EireOg Innovations Ltd. v. Cisco Systems Inc.

District Court, E.D. Texas·Decided April 6, 2026·No. 2:24-cv-00224·Unknown

Opinion

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

EIREOG INNOVATIONS LTD., § § Plaintiff, § Case No. 2:24-cv-00224-RWS-RSP v. §

§ (Lead Case) CISCO SYSTEMS INC., § Defendant. §

MEMORANDUM ORDER Before the Court is Plaintiff EireOg Innovations LTD’s (“EireOg”) Motion to Exclude Certain Opinions of Dr. Emmett Witchel and to Strike Portions of His Expert Reports. Dkt. No. 189. In the Motion, Plaintiff argues that Dr. Witchel’s written description and anticipation opinions apply the incorrect legal standard, and that his report offers untimely claim construction opinions. Having considered the Motion, and for the reasons discussed below, the Motion is DENIED. I. BACKGROUND In the instant Case, EireOg has accused Cisco products that contain certain Intel and AMD chips of infringing U.S. Patent Nos. 8,504,777 (“the ’777 patent”), 9,436,626 (“the ’626 patent”) and 9,442,870 (“the ’870 patent”) (together, “asserted patents”).1 See generally Dkt. No. 1. The asserted patents are generally directed at managing “virtual divisions” of computer chips, which allow each “partition” to operate as a separate machine. As a defense to infringement of the ’777 patent, Defendant argues that it lacks adequate written description support, and is anticipated by the prior art. Defendant supports these defenses with testimony from its technical expert, Dr. Witchel.

1 U.S. Patent No. 8,117,399 (“the ’399 patent”), is no longer asserted in this Case. II. LEGAL STANDARD An expert witness may provide opinion testimony if “(a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product

of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case.” Fed. R. Evid. 702. Rule 702 requires a district court to make a preliminary determination, when requested, as to whether the requirements of the rule are satisfied with regard to a particular expert’s proposed testimony. See Kumho Tire Co. v. Carmichael, 526 U.S. 137, 149 (1999); Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592-93 (1993). District courts are accorded broad discretion in making Rule 702 determinations of admissibility. Kumho Tire, 526 U.S. at 152 (“the trial judge must have considerable leeway in deciding in a particular case how to go about determining whether particular expert testimony is reliable”). Although the Fifth Circuit and other courts have identified various factors that the district court may consider in determining whether an expert’s testimony

should be admitted, the nature of the factors that are appropriate for the court to consider is dictated by the ultimate inquiry—whether the expert’s testimony is sufficiently reliable and relevant to be helpful to the finder of fact and thus to warrant admission at trial. United States v. Valencia, 600 F.3d 389, 424 (5th Cir. 2010). Importantly, in a jury trial setting, the Court’s role under Daubert is not to weigh the expert testimony to the point of supplanting the jury’s fact-finding role; instead, the Court’s role is limited to that of a gatekeeper, ensuring that the evidence in dispute is at least sufficiently reliable and relevant to the issue before the jury that it is appropriate for the jury’s consideration. See Micro Chem., Inc. v. Lextron, Inc., 317 F.3d 1387, 1391-92 (Fed. Cir. 2003) (applying Fifth Circuit law) (“When, as here, the parties’ experts rely on conflicting sets of facts, it is not the role of the trial court to evaluate the correctness of facts underlying one expert’s testimony.”); Pipitone v. Biomatrix, Inc., 288 F.3d 239, 249-50 (5th Cir. 2002) (“‘[t]he trial court’s role as gatekeeper [under Daubert] is not intended to serve as a replacement for the adversary system.’ . . . Thus, while

exercising its role as a gate-keeper, a trial court must take care not to transform a Daubert hearing into a trial on the merits,” quoting Fed. R. Evid. 702 advisory committee note). As the Supreme Court explained in Daubert, 509 U.S. at 596, “Vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.” See Mathis v. Exxon Corp., 302 F.3d 448, 461 (5th Cir. 2002). III. ANALYSIS A. Written Description Plaintiff argues that Dr. Witchel’s written description opinions should be excluded because they improperly compare the written description to the accused products. Id. at 2. Plaintiff notes

that Dr. Witchel’s report admits that his written description opinions are based on “what [Plaintiff’s] infringement theories were and the terms that they used and then [he] tried to see if those were supported in the written description of the patent.” Id. at 2-3. Plaintiff cites Dr. Witchel’s testimony, where he purports to admit the asserted claims meet the written description requirement Q. … [A]re you offering any opinion that there is a claim limitation of Claim 16 of the ’777 patent that is not adequately described in the patent specification such that the claim is invalid under the written description requirement? A. No. I believe that the claims, as written, can be understood by a person of ordinary skill in the art. Q. You believe that the claims as written are adequately described in the specification such that a person of ordinary skill in the art would understand that the inventors were in possession of the invention? A. Yes, I believe that they -- they constitute an adequate description of the full scope of what is claimed. Dkt. No. 189-4 at 145:17-146:11. Plaintiff cites several portions of Dr. Witchel’s report, and argues that he improperly compares the accused products to the ’777 patent’s written description. See e.g. Dkt. No. 189 at 3 (“he opines that there is not ‘any disclosure in the 777 patent of a decoration being used to alter the number of bytes that are written to the target memory,’ which is an aspect of EireOg’s infringement theory.”). Plaintiff concludes that because Dr. Witchel improperly applies the law, his opinions are improper and should be excluded. Defendant responds that while Plaintiff is correct to characterize Dr. Witchel’s written description opinions as “rooted in [Plaintiff’s] infringement theories,” Plaintiff is incorrect to argue he directly compares the accused product to the ’777 patent’s written description. Dkt. No. 261 at 9. Defendant identifies several portions of Dr. Witchel’s report to explain that under Plaintiff’s infringement theories, the asserted claims lack written description support. Id. at 10. Defendant argues this is consistent with the Federal Circuit’s requirement that claims be construed the same way for infringement as for invalidity. Id. “A patent may not, like a nose of wax, be twisted one way to avoid anticipation and another to find infringement.” Amazon.com, Inc. v.

Free access — add to your briefcase to read the full text and ask questions with AI

EireOg Innovations Ltd. v. Cisco Systems Inc., (E.D. Tex. 2026).

EireOg Innovations Ltd. v. Cisco Systems Inc. (EireOg Innovations Ltd. v. Cisco Systems Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Mathis v. Exxon Corporation
302 F.3d 448 (Fifth Circuit, 2002)
United States v. Valencia
600 F.3d 389 (Fifth Circuit, 2010)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)