Universal Connectivity Technologies Inc. v. Lenovo Group Limited

2:23-cv-00449Txed30 janv. 2026

Texte intégral

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
UNIVERSAL CONNECTIVITY
TECHNOLOGIES INC.,
Plaintiff,
v.
LENOVO GROUP LIMITED,
Defendant.
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CIVIL ACTION NO. 2:23-CV-00449-JRG
MEMORANDUM OPINION AND ORDER
The Court held a Pretrial Conference in the above-captioned case on January 21, 2026
regarding pending pretrial motions, motions in limine (“MILs”), and disputed exhibits between
Plaintiff Universal Connectivity Technologies Inc. (“Plaintiff,” or “UCT”) and Defendant Lenovo
Group Limited (“Defendant,” or “LGL”) (collectively, the “Parties.”) (Dkt. Nos. 232, 233, 234,
235, 236, 237, 238, 239, 240, 241, 280, 281, 319.) This Order memorializes the Court’s rulings on
the pretrial motions, MILs, and disputed exhibits as announced from the bench and read into the
record, including additional instructions that were given to the Parties. While this Order
summarizes the Court’s rulings as announced into the record during the Pretrial Conference, this
Order in no way limits or constrains such rulings from the bench. Accordingly, it is hereby
ORDERED as follows:
1. 	LGL’s Unopposed Motion for Leave to Present One Additional Testifying Expert
Witness (Dkt. No. 319).
The motion was GRANTED as unopposed.
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2. 	LGL’s Motion for Summary Judgement of No Infringement With Respect to U.S.
Patent No. 7,746,798 (Dkt. No. 235).
The motion was GRANTED. The Court determined that under the Parties’ agreed
construction of “synchronization symbol,” a symbol must both “mark the start” of a packet and
“coordinate events,” and that a symbol does not coordinate events merely by virtue of it marking
the start of the packet. In light of this determination regarding claim construction, the Court found
that there was no support in the record for a finding of infringement of the ’798 patent, given that
UCT’s expert testimony did not provide a basis on which a reasonable jury could find that the
synchronization symbols coordinate events independent of their marking the start of the packets.
3. 	LGL’s Motion to Exclude Expert Testimony of Dr. Vijay Madisetti (Dkt. No. 236).
The motion was GRANTED-IN-PART and DENIED-IN-PART.
On the issue of Dr. Madisetti’s opinions regarding the alleged incremental benefits on the
patents-in-suit, the Court granted the motion to exclude this testimony. The Court found that Dr.
Madisetti’s report failed to sufficiently tie his conclusions, which he derived from the standards,
back to the asserted patents, given that the asserted patents are not standard essential by UCT’s
own admission.
On the issue of Dr. Madisetti’s “new” theories that LGL contests were not disclosed in
UCT’s infringement contentions, the Court denied as moot the part of the motion relating to the
’798 patent, granted the part of the motion relating to claim 74 of the ’307 patent to reflect the
Parties’ agreement and representation not to assert such theories as to claim 74 of the ’307 patent,
and the Court otherwise determined that UCT’s infringement contentions had sufficiently
disclosed Dr. Madisetti’s theories and denied the remainder of the motion.
Following this ruling from the Court, UCT asked if it might seek leave to supplement Dr.
Madisetti’s report. The Court ORDERED that UCT submit a written motion to the Court with a
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proposal for when and how it requests leave to supplement Dr. Madisett’s report by 12:00 p.m. on
January 26, 2026. LGL may respond to this motion by 12:00 p.m. on January 29, 2026, and no
further briefing will be considered by the Court. Thereafter the Court will rule on such request.
4. 	UCT’s Motion to Stike and Exclude Opinions of Henry Direen (Dkt. No. 239).
The motion was DENIED AS MOOT in light of the Court’s ruling on Dkt. No. 235
(granting summary judgement of no infringement of the ’798 patent).
5. 	LGL’s Motion to Exclude and Strike Expert Testimony of Mr. Nigel Jones (Dkt. No.
238).
The portion of the motion regarding Mr. Jones’ opinions on the representativeness of third-
party source code directories was GRANTED. The Court found that Mr. Jones does not provide
a sufficient explanation of his methodology in his report to support his ultimate conclusion that
the differences between the source code directories he examined were not material.
The portion of the motion regarding Mr. Jones’ opinions on “synchronization symbols”
was DENIED AS MOOT in light of the Court’s rule on Dkt. No. 235 (granting summary
judgement of no infringement of the ’798 patent).
The Court ORDERED UCT to include any potential requests to supplement Mr. Jones’
report in its motion to be submitted by 12:00 p.m. on January 26, 2026.
6. 	UCT’s Motion to Exclude Noninfringing Alternative Testimony of James Geier,
Robert Dezmelyk, Harry Direen, and DeForest McDuff (Dkt. No. 241).
The motion was GRANTED-IN-PART and DENIED-IN-PART.
The Court denied the portion of the motion seeking to exclude the broad noninfringing
alternative testimony in these experts’ opening reports.
The Court granted the portion of the motion seeking to exclude testimony asserting the
Qualcomm-based products specifically as noninfringing alternatives in the experts’ rebuttal
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reports. The Court found that LGL had not met its burden to raise and establish the applicability
of the named Qualcomm-based products as noninfringing alternatives, given the experts’ own
admissions they had not examined source code or technical documentation regarding these
products.
7. 	LGL’s Motion to Exclude Expert Testimony of Dr. Reed-Arthurs (Dkt. No. 237).
The motion was GRANTED-IN-PART and DENIED-IN-PART.
The Court granted the portion of the motion seeking to exclude Dr. Reed-Arthurs’
opinions on the survey for the ’905, ’307, and ’798 patents in light of its ruling on Dkt. No. 236
(granting the motion to strike the portions of Dr. Madisetti’s report on which Dr. Reed-Arthurs
relied to reach this opinion).
The Court denied the portion of the motion regarding damages calculations for the ’231
patent, finding that Dr. Reed-Arthurs properly relied on opinions of Dr. Madisetti that have
survived Daubert motion practice, and the Court denied the remainder of the motion.
8. 	UCT’s Motion for Partial Summary Judgement of No Invalidity of U.S. Patent No.
7,746,798 (Dkt. No. 240).
The motion was DENIED AS MOOT in light of the Court’s ruling on Dkt. No. 235
(granting summary judgement of no infringement of the ’798 patent), given that the invalidity
contentions 	in 	this 	case 	are 	only 	asserted 	as 	affirmative 	defenses 	and 	not 	independent
counterclaims.
9. 	LGL’s Motion for Partial Summary Judgement of No Infringement with Respect to
U.S. Patent No. 7,187,307 (Dkt. No. 234).
The motion was DENIED. The Court determined that factual disputes remain which
preclude summary judgement on the question of infringement of the ’307 patent.
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10. LGL’s Motion for Partial Summary Judgement Regarding License Defense (Dkt. No.
232).
The motion was DENIED. The Court determined that the motion did not present any
dispute which would open the door to judicial interpretation of the license at issue.
11. LGL’s Motion for Summary Judgement of No Constructive Notice (Dkt. No. 233).
The motion was GRANTED-IN-PART and DENIED-IN-PART.
Regarding the Apple products, the Court granted the motion. The Court expressly found
that an expert’s reliance on a Wikipedia article is not reliable and therefore is not appropriate
summary judgment evidence. The Court further found that all Apple products had been properly
disclosed, as the Court had previously determined in its earlier order denying UCT’s motion to
strike. Accordingly, the Court granted summary judgement of no constructive notice on the five
Apple products.
Regarding the Intel products, the Court denied the motion. The Court found that Dr.
Madisetti provided sufficient analysis in his report to create an issue of material fact that precludes
an entrance of summary judgement.
12. Parties Opposed Motions in Limine (Dkt. Nos. 280, 281).
a. 	UCT’s Motion in Limine 1: no evidence, testimony, or argument as to Wi-LAN’s
owners, subsidiaries, or related entities (other than UCT), or statements that Wi-LAN
has created shell companies, a web of companies, or other statements that would
unduly emphasize the number of companies owned by, or related to, Wi-LAN.
This MIL was GRANTED, with the clarification that Wi-LAN may be mentioned in the
case but only on a factual, background basis regarding its relationship to UCT.
b. 	UCT’s Motion in Limine 2: no evidence, testimony, or argument that any LGL accused
product is covered by any LGL or third-party patent.
This MIL was GRANTED by agreement of the Parties as stated in their briefing.
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c. 	UCT’s Motion in Limine 3: no evidence, testimony, or argument regarding a party’s
prior or current law firm’s or the party’s (including related entities) retention of the
same expert in other litigation.
This MIL was GRANTED by agreement of the Parties as read into the record. The Parties
reached an understanding that this MIL does not prevent questioning the experts regarding the
number of times they have testified for a given plaintiff or defendant.
d. 	UCT’s Motion in Limine 4: no evidence, testimony, or argument that uses the
prosecution history for any claim construction or claim scope argument.
This MIL was DENIED AS MOOT in light of the Court’s ruling on Dkt. No. 235 (granting
summary judgement of no infringement of the ’798 patent).
e. 	UCT’s Motion in Limine 5: no evidence, testimony, or argument that it was improper
for an expert to submit an errata or supplemental expert report or that such submission
indicates any error or deficiency in the original report.
This MIL was GRANTED as to supplemental reports but DENIED as to erratas. The
Court determined that the jury can consider whether a witness submitted a substantial number of
corrections in the form of an errata in weighing the credibility of their testimony, but the Court
directed that the Parties not mischaracterize an errata as anything beyond the correction of an
unintended error.
f. 	LGL’s Motion in Limine 1: exclude evidence and argument regarding total revenue
and profits of accused products.
This MIL was GRANTED. The Court noted that it has a pre-existing standing MIL No. 3
which precludes mentioning a party’s overall financial size, wealth, or executive compensation,
and that it sees this MIL as an appropriate corollary to that. UCT is required to seek leave to
mention total revenues or profits for the accused products, if they determine that such numbers
will be necessary for Dr. Reed-Arthurs to mention when testifying about her damages calculations.
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g. 	LGL’s Motion in Limine 2: exclude evidence and argument regarding standards-based
infringement theories.
This MIL was DENIED as overly broad. The Court clarified that the Parties are not to
improperly use the dropped standards-based positions and arguments from earlier in this case, but
they may be mentioned to the extent the evolution of the parties’ positions throughout the duration
of this case are relevant to issues at trial.
h. 	LGL’s Motion in Limine 3: exclude testimony and argument that LGL fact witnesses
have not read the asserted patents.
This MIL was GRANTED, with the substantive addition: “exclude testimony and
argument that LGL fact witnesses have not read the asserted patents unless the witness has been
previously designated for deposition on any issue related to the patents.”
13. Parties’ Exhibit Disputes
UCT’s exhibits PTX-006 and PTX-007 are not preadmitted as they currently exist, but the
Parties read into the record an agreement to prepare redacted versions of those exhibits consistent
with the Court’s order on LGL’s MIL No. 1, which will resolve the dispute and allow these exhibits
to be preadmitted. As such and with appropriate redactions these exhibits are PRE-ADMITTED.
In addition, UCT’s exhibits PTX-008, PTX-027, PTX-028, PTX-029, and PTX-030 are
PRE-ADMITTED.
LGL’s exhibits DTX-001, DTX-002, DTX-003, DTX-004, DTX-006, DTX-007, DTX-
008, DTX-009, DTX-010, DTX-011, DTX-012, and DTX-018 are PRE-ADMITTED.
The Court heard argument on PTX-004 and PTX-005, and these exhibits were not pre-
admitted in light of LGL’s Rule 403 and 408 objections and the Court’s concern about a risk of
jury confusion and skewing the damages horizon. The Court excluded them as pre-admitted
exhibits but did not strike them as attachments to Dr. Reed-Arthurs’ expert report, and informed
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UCT that it may approach the bench and seek leave to use these documents as demonstratives if
during trial it believes it can persuade the Court that the use of these documents have significant
substantive and probative value in light of how the case has developed.
____________________________________
RODNEY GILSTRAP
UNITED STATES DISTRICT JUDGE
So ORDERED and SIGNED this 29th day of January, 2026.
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