoft Azure Migrate, Microsoft Azure Kubernetes Service, Azure Marketplace, Azure Monitoring, and Azure SQL Database”.

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In Case You Missed It

Nonexistent Plaintiff Relaunches Litigation over Portfolio after Existent One Evaded Fees Shift

A plaintiff calling itself “Ziedman Technologies II LLC” has filed an Eastern District of Texas complaint against IBM (2:25-cv-01002). In it, this “Ziedman Technologies II LLC” characterizes itself as a Texas LLC, but Texas records contain no such entity. “Ziedman Technologies II LLC” asserts three patents that currently available USPTO assignment records suggest are held by ZT IP II LLC, an entity that does exist in Texas. A named inventor for these patents is Robert M. (“Bob”) Zeidman—not “Ziedman”. Ramey LLP provides representation here.

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