Universal Connectivity Technologies Inc. v. HP Inc.

District Court, N.D. California·Decided February 4, 2026·No. 5:24-cv-04097·Unknown

Opinion

UNIVERSAL CONNECTIVITY Case No. 24-cv-04097-NW (SVK) TECHNOLOGIES INC., ORDER GRANTING IN PART AND Plaintiff, DENYING IN PART DEFENDANT’S RENEWED MOTION TO STRIKE v. INFRINGEMENT CONTENTIONS; RESOLVING DISCOVERY DISPUTE HP INC., AT DKT. 230 Defendant. Re: Dkt. Nos. 199, 230 This is the latest in a series of orders related to Plaintiff Universal Connectivity Technologies Inc.’s (“UCT”) infringement contentions in this case. Pending before the Court is Defendant HP Inc.’s (“HP”) Renewed Motion to Strike Plaintiff’s Third Amended Infringement Contentions, (Dkt. 199 (the “Motion”)), following this Court’s September 8, 2025 Order granting in part (with partial leave to amend) and denying in part HP’s first motion to strike, (see Dkt. 160, motion for relief from nondispositive pretrial order denied, Dkt. 192). The Motion was referred to the undersigned on December 1, 2025. Dkt. 204. The matter came on for hearing on February 3, 2026. Having considered the Parties’ submissions and oral arguments, the relevant law, and the record in this matter, the Court GRANTS IN PART and DENIES IN PART HP’s Motion. The Parties are familiar with the factual and procedural history of this dispute, as set forth in Dkts. 137 (“Order re Motion to Amend”) and 160 (“First Order re MTS”). The Court thus summarizes the history only briefly, below. In short, “this action was originally filed in the Western District of Texas on September 28, 2023, accusing certain “HP laptops, desktops, monitors, and docking stations” of infringing eight DisplayPort, PCIe power and HDMI connections.” Dkt. 160 at 2 (citing, generally, Dkt. 1; Dkt. 101 at 2).1 Subsequent to this Court’s First Order re MTS, the Parties stipulated to dismissal of two patents; six patents remain at issue in this litigation. See Dkt. 160 at 2-3; Dkts. 183, 223 (the Honorable Noël Wise entering partial judgment re U.S. Patent Nos. ’520 and ’265). A. Procedural History re UCT’s Infringement Contentions UCT served two rounds of infringement contentions in the Western District in the Spring of 2024, (see Dkt. 101 at 2), and on July 8, 2024, the Western District transferred venue to this District, (Dkt. 52). After UCT initially served updated contentions on October 21, 2024, HP informed UCT of purported deficiencies in its contentions; UCT moved to amend its contentions, while HP sought leave to move to strike the contentions in February 2025. See Dkt. 101 at 3; Dkt. 130 at 2 (recounting history). On May 29, 2025, this Court granted UCT’s motion to amend, denied HP’s request to move to strike the original contentions as moot and ordered abbreviated briefing on a motion to strike the contentions as amended, to the extent any asserted deficiencies remained. Dkt. 130 at 6-7. The Court’s First Order re MTS ultimately approved of certain parts of UCT’s infringement contentions, struck certain parts of the contentions with leave to amend and struck certain parts of the contentions without leave to amend. See, generally, Dkt. 160. In relevant part, the Court struck UCT’s contentions as to representative products with leave to amend. Id. The Court explained that because UCT’s infringement theories were based on “both compliance with [industry standards] and HP’s implementation of those standards,” UCT “must provide at least a preliminary explanation as to how it expects HP’s implementation in the representative products to be the same as HP’s implementation in other products” even prior to discovery of technical information such as source code. Dkt. 160 at 5-7 (emphasis omitted). Judge Wise denied UCT’s motion for relief from the First Order re MTS on October 28, 2025. Dkt. 192. UCT served the operative, third amended infringement contentions (“TAIC”) on October 15, 2025. Dkt. 208 at 6. The TAIC accuse, as did UCT’s prior contentions, over 2,000 of HP’s products of infringement. See Dkt. 230 at 2; Dkt. 160 at 3 (citing Dkt. 138-2 at 5; Dkt. 101-4 at 3); Dkts. 199-3–4. In its TAIC, UCT does not chart each of the accused products but rather continues to rely on representative products. See Dkts. 199-3–4. On November 18, 2025, HP renewed its motion to strike on the narrower grounds that UCT’s “representativeness” contentions remain deficient. See Dkt. 199. The Motion was fully briefed on December 19, 2025. Dkts. 208, 211. On January 29, 2026, the Court issued a tentative ruling explaining that it was inclined to grant the Motion as to peripheral products but deny the Motion as to accused laptops and desktops and order certain discovery as to Intel-based products. Dkt. 234. The Court heard oral argument on February 3, 2026. Dkt. 241. B. Other Relevant Procedural History HP’s initial challenge to UCT’s contentions was brought before the Court in February, 2025. See Dkts. 101, 102. Judge Wise held a claim construction hearing on October 15, 2025, and issued a Claim Construction Order on November 7, 2025. Dkts. 183, 197. Fact discovery in this case was segmented per agreement of the Parties: “discovery of documents and things from third parties” has been open since April 3, 2024, but discovery as between the Parties was closed2 “until one day after issuance of the Markman order” in this case. Dkt. 116 at 6 (citing the Parties’ agreement in Dkt. 31, ¶ 10). Fact discovery is currently scheduled to close February 27, 2026, with opening expert reports due March 20, 2026. Dkt. 220. Dispositive and Daubert motions are due May 8, 2026. Id. After multiple case schedule amendments, Judge Wise noted that “the Court is not inclined to alter the deadline to file dispositive and Daubert motions or the trial date.” Dkt. 220 at 1. A. Patent Local Rule 3-1 “This District’s Patent Local Rules aim to make the parties more efficient, to streamline the litigation process, and to articulate with specificity the claims and theory of a plaintiff’s infringement claims.” Unicorn Energy AG v. Tesla Inc., No. 21-cv-07476-BLF (SVK), 2023 WL 4670294, at *1 (N.D. Cal. July 19, 2023) (quotation marks and citations omitted). The purpose of the infringement and invalidity contentions required under the Patent Local Rules is to “require the parties to crystallize their theories of the case early in the litigation” in order to “further the goal of full, timely discovery and provide all parties with adequate notice of and information with which to litigate their claims.” Finjan, Inc. v. Blue Coat Sys., Inc., No. 13-cv-03999-BLF, 2015 WL 3640694, at *1 (June 11, 2015) (citations omitted). Under Patent Local Rule 3-1, the party alleging patent infringement must serve infringement contentions. Patent L.R. 3-1. Among other things, the contentions must identify each claim of each patent in suit that is allegedly infringed and, for each asserted claim, “each accused apparatus, product, device, process, method, act, or other instrumentality (‘Accused Instrumentality’) of each opposing party of which the party is aware.” Patent L.R. 3-1(a), (b). In general, this District does “not tolerate broad categorical identifications or the use of mere representative examples,” and demands “a full list of accused products … if they are known to the plaintiff.” Oyster Optics, LLC v. Ciena Corp., No. 20-cv-02354-JSW (LB), 2022 WL 561931, at *2 (N.D. Cal. Feb. 24, 2022) (cleaned up) (citation omitted). However, “representative products may … be charted when supported by adequate analysis showing that the accused products share the same critical characteristics” as the representative products. Id. at *3 (internal quotations and citations omitted). The infringement contentions “must be sufficient to provide reasonable notice to the defendant why the plaintiff believes it has a reasonable chance of proving infringement and to raise a reasonable inference that all accused products infringe.” SAGE Electrochromics Inc v. View Inc, No. 12-cv-06441-JST (DMR), 2013 WL 4777164, at *1 (N.D. Cal. Sept. 6, 2013) (citing, inter alia, Antonious v. Spalding & Evenflo Cos., Inc., 275 F.3d 1066, 1075 (Fed. Cir.

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