Court: U.S. Court of Appeals for the Federal Circuit

Docket: 23-2117 

Opinion Date: August 8, 2025

The dispute centers on allegations by Mondis Technology Ltd. and related entities that LG Electronics Inc. and its U.S. subsidiary infringed claims 14 and 15 of U.S. Patent No. 7,475,180. The patent describes a display unit, such as a computer monitor, that stores identification numbers in memory to control access by external devices. The key issue was whether the patent’s written description supported a claim limitation requiring an “identification number for identifying at least a type of said display unit,” as opposed to identifying a specific unit.

After Mondis filed suit in the Eastern District of Texas, the case was transferred to the United States District Court for the District of New Jersey and stayed for patent reexamination. When some claims survived, litigation resumed on claims 14 and 15. A jury found the claims not invalid and infringed, awarding damages to Mondis. The district court denied LG’s motion for judgment as a matter of law (JMOL) on invalidity, relying on the presumption of validity and the jury’s ability to weigh expert testimony. The court vacated the initial damages award and ordered a retrial, after which a reduced damages award was entered. Both parties appealed.

The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL. The appellate court held that no reasonable jury could find the patent’s written description adequately supported the claim limitation requiring identification of a type of display unit. The court found that the patent only disclosed identification of specific units, not types, and that neither expert testimony nor the prosecution history provided substantial evidence to the contrary. The Federal Circuit reversed the district court’s judgment, held claims 14 and 15 invalid for lack of written description, and ordered judgment for LG. All other issues were deemed moot.