Redwood Technologies, LLC v. Texas Instruments Incorporated

On March 29, 2023, Redwood Technologies, LLC (“Redwood” or “Plaintiff”), represented by Patrick J. Conroy, filed an intellectual property lawsuit against Texas Instruments Incorporated (“TI” or “Defendant”), seeking declaratory relief for alleged infringement of U.S. patents owned by the plaintiff. This case was filed in the U.S. District Court for the Eastern District of Texas.

Plaintiff filed this complaint for the alleged infringement of U.S. patent Nos. 7,359,457 (the “ʼ457 patent”), 7,688,901 (the “ʼ901 patent”), 7,974,371 (the “ʼ371 patent”), 8,284,866 (the “ʼ866 patent”) and 9,374,209 (the “ʼ209 patent”) (collectively, the “Asserted Patents”).

In the complaint, the plaintiff alleged, “TI has and continues to directly and/or indirectly infringe (by inducing infringement) one or more claims of the ’457 patent in this judicial district and elsewhere in Texas and the United States. TI directly infringes the ʼ457 patent via 35 U.S.C. § 271(a) by making, using, offering for sale, selling, and/or importing the Accused Products, their components and processes, and/or products containing the same that incorporate the fundamental technologies covered by the ’457 patent.”

The plaintiff further alleged, “The Accused Products, including the WL1807MOD, each comprise circuitry and/or components (hardware and/or software) that determine a modulation system from among a plurality of modulation systems based on a communication situation. The Accused Products, including the WL1807MOD, each comprise circuitry and/or components (hardware and/or software) that modulate a digital transmission signal according to the modulation system previously determined and generates a first symbol. The first symbol comprises a first quadrature baseband signal.”

Plaintiff additionally alleged, “On information and belief, despite having knowledge of the ’457 patent and knowledge that it is directly and/or indirectly infringing one or more claims of the ’457 patent, TI has nevertheless continued its infringing conduct and disregarded an objectively high likelihood of infringement. TI’s infringing activities relative to the ’457 patent have been, and continue to be, willful, wanton, malicious, in bad-faith, deliberate, consciously wrongful, flagrant, characteristic of a pirate, and an egregious case of misconduct beyond typical infringement such that Plaintiff is entitled under 35 U.S.C. § 284 to enhanced damages up to three times the amount found or assessed.”

Plaintiff also alleged, “TI has and continues to directly and/or indirectly infringe (by inducing infringement) one or more claims of the ’901 patent in this judicial district and elsewhere in Texas and the United States. TI directly infringes the ’901 patent via 35 U.S.C. § 271(a) by using and/or testing the Accused Products, their components and processes, and/or products containing the same that incorporate the fundamental technologies covered by the ’901 patent.”

The plaintiff further alleged, “Redwood is entitled to recover from TI the damages sustained by Plaintiff as a result of TI’s wrongful acts, and willful infringement, in an amount subject to proof at trial, which, by law, cannot be less than a reasonable royalty, together with interest and costs as fixed by this Court.” 

Plaintiff stated five claims for relief for the alleged infringement of the Asserted Patents owned by the plaintiff. 

In the prayer for relief, the plaintiff requested declaratory relief and an award of damages together with pre- and post-judgment interest and costs incurred by the plaintiff.

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