Clear Imaging Research LLC v. Lenovo Group Ltd.

CourtDistrict Court, E.D. Texas
DecidedMarch 31, 2026
Docket2:25-cv-00240
StatusUnknown

This text of Clear Imaging Research LLC v. Lenovo Group Ltd. (Clear Imaging Research LLC v. Lenovo Group Ltd.) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clear Imaging Research LLC v. Lenovo Group Ltd., (E.D. Tex. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

CLEAR IMAGING RESEARCH LLC, § § Plaintiff, § § v. § CIVIL ACTION NO. 2:25-CV-00240-JRG § LENOVO GROUP LTD., § § Defendant. § §

MEMORANDUM OPINION AND ORDER Before the Court is Defendant Lenovo Group Ltd.’s (“LGL”) Motion to Dismiss for Lack of Personal Jurisdiction and Motion to Dismiss Direct, Willful, and Indirect Infringement Claims (the “Motion”). (Dkt. No. 17.) Having considered the Motion, the subsequent briefing, and the documents submitted in support thereof, the Court finds that the Motion should be DENIED. I. BACKGROUND Plaintiff Clear Imaging Research LLC (“Clear Imaging”) filed suit, accusing LGL of infringing seven U.S. patents. (Dkt. No. 1.) The patents pertain to digital image processing technologies that purportedly help correct or avoid blurred images and videos. (E.g., id. ¶¶ 1, 22, 30.) Clear Imaging asserts that Lenovo- and Motorola-branded laptops, smartphones, and tablets infringe the asserted patents. (E.g., id. ¶ 31.) Defendant LGL is incorporated in Hong Kong and is the parent of certain U.S. entities. (See Dkt. No. 17-1 ¶ 2.) For instance, Lenovo (United States) Inc. (“Lenovo U.S.”) and Motorola Mobility LLC (“Motorola”) are subsidiaries of LGL. (Id. ¶¶ 1–3; Dkt. No. 17 at 8, 16.) LGL represents that Lenovo U.S. and Motorola have principal places of business in North Carolina and Illinois, respectively. (Dkt. No. 17-1 ¶ 6.) II. LEGAL AUTHORITY A. Personal Jurisdiction Federal Rule of Civil Procedure 12(b)(2) requires a court to dismiss a claim if the court does not have personal jurisdiction over the defendant. Cunningham v. CBC Conglomerate, LLC, 359 F. Supp. 3d 471, 476 (E.D. Tex. 2019). Personal jurisdiction exists over a defendant where a forum state’s long-arm statute permits service of process and where assertion of personal

jurisdiction does not violate due process. NexLearn, LLC v. Allen Interactions, Inc., 859 F.3d 1371, 1375 (Fed. Cir. 2017). Texas’ long-arm statute is “coextensive with the Due Process Clause of the Fourteenth Amendment” such that these two inquiries merge. Carmona v. Leo Ship Mgmt., Inc., 924 F.3d 190, 193 (5th Cir. 2019). To satisfy due process when exerting personal jurisdiction over a defendant, the defendant must have “certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (internal quotations omitted). A defendant has “minimum contacts” with a forum if it “delivers its products into the stream of commerce with the expectation

that they will be purchased by consumers in the forum [s]tate.” Beverly Hills Fan Co. v. Royal Sovereign Corp., 21 F.3d 1558, 1566 (Fed. Cir. 1994) (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297–98 (1980)). Stream-of-commerce-based personal jurisdiction attaches where “defendants, acting in consort, placed the accused [product] in the stream of commerce, they knew the likely destination of the products, and their conduct and connections with the forum state were such that they should reasonably have anticipated being brought into court there.” Id. at 1566. The existence of an “established distribution channel into the forum” is a “significant factor” when evaluating the strength of a non-movant’s stream-of-commerce theory. See id. at 1565 n.15. “When the district court’s determination of personal jurisdiction is based on affidavits and other written materials, and no jurisdictional hearing is conducted, the plaintiff usually bears only a prima facie burden.” Celgard, LLC v. SK Innovation Co., 792 F.3d 1373, 1378 (Fed. Cir. 2015). To bear that burden, “[the plaintiff] need only demonstrate facts that, if true, would support

jurisdiction over the [d]efendant.” Campbell Pet Co. v. Miale, 542 F.3d 879, 888 (Fed. Cir. 2008). That is, “[w]ithout discovery and a record on jurisdiction, this court must resolve all factual disputes in the plaintiff’s favor.” Nuance Commc’ns, Inc. v. Abbyy Software House, 626 F.3d 1222, 1231 (Fed. Cir. 2010); Polar Electro Oy v. Suunto Oy, 829 F.3d 1343, 1347–48 (Fed. Cir. 2016). In addition, a court may exercise jurisdiction under Federal Rule of Civil Procedure 4(k)(2) if “(1) the plaintiff’s claim arises under federal law, (2) the defendant is not subject to jurisdiction in any state’s courts of general jurisdiction, and (3) the exercise of jurisdiction comports with due process.” M-I Drilling Fluids UK Ltd. v. Dynamic Air Ltda., 890 F.3d 995, 999 (Fed. Cir. 2018) (quoting Synthes (U.S.A.) v. G.M. Dos Reis Jr. Ind. Come de Equip. Medico, 563 F.3d 1285, 1293– 94 (Fed. Cir. 2009)). This rule “contemplates a defendant’s contacts with the entire United States,

as opposed to the state in which the district court sits.” Id. (quoting Synthes, 563 F.3d at 1295). B. Failure to State a Patent Infringement Claim “A pleading that states a claim for relief must contain,” inter alia, “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Defendants may “test[] the sufficiency of the pleadings” against this standard by moving under Federal Rule of Civil Procedure 12(b)(6). To survive such a test, a complaint must state enough facts such that the claim to relief is plausible on its face. Thompson v. City of Waco, 764 F.3d 500, 502 (5th Cir. 2014) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Regional circuit law governs a motion to dismiss under Rule 12(b)(6), and in the Fifth Circuit such motions are viewed with disfavor and are rarely granted. Lormand v. US Unwired, Inc., 565 F.3d 228, 232 (5th Cir. 2009); AlexSam, Inc. v. Aetna, Inc., 119 F.4th 27, 34–35 (Fed. Cir. 2024). A complaint must place the alleged patent infringer on notice of what activity is being accused of infringement. Lifetime Indus., Inc. v. Trim-Lok, Inc., 869 F.3d 1372, 1379 (Fed. Cir.

2017).

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Bluebook (online)
Clear Imaging Research LLC v. Lenovo Group Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/clear-imaging-research-llc-v-lenovo-group-ltd-txed-2026.