Largan Precision Co., Ltd. v. Ability Opto-Electronics Technology Co., Ltd.
4:19-cv-00696
| E.D. Tex. | Feb 5, 2020Background
- Largan (Taiwanese lens maker) sued AOET and Newmax (Taiwanese lens suppliers) and HP for infringing four U.S. patents by lenses incorporated into HP products sold in the U.S., including Texas.
- Largan purchased HP products in Texas and used CT scans to identify AOET/Newmax lenses in finished HP devices sold through major U.S. retailers.
- AOET and Newmax manufacture lenses/lens assemblies in Asia and sell them into a multi-tier supply chain (module makers → system integrators → OEMs like HP); they submitted affidavits denying purposeful contacts with Texas.
- Largan contended AOET/Newmax intentionally placed products into a distribution stream destined for the U.S./Texas (stream‑of‑commerce theory); AOET/Newmax argued lack of purposeful availment and lack of control over downstream sales.
- AOET moved to dismiss for lack of personal jurisdiction and improper venue; Newmax moved to dismiss for lack of personal jurisdiction. The Court denied both motions, finding specific jurisdiction under a stream‑of‑commerce theory and that venue was proper for foreign corporations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| General jurisdiction | Not argued | AOET/Newmax not "at home" in Texas | No general jurisdiction; defendants not domiciled or PPB in Texas |
| Specific jurisdiction (stream of commerce) | AOET/Newmax placed lenses into a distribution chain they knew would reach the U.S./Texas | Mere placement into stream without targeting Texas; lack of control over downstream sales defeats jurisdiction | Largan made a prima facie showing; specific jurisdiction exists under stream‑of‑commerce (defendants knew/should have foreseen U.S./Texas sales) |
| Fairness (due process reasonableness) | Texas has strong interest; Largan has interest in relief; litigation in Texas is reasonable | Litigation in Texas is burdensome; dispute better litigated in Taiwan | Exercise of jurisdiction is fair and reasonable; defendants failed to make compelling showing otherwise |
| Venue (patent venue for foreign defendant) | Venue proper because foreign defendant may be sued in any district | AOET argued improper venue | Venue proper in Eastern District of Texas for foreign corporate defendant |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts due process test)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (stream‑of‑commerce foreseeability concept)
- Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (1987) (split on whether mere placement in commerce suffices)
- J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (2011) (plurality emphasizing targeted conduct)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits general jurisdiction to forum where corporation is "at home")
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (framework for specific jurisdiction and reasonableness factors)
- Walden v. Fiore, 571 U.S. 277 (2014) (focuses specific jurisdiction on defendant’s forum‑directed conduct)
- Beverly Hills Fan Co. v. Royal Sovereign Corp., 21 F.3d 1558 (Fed. Cir. 1994) (Fed. Cir. applying stream‑of‑commerce to support jurisdiction in patent case)
- In re HTC Corp., 889 F.3d 1349 (Fed. Cir. 2018) (treating foreign corporations as subject to suit in any district for patent cases)