Texas Round-Up: September 2025 

The September 2025 edition of our Texas Round-Up focuses on developments in cases involving jurisdiction and pleadings. 

Intell. Ventures I LLC v. Lenovo Grp. Ltd., No. 6:23-cv-00307, Dkt. 167 (W.D. Tex. Sep. 15, 2025). 

Judge Albright denied defendant Lenovo Group Limited (LGL)’s motion to dismiss for lack of personal jurisdiction in an opinion dated September 15th, 2025. Plaintiffs Intellectual Ventures I and II accuse LGL — a Hong Kong-based parent company — of acting in concert with its subsidiaries to place infringing wireless communication and timing products into the U.S. stream of commerce. 

LGL argued that it was not subject to general jurisdiction in the U.S., emphasizing its status as a separate legal entity that does not do business in the U.S. However, Judge Albright found that the plaintiffs had made the prima facie showing of personal jurisdiction required at that stage of the dispute. 

The court pointed to LGL’s alleged acquisition of companies to enter the U.S. market, general corporate structure, and revenue received from its subsidiaries’ U.S. sales as evidence of coordinated conduct with its subsidiaries under a stream of commerce theory. Judge Albright explained that, even if LGL is a distinct corporate entity, its alleged relationships with its subsidiaries indicated that it was “acting in conjunction with them” and had “knowledge that [the accused products] enter the U.S.” Additionally, a prior holding that LGL was subject to jurisdiction in the district made it reasonable for the company to anticipate being there. Accordingly, Judge Albright denied LGL’s motion to dismiss.  

Longhorn Automotive Grp. LLC v. Hyundai Motor Co., No. 2:24-cv-00554, Dkt. 84 (E.D. Tex. Sep. 26, 2025). 

On the other side of the state, Judge Gilstrap granted defendant Nissan’s Rule 12(b)(6) motion to dismiss Longhorn’s direct infringement claims. Longhorn alleged that Nissan infringed in the Eastern District by “regularly travel[ing] to the United States to test and/or troubleshoot the Accused Products,” directly infringing an asserted patent by practicing its method. Longhorn argued that this “regularly travel…to test and/or troubleshoot” language — which was sufficient in an earlier case in the district t— met the plaintiff’s pleading standard to survive the motion. See NorthStar Sys. LLC v. Volkswagen AG, No. 2:22-CV-00486-JRG, 2023 WL 5723648, at *2 (E.D. Tex. Sep. 5, 2023).  

However, the court disagreed. In his opinion dated September 26, 2025, Judge Gilstrap ruled that Longhorn’s allegations were insufficient to establish the factual basis required to survive a 12(b)(6) motion. He noted that the “formulaic recitation of the facts found sufficient in a different case” was little different than the formulaic recitation of legal claim elements which, under Twombly, cannot form the basis of a reasonable inference of the defendant’s liability. While the court left unanswered whether Longhorn’s other evidence — such as screenshots and textual analysis — was sufficient, it dismissed the complaint against Nissan and granted leave to amend.