Neodron Ltd. v. Lenovo Group Ltd.

Background

Neodron filed a patent-infringement action involving seven asserted patents concerning touchscreen and other touch-input technology. The opinion identifies Lenovo Group Ltd., Lenovo Inc., and Motorola Mobility LLC as defendants. Neodron alleged that products including the Lenovo Yoga 730, Motorola Moto G6, and Lenovo ThinkPad X1 Yoga infringed various asserted patents. The defendants denied infringement and contended that the patents were invalid.

The order addressed proposed constructions for four terms under the parties’ joint claim-construction statement and also addressed motions to strike.

Claim constructions

’286 patent: “sensor value”

The court construed “sensor value” as “measurable sensor signal value.” The defendants had proposed “value indicating the strength of the sensor signal.” The court concluded that the patent did not expressly redefine or disclaim the broader meaning of “sensor value,” and that the preferred embodiments and patent context did not justify limiting the claim term to the defendants’ proposed wording.

’502 patent: “sensing area”

The court construed “sensing area” as “an area defined by the sensing cells.” The defendants had proposed “an area defined by the sensing electrodes.” The court reasoned that the defendants’ interpretation would make the claim’s separate reference to sensing cells unnecessary and did not fit the contextual claim language.

’502 patent: wrap-around connections

For the language concerning row sensing electrodes being connected by “row wrap-around connections made outside of the sensing area,” the court adopted a construction based on the plain and ordinary meaning: “wherein row sensing electrodes of sensing cells at opposing ends of at least one of the rows are electrically coupled to one another by connections that wrap around the respective row and are made outside the sensing area.” The court explained that the connection must run from one vertical side of the sensing area to the other vertical side and curve around the respective row, rather than run from a vertical side to a horizontal side.

’770 patent: “generally straight line”

The defendants argued that “generally straight line” was indefinite under 35 U.S.C. § 112 because it lacked objective boundaries. The court rejected that argument, concluding that the defendants had not overcome the patent’s presumption of validity with clear and convincing evidence. The court held that the term is not indefinite and retains its plain and ordinary meaning. The court relied in part on the specification’s use of related terms such as “generally quadrilateral,” “generally rectangular,” and “generally parallel.”

Motions to strike

The defendants moved to strike Neodron’s second supplemental declaration from Richard A. Flasck and references to or reliance on that declaration in Neodron’s responsive claim-construction brief. The defendants argued that the declaration was untimely and prejudicial. Neodron argued that the declaration properly responded to the defendants’ arguments that “generally straight line” was indefinite.

The court granted the defendants’ motion to strike. It held that Neodron had not timely disclosed the supplemental testimony under the amended schedule and the local patent rules. The court struck the supplemental declaration and any reference to or reliance on it in Neodron’s responsive brief.

The court also granted Neodron’s motion to strike its own claim-construction reply brief. The opinion states that Neodron voluntarily withdrew that brief after discovering that the defendants had interpreted the scheduling order as prohibiting reply claim-construction briefs.

Disposition

The court adopted the claim constructions set out in the order, granted the defendants’ motion to strike Neodron’s second supplemental declaration, and granted Neodron’s motion to strike its own claim-construction reply brief.