IP Edge’s Bishop Display Keeps Filing in Couplets

February 10, 2024

Bishop Display Tech LLC has filed two cases against LG Display, LG Electronics (LGE), and WOOREE BIO (New Optics) together in a pair of Eastern District of Texas complaints (2:24-cv-00084, 2:24-cv-00085) and Heesung Electronics in another pair of complaints (2:24-cv-00086, 2:24-cv-00087) in the same district. The plaintiff, managed by the three principals of Texas monetization firm IP Edge LLC, targets the provision of thin-film-transistor liquid-crystal displays (TFT-LCDs), as well as products incorporating the accused TFT-LCDs (e.g., liquid crystal modules (LCMs), monitors, smartphones, tablets, and TVs).

In the -84 and -86 cases, Bishop Display Tech asserts six LCD patents (6,525,798; 6,787,829; 6,801,293; 6,816,208; 6,850,303; 6,906,769), while in the -85 case, it asserts another six (6,819,377; 6,822,706; 7,414,682; 7,583,347; 7,995,047; 8,093,830) and in the -87 suit, it asserts just four (the ‘377, ‘706, ‘682, and ‘347 patents). IP Edge acquired them from IP Bridge, Inc. in May 2019, through Parkside IP LLC (one of IP Edge’s many other controlled entities). The portfolio (of roughly 50 US patents) involves assets originating with Panasonic and Seiko Epson, with further background provided here.

Bishop Display Tech began litigating with a pair of April 2021 suits against Samsung, filed in the Eastern District of Texas, which were dismissed in May 2022 in light of an earlier noticed settlement. That October, Bishop Display Tech hit Innolux with another pair of lawsuits, again in East Texas, which also ended after the parties noticed a settlement.

In the -84 and -85 cases, the plaintiff pleads that joinder is proper because the infringing conduct arises “out of the same transaction, occurrence, or series of transactions or occurrences”. Specifically, the plaintiff alleges that the LG Display-branded TFT-LCDs are “common to all Defendants’ infringement of the Asserted patents”, including through the accused New Optics LCMs (which incorporate the LG TFT-LCDs). Here, Bishop Display Tech pleads willful infringement, contending that the various LG entities have known about several of the patents-in-suit as early as February 2017, when LG Display “received notice of their infringement from a former patent owner Godo Kaisha IP Bridge 1”.

In the Heesung complaints, various LG-series products (e.g., TVs) are identified as incorporating the accused Heesung LCMs and TFT-LCDs, but LG is not named as a defendant there. Here, the plaintiff repeats the same facts (that LG Display received notice as early as February 2017 when it received notice of their infringement from Good Kaisha), further alleging that Heesung was on notice as a result of “indemnity, contractual, and/or its business with LGE, LGEUS, and/or LGD”.

In 2019 and 2020, IP Edge moved three batches of patents from the Parkside-held portfolio to other LLCs for assertion. Two of those LLCs launched litigation, in typical IP Edge fashion: Boracho IP Holdings LLC, waging a device charging campaign from September 2019 through November 2020; and Radent Licensing LLC, targeting pulse width modulation (PWM) control circuits in litigation stretching from April 2020 through August of last year. However, the third LLC, Enlighten IP LLC, never filed suit over its two assets (6,781,659; 7,499,115). Instead, in January 2021, Enlighten IP moved them to Bishop Display Tech, which had just received more than two dozen of the former IP Bridge patents, also from Parkside IP, in November 2020.

Boracho IP (in January 2019 naming Son Nguyen), Radent Licensing (in April 2020 naming Victor Halfon), and Enlighten IP (in August 2020 naming John Rathgeber, Jr.) all follow what had been IP Edge’s main assertion approach: an entity created in Texas, a longtime resident of Texas named as its managing member, patents assigned, and a litigation campaign pursued in settle-and-dismiss fashion. That approach screeched to a halt in late 2022 after it came under intense scrutiny from Delaware Chief Judge Colm F. Connolly. Hearings over compliance with standing orders that impose heightened disclosure on litigants in his courtroom gave rise to concerns from Judge Connolly, concerns that ultimately led him to issue letters to the US Department of Justice, to the USPTO, and to state bodies regulating attorneys—detailed coverage of this “Series of Extraordinary Events” is available on RPX Insight.

The founders of IP Edge (formed first in Nevada but then later, in 2015, in Texas)—Illinois attorney Gautham (Gau) Bodepudi and Texas attorneys Sanjay Pant and Lillian Woung—have less often formed a litigating LLC themselves, but they have done so. In May 2020, they created Q3 Networking LLC, which filed an ITC complaint (a first for the firm) over former Siemens patents, taking the litigation through an adverse final initial determination and subsequent appeal. October 2020 saw them form Bishop Display Tech, and 2022 gave rise to AdaptFlow Technologies LLC (in June), which litigated former Technicolor patents against Roku from September 2022 into August 2023; Solstice Wireless LLC (also that June), which litigated former Ajou University patents, also against Roku, from August 2022 into September 2023; and Communication Advances LLC (formed in August 2022), which has open litigation, in two separate campaigns as a formal matter, over former MediaTek patents, one case filed against Roku as well; the other, against GM.

For a broader view of IP Edge’s fall from its position atop the list of volume NPE filers, see “Funding Appears to Have Fueled Leading Volume NPE Filers, Present and Past” (January 2024). Chief Judge Rodney Gilstrap will preside over the new sets of Bishop Display Tech cases. 2/8, Eastern District of Texas.