District Judge Richard G. Andrews has invalidated claims from two patents “directed to a ‘nano gas sensor device’ that detects and changes in reaction to the presence of a gas, chemical, or biological object” under Alice. The court held that the claims are patent-ineligibly directed to the abstract idea of a sensor, observing along the way that the plaintiff, NPE Rondevoo Technologies, LLC, has filed numerous complaints throughout the country with “virtually no real litigation in any of these cases”. Judge Andrews’s order comes as the Western District of Texas has cemented its place at the top of the list of patent venues favored by NPE plaintiffs, outpacing Delaware in the first quarter.

After three attempts to sue the manufacturer of Anker’s Roav SmartCharge Car Kit, Hailo Technologies, LLC has changed tacks, this time accusing retailers Best Buy (4:20-cv-00025), Target (4:20-cv-00026), and WalMart (4:20-cv-00024) of infringement through sales of the devices. The plaintiff first sued Roav in January 2018, shifting to Anker by amended complaint in that same case, which was dismissed for improper service. Hailo then, in May of last year, tried suing Anker in the Western District of Washington but voluntarily dismissed the suit, without prejudice, after Anker reiterated by letter that it is “a holding company registered in Hong Kong and does not have an agent for service of process in the United States”—the standoff triggering the current retailer suits.

Optima Direct, LLC has expanded its sixth litigation campaign with two new Eastern District of Texas suits, one each against Oracle (2:19-cv-00380) and Symantec (2:19-cv-00381). At issue is the same secure document transmission patent asserted in complaints filed this month against Citrix (1:19-cv-02091) in the District of Delaware and Dropbox (1:19-cv-01098) in the Western District of Texas. The defendants are accused of infringement through the provision of software platforms that feature secure file sharing and syncing through encryption or hashing. Oracle is targeted over the BEA Tuxedo Security system and Symantec, over the Symantec Desktop Email Encryption feature of the NortonLifeLock PGP platform.

Last week Optima Direct, LLC filed suit against Dropbox (1:19-cv-01098) in the Western District of Texas over the same secure document transmission patent asserted in its complaint against Citrix (1:19-cv-02091), filed in the District of Delaware one week before. File sharing and syncing features in the defendants’ respective products—Dropbox and Citrix Files App—are accused. This new campaign is the sixth that Optima Direct has launched in just over a year.

TZU Technologies LLC, one of the “licensing programs” under “intellectual property accelerator” 2S Ventures, LLC, has launched a second litigation campaign, this one over a patent, generally related to a “self-articulating behind-wall camera”, from a family familiar to litigation. The NPE has accused Fluke (2:19-cv-00561), Milwaukee Electric Tool (1:19-cv-00651), and Optim (1:19-cv-00709) of infringement through the provision of diagnostic scopes (e.g., a videoscope for insertion and inspection of a vehicle’s gas tank). The subject matter of TZU Technologies’s prior litigation campaign suggests that the proper pronunciation of the plaintiff’s name is meant to be “tease you”.

On March 21, 2019, individual inventor Bao Tran assigned to California entity Rondevoo Technologies, LLC a portfolio that includes 16 US patents generally related to “nano” sensors, circuit elements, packaging, and genetic engineering. That same day, Tran assigned to Eloqui Voice Systems, LLC (EVS) a set of three US patents, two of them generally pertaining to speech recognition systems, and the third, to a “smart system powered by a light socket”. Both Rondevoo and EVS can be traced through Red Dragon Innovations, LLC to attorney Daniel C. Cotman of Cotman IP. With both Rondevoo and EVS already in litigation, over patents acquired separately, these latest transfers suggest that more campaigns or cases may be coming.

Rondevoo Technologies, LLC has added a case against HMD Global and Nokia (1:19-cv-00595) to its litigation campaign over a single patent that generally pertains to “clustering” keys on an input device, such as a telephone keypad or computer keyboard, to facilitate selection entry. The NPE has targeted the ability to enter alternate (e.g., accented) characters through the keypads of certain Android smartphones in complaints filed earlier against HTC, LG Electronics (LGE), Sony, and ZTE, calling out the Nokia 9 PureView in its latest complaint. The case against Sony was dismissed without prejudice (before an answer was filed) in January 2019, while the ZTE suit was dismissed in March, with prejudice in light of a settlement after the defendant answered. HTC has also answered, while the court granted LGE an extension of the deadline to respond Rondevoo’s complaint.

Rondevoo Technologies, LLC has opened up a second litigation campaign, filing a District of Delaware suit against LG Electronics (LGE) (1:18-cv-00860) and a Northern District of Illinois suit against Sony (1:18-cv-03950). The NPE asserts a single patent generally related to “clustering” keys on an input device, such as telephone keypad or computer keyboard, to facilitate selection entry, with infringement allegations focused on the ability to enter alternate (i.e., accented) characters through the keypads of certain Android smartphones—e.g., Sony’s Xperia Z5 and the LG G3. Rondevoo pleads that the “inventors” recognized “a need for improving cluster key arrangements for mobile devices such as cell-phones”, citing to the patent’s abstract for the statement that “[t]his cluster key arrangement may be mechanically configured or electronically configured”.

A late May assignment suggests that courts may soon see litigation filed by a plaintiff with connections to 2S Ventures, LLC—an “intellectual property accelerator” with apparent ties to several litigating NPEs. Meanwhile, former Intellectual Ventures LLC (IV) assets continue to spread among NPEs, with one assignee (a top filer in 2017) kicking off three new campaigns in April-May involving IV divestitures.

Secure Cam, LLC, an NPE formed in Wyoming last July, has filed its first lawsuit, suing Project Nursery (5:18-cv-02335), a San Francisco-based company established by two friends “who set out to help parents find the vision, tools, and products for all their baby nursery and kid-friendly decorating projects”. Project Nursery notes that its brand “now includes various licensed products such as [its] exciting new line of nursery electronics, including the Project Nursery Baby Monitor and Sight & Sound Projector (a Techlicious Best of CES Award-winning joint venture with VOXX International)”, available through various retailers. The company now accused of infringing one patent, generally related to transmitting video images over a network, through the manufacture and sale of some of those baby monitors.