In late March, Semiconductor Energy Laboratory Co., Ltd. (SEL) filed a second suit in what appears to be its first US patent litigation campaign in roughly eight years. Last June, the plaintiff sued BOE Technology Group and Lenovo (Motorola Mobility), accusing the former of manufacturing allegedly infringing displays incorporated into smartphones, including the latter’s Motorola RAZR. January 2021 saw that case end in a settlement with BOE and a covenant not to sue Motorola Mobility. SEL has now accused TCL China Star Optoelectronics Technology (CSOT) of infringement (8:21-cv-00554) through the provision of display panels for smartphones, of TCL and, again, of Motorola Mobility but this time not naming the Lenovo subsidiary as a defendant.