Universal Connectivity Technologies Inc. v. HP Inc.

Background

Universal Connectivity Technologies Inc. (UCT) brought a patent-infringement action against HP Inc. involving certain HP laptops, desktops, monitors, and docking stations. UCT alleged that the products infringed eight patents based on compliance with various standards involving USB, DisplayPort, PCIe power, and data transfer.

UCT served infringement contentions, later reduced the asserted claims to 70, and served updated contentions after the case was transferred from the Western District of Texas to the Northern District of California. After HP identified alleged deficiencies, the parties met and conferred. UCT proposed amended contentions, HP rejected them as still deficient, and UCT moved for leave to amend.

The parties also presented two related disputes: HP sought permission to brief a motion to strike UCT’s original and amended infringement contentions, and UCT sought permission to brief a motion to compel HP to amend its invalidity contentions.

Legal standard

Under Patent Local Rule 3-6, a party may amend infringement contentions only by court order after a timely showing of good cause. The court explained that good cause generally requires examining whether the moving party acted diligently and whether the amendment would prejudice the opposing party.

Ruling on UCT’s motion to amend

The court found that UCT was diligent. HP did not challenge UCT’s diligence, and the court concluded that UCT promptly evaluated HP’s concerns, met and conferred, proposed amendments, and moved for leave to amend less than two months after serving its first contentions in this District.

The court also found that HP had not shown prejudice. The proposed amendments added detail and evidence addressing the deficiencies HP had identified; they did not change UCT’s infringement theories or add products or claims. The amendments would not disrupt the case schedule or existing court orders.

HP argued that the amendments remained deficient and should be denied as futile. The court rejected HP’s argument that it should expand the Patent Local Rule 3-6 good-cause inquiry to include a futility analysis under Federal Rule of Civil Procedure 15(a). The court stated that it was not deciding the merits of HP’s arguments that the amended contentions remained deficient.

The court therefore granted UCT’s motion for leave to amend its infringement contentions. UCT was ordered to serve the amended contentions no later than June 3, 2025.

Related motions

Because the court granted leave to amend, it denied HP’s motion to strike the original infringement contentions as moot. The court nevertheless allowed abbreviated briefing on HP’s motion to strike the amended contentions. HP was ordered to file a supplemental brief within 14 days after UCT served the amended contentions, UCT was given 14 days to respond, and HP could file a reply within seven days after that response. The court stated that it would set a hearing if needed.

The court deferred UCT’s request to fully brief its motion to compel HP to amend its invalidity contentions because that dispute was premature while the motion to strike was pending. Within 10 days after resolution of the motion to strike, the parties must meet and confer about whether and to what extent HP will amend its invalidity contentions. If they cannot agree, they must submit a proposed briefing schedule within an additional three days.

Disposition

The order granted UCT’s motion for leave to amend infringement contentions, denied HP’s motion to strike the original contentions as moot, granted limited further briefing on HP’s motion to strike the amended contentions, and deferred briefing on UCT’s motion to compel amended invalidity contentions.