IP Law Daily, PATENT—E.D. Tex.: LG did not infringe on television patents a jury found invalid at trial, (Mar 26, 2026)

By Justin Marcus Smith, J.D.

Defendant LG introduced evidence of claim invalidity that was entirely consistent with the plaintiff’s understanding of the claim.

The federal district court in Marshall, Texas, declined to disturb jury findings in an unsuccessful patent infringement suit asserted against LG Electronics USA, Inc. The court ultimately found the question of infringement moot because, at trial, the jury found the asserted patents were invalid. The court analyzed, first, how the jury apparently saw no difference in the functionality of a 2011 LG television, which preceded the patents in dispute, and the current LG model. The court found the jury drew a reasonable conclusion that there was no difference in functionality in light of the YouTube video evidence LG presented. The court also held that LG sufficiently corroborated its invention in light of that same YouTube video evidence. Moreover, LG did not have to corroborate every detail of its invention. The LG TV was prior art, so estoppel was moot with respect to LG use of secondary references against the asserted patents. The court also did not find any grounds for a new trial on the plaintiff’s argument that it had a valid claim over the LG so-called “Song” menu navigation system (Multimedia Technologies Pte. Ltd. v. LG Electronics Inc., No. 2:22-cv-00494-JRG-RSP (E.D. Tex. Mar. 19, 2026)).

Background. Plaintiff Multimedia Technologies PTE. Ltd. (Multimedia) alleged that defendants LG Electronics Inc. and LG Electronics USA, Inc. (collectively, LG) infringed on five purportedly valid Multimedia patents (collectively, the asserted patents). The patents were from the same patent family. They all pertained to smart TVs.

At trial, LG asserted the plaintiff’s patents were obvious over the LG 5700 TV, and the jury agreed. LG introduced evidence that the LG 5700 TV hardware and operating system were publicly available in 2011. However, LG’s own expert testified the TV had a post-priority date software update.

In light of that post-priority date software update, the parties now disputed whether the LG 5700 TV was, in fact, prior art. Plaintiff Multimedia moved for judgment as a matter of law (JMOL) under Fed. R. Civ. P. 50(b), or, in the alternative, for a new trial under R. 59(a).

Prior art. The court found Multimedia did not identify any grounds for a new trial because a reasonable jury could find the functionality remained materially unchanged since 2011.

Multimedia argued the LG TV was not prior art because the software update materially changed its search functionality. Multimedia further noted that third-party apps on the TV were subject to change at any time without notice.

LG countered that the jury considered “substantial evidence” that the software update did not alter the TV functionality because the so-called NetCast 2.0 software continued to operate the same way it did in 2011. LG presented a 2011 YouTube video as evidence in support of unchanged operation. The court found the video allowed the jury to compare the 2011 model to the current one. An LG expert also testified that the operating system, not the software update, defined the functionality of the TV.

The court agreed with LG. The jury apparently saw no difference in the functionality. The court found that a reasonable conclusion in light of the evidence. LG expert testimony also backed the video insofar as the expert testified that software updates pertained only to “lower level” functionality, not the claimed functionality.

The court acknowledged that Multimedia’s strongest argument relied on a depiction of a different search function in the 2011 manual, but LG disputed that. Under these facts, the court not only denied a new trial, it also concluded that JMOL was inappropriate.

Corroboration. The court also rejected Multimedia’s contention that LG failed to corroborate its prior art and several specific functions, like the search application. Multimedia especially questioned LG’s use of testimony by its own witnesses.

LG countered that Multimedia improperly sought to turn the sufficiency of the LG corroboration analysis into a question of law calling for corroboration of each and every aspect of the TV by documentary evidence.

The court concluded Multimedia overstated its case because corroboration of inventor testimony is a question of fact, and inventors do not necessarily need to corroborate every aspect of their testimony through an independent source of evidence.

Moreover, the court once again found a reasonable jury could find LG sufficiently corroborated the TV a prior art by reference to the 2011 YouTube video. The inventor of the asserted patents, meanwhile, testified to user interface navigation of included apps represented as graphical tiles. The court concluded the video and expert testimony were enough for the jury to find the 2011 functionality did not change.

Estoppel. Next, the court held estoppel did not apply to LG use of secondary references of prior art against three of the five asserted patents. Multimedia argued here that LG would be estopped from asserting the secondary references if the TV was not properly classified as prior art. LG relied on these same three references against the patents in parallel inter partes review proceedings, and LG stipulated it would not pursue grounds it could have raised before the Patent Trial and Appeal Board. The court concluded that estoppel was moot because the TV was prior art.

Navigation menu. The court did not find any grounds for a new trial on Multimedia’s argument that it had a valid claim over the so-called “Song” menu navigation system. At trial, LG argued that a claim of one of the patents was anticipated by or obvious in light of a Korean Patent Application Publication pertaining to the “Song menu navigation system.” LG’s expert argued, and the jury agreed, that different aspects of the Song menu navigation system satisfied two claim elements: (1) a “live TV application feature”; and (2) a “global panel feature.”

Multimedia argued now for JMOL with respect to the validity of its claim over Song insofar as the live TV application and global panel features were distinct limitations that a single prior art element could not satisfy. Multimedia reasoned the features were discretely determined by separate inputs and discretely presented in different parts of the display.

LG said the Song menu navigation system consisted of different components, separately determined by different inputs, and presented in different parts of the display. LG noted Multimedia did not introduce contrary evidence.

The court agreed with LG because it showed evidence the Multimedia claim was invalid; that Song taught the use of different inputs for a live application feature and a global panel input; and LG’s expert further testified that Song disclosed the two features would be located in different parts of the display. The court also agreed with LG that Multimedia did not show any evidence to the contrary.

Infringement. Last, the court denied the Multimedia motion for JMOL on the issue of infringement because the issue was moot. The jury found the asserted patents were all invalid. Multimedia did not show that the court should disturb that finding. There could not be any infringement of invalid patents.

The Case is No. 2:22-cv-00494-JRG-RSP.

Judge: Gilstrap, R.

Attorneys: Amanda Sewanan (Schulte Roth & Zabel LLP) for Multimedia Technologies Pte. Ltd. Austin Zuck (Morgan Lewis & Bockius) for LG Electronics Inc. and LG Electronics USA, Inc.

Companies: Multimedia Technologies Pte. Ltd.; LG Electronics Inc.; LG Electronics USA, Inc.

Cases: Patent TexasNews