Longitude Licensing Limited v. BOE Technology Group Co., Ltd.

CourtDistrict Court, E.D. Texas
DecidedJuly 21, 2025
Docket2:23-cv-00515
StatusUnknown

This text of Longitude Licensing Limited v. BOE Technology Group Co., Ltd. (Longitude Licensing Limited v. BOE Technology Group Co., 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
Longitude Licensing Limited v. BOE Technology Group Co., Ltd., (E.D. Tex. 2025).

Opinion

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

LONGITUDE LICENSING LIMITED, et § al, § § Plaintiffs, § § CIVIL ACTION NO. 2:23-CV-00515-JRG-RSP v. § § BOE TECHNOLOGY GROUP CO., § LTD., § § Defendant. MEMORANDUM ORDER Before the Court is the Motion to Exclude Opinions of Dr. Shukri Souri filed by Plaintiffs Longitude Licensing Limited and 138 East LCD Advancements Limited. Dkt. No. 184. Dr. Souri is Defendant’s invalidity expert. For the reasons discussed below, the Motion is GRANTED, except for the final portion. I. 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). II. ANALYSIS A. Dr. Souri’s Invalidity Opinions that Do Not Apply the Court’s Claim Constructions

First, Plaintiffs move to exclude Dr. Souri’s opinions which do not apply the Court’s claim constructions. Dkt. No. 184 at 3. Plaintiffs explain that Dr. Souri issued his invalidity report the same day as the Court issued its Claim Construction Order and did not engage with the Court’s constructions1. Id. at 4. Specifically, the Court construed “a channel area that extends in a direction” from Claim 2 of the ’079 patent to mean “a channel length that runs between source and drain electrodes.” Dkt. No. 129 at 12. Additionally, the Court construed “a first/second semiconductor layer extending in a/the direction” from claim 1 of the ’093 patent to mean “a first/second semiconductor layer that runs between source and drain electrodes.” Id. at 26. These constructions were not proposed by the parties. Id. at 7, 23. Nevertheless, in support of his invalidity opinion, Dr. Souri opines that a certain reference discloses “the channel region . . . ‘extending in a direction,’ . . . under either Longitude’s or BOE’s claim construction.” Dkt. No. 184 at 4; Dkt. No. 184-2 at App’x VII. ¶ 26. Plaintiffs contend that Dr. Souri fails to apply the Court’s constructions for other invalidity opinions regarding the ’079 and ’093 patents. Dkt. No. 184 at 5. Ultimately, Plaintiffs argue that Dr. Souri’s failure to apply the Court’s claim

constructions render his opinions improper and unreliable and thus they should be excluded. Id. BOE responds that Dr. Souri’s opinions are consistent with the Court’s claim constructions and thus should not be stricken. Dkt. No. 204 at 1. BOE argues that the inquiry is one of substance not of form and that the expert need not use the Court’s exact words in his analysis. Id. at 2 (citing Genband US LLC v. Metaswitch Networks Corp., No. 2:14-cv-33-JRG-RSP, 2016 WL 3475688,

1 The Claim Construction Order was filed at 10:14 a.m. on February 4, 2025. Defendant did not seek leave for additional time for its expert to apply the constructions contained therein. at *4 (E.D. Tex. Jan. 7, 2016)). In its Response, BOE explains how Dr. Souri’s analysis is consistent with the Court’s constructions. Id. at 2–4. “Expert opinions that contradict or disregard a court’s claim constructions should be excluded.” Genband, 2016 WL 3475688, at *4. Where the Court construes claim limitations and

an expert does not even acknowledge the Court’s construction, the expert’s opinion is unreliable and unhelpful to the jury and thus must be excluded. Here, Dr. Souri’s analysis of the claim “under either Longitude’s or BOE’s claim construction” is particularly inappropriate because the Court rejected both of those constructions. Dkt. No. 129 at 11, 26 (for the ’079 patent: “The Court is not persuaded by BOE’s proposed construction and therefore rejects it”; for the ’093 patent: “Accordingly, the Court is not persuaded by BOE’s proposed constructions and therefore rejects them.”).2 Allowing experts to analyze claims under rejected constructions would render the entire claim construction process a waste of time. This is not a situation like in Genband, where the expert failed to use the Court’s exact words, but still applied its construction. 2016 WL 3475688, at *4–*5 (“[H]e opines that a particular data structure in the accused product satisfies the Court’s

construction.”) (emphasis added). Rather, Dr. Souri plainly disregards the Court’s construction. BOE cannot now save Dr. Souri’s opinions through attorney argument, or by relying on Dr. Souri’s later deposition.

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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)
Factory Mutual Insurance, Co. v. Alon USA, L.P., e
705 F.3d 518 (Fifth Circuit, 2013)
Arthur Drager v. PLIVA USA
741 F.3d 470 (Fourth Circuit, 2014)

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Longitude Licensing Limited v. BOE Technology Group Co., Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/longitude-licensing-limited-v-boe-technology-group-co-ltd-txed-2025.