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VIDEOLABS, INC. v. TCL Technology Group Corporation et al

Docket 2:25-cv-00161, Texas Eastern District Court (Feb. 10, 2025)
District Judge Rodney Gilstrap, presiding, Magistrate Judge Roy S. Payne
Patent
DivisionMarshall
FlagsJRG1, JURY, PATENT/TRADEMARK
Cause35:271 Patent Infringement
Case Type830 Patent
Tags830 Patent, 830 Patent
Patent
7525535; 7769238; 7970059; 8139878; 8220027; 8291236; 8667304
75255357769238797005981398788220027
8291236
8667304
Plaintiff VIDEOLABS, INC.
Defendant TCL Technology Group Corporation
Defendant TCL Electronics Holdings, Ltd. (f/k/a TCL Multimedia Technology Holdings, Ltd.)
...
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No. 11 MOTION to Dismiss by All Defendants

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 11 (E.D.Tex. Mar. 12, 2025)
Motion to Dismiss (Demurrer)
P. 12(B)(5) ...................................................................................................... passim Case 2:25-cv-00161-JRG-RSP Document 11 Filed 03/12/25 Page 4 of 16 PageID #: Defendants TCL Technology Group Corporation et al. (collectively “Defendants” or “TCL”) are foreign entities located in China, Mexico, Hong Kong, and Vietnam and respectfully move the Court for dismissal under Federal Rule of Civil Procedure 12(b)(5) for improper service.
Case 2:25-cv-00161-JRG-RSP Document 11 Filed 03/12/25 Page 11 of 16 PageID #: On a Rule 12(b)(5) Motion, it is Plaintiff’s burden of establishing proper service of process for each Defendant.
Mar. 16, 2012) (“Because substituted service on the Texas Secretary of State for a nonresident defendant requires the transmittal of judicial documents abroad, the Hague Convention is implicated.”); Traxcell Techs., LLC v. Nokia Sols.
of State – Bureau of Consular Affairs website) to show that service of process by mail is improper in China and Mexico – two of the countries where several of the Defendants are located.
Both Plaintiff and TCL Communication (USA) are incorporated in Delaware and maintain principal places of business in California (see Exhibit A and Compl., ECF No. 1, ¶14).
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No. 1 COMPLAINT against Manufacturas Avanzadas S.A. de C.V., Schenzhen TCL New Technology Co. Ltd., ...

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 1 (E.D.Tex. Feb. 10, 2025)
Complaint
To this day, VideoLabs continues to promote an efficient, respected, and balanced intellectual property environment where technology companies have predictable design freedom and innovators who contribute impactful patented inventions can obtain fair and just compensation.
The parties to this action are properly joined under 35 U.S.C. § 299 because of the right to relief asserted against Defendants jointly and severally arises out of the same series of transactions and occurrences relating to the making, importing, using, offering for sale and selling of the same products or processes.
On information and belief, personal jurisdiction also exists specifically over each of the Defendants because they have overlapping executives, interlocking corporate structures and close relationships as manufacturer, importer and distributor of accused products.
As discussed with regard to the ’236 patent infra, both CAS and DRM systems are critically important technologies for securing valuable content programming intended for myriad consumer devices.
Case 2:25-cv-00161-JRG-RSP Document 1 Filed 02/10/25 Page 40 of 52 PageID #: 2014) (intent satisfied where defendant provided “technical support and services, as well as detailed explanations, instructions and information as to arrangements, applications and uses” of accused products).
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No. 10 SUMMONS Returned Executed by VIDEOLABS, INC

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 10 (E.D.Tex. Feb. 20, 2025)
06/12) Summons in a Civil Action
To: (Defendant’s name and address) TCL Technology Group Corporation c/o The Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701 A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure.
You also must file your answer or motion with the court.
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No. 9 SUMMONS Returned Executed by VIDEOLABS, INC

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 9 (E.D.Tex. Feb. 20, 2025)
TCL TECHNOLOGY GROUP CORPORATION, et al.
Defendant(s) To: (Defendant’s name and address) TCL Electronics Holdings, Ltd.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure.
You also must file your answer or motion with the court.
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No. 8

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 8 (E.D.Tex. Feb. 19, 2025)

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No. 7

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 7 (E.D.Tex. Feb. 18, 2025)

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No. 5

Document VIDEOLABS, INC. v. TCL Technology Group Corporation et al, 2:25-cv-00161, No. 5 (E.D.Tex. Feb. 11, 2025)

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