East Texas, Once Again the Top District, Saw Notable Verdicts in Q1

The Eastern District of Texas was the top patent district for overall litigation (i.e., with no filter for plaintiff type) and NPE litigation in Q1 2026, also holding the number-two spot for operating company litigation. In second for overall litigation was the District of Delaware, which also held second place for NPE litigation but was the most popular district for operating company litigation. Meanwhile, the Western District of Texas trailed behind Delaware in third place for overall litigation and NPE litigation, failing to break the top five for operating company filings.

Given the relative concentration of litigation in Eastern District of Texas, it is not surprising that some of the most noteworthy patent verdicts of the first quarter were returned by East Texas juries.

One of the most significant came in a cellular standard essential patent (SEP) case filed by various subsidiaries of brought by PanOptis Holdings, LLC against Apple—a case that has now come before three East Texas juries. The first found infringement and awarded PanOptis $500M in damages in August 2020, but in a damages retrial, the second trimmed that amount down to $300M. The Federal Circuit subsequently threw out the entire judgment (of infringement from the first jury and of damages from the second) because a general verdict form had been used for infringement—i.e., the first jury was simply presented with a single question, whether PanOptis had proven infringement of any of the asserted claims from the five patents tried, rather than with patent-by-patent infringement questions. After remand, a third jury found on February 12, 2026 that Apple had not infringed any claims from five tried patents, awarding no damages at all.

On January 31, another East Texas jury returned a noninfringement verdict, this one finding that AUO and Optronics did not infringe a single LCD patent asserted by funded plaintiff Phenix Longhorn, LLC. The jury found the two tried claims of that patent invalid for lack of written description, also finding that AUO did not infringe a second LCD patent (this one surviving an invalidity determination). Prior to trial, three late-added RICO-related counterclaims from the defendants were severed from the main case to “keep them from interfering with the prompt adjudication of the patent infringement claim”. An inequitable conduct counterclaim was also stricken. The severed counterclaims concern alleged bankruptcy fraud and racketeering that “have injured the entire LCD industry”.

In contrast, a third East Texas jury sided with IPValue Management (d/b/a IPValue) plaintiffs 138 East LCD Advancements Limited and Longitude Licensing Limited, finding that BOE had infringed four claims from three patents, and had proven none to be invalid, in another case over LCD technology. The jury awarded a total of about $66.9M in damages and further found that infringement had been willful. Roughly a week before the verdict, the court severed two “late-raised counterclaims” (of tortious interference with contract and tortious conspiracy to so interfere) into a separate action.

See RPX’s first-quarter review for more on district court filing trends and other key patent litigation trends from Q1 2026.