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Barco v. Yealink — court leaves ongoing indirect-infringement claim for jury

Reported / Citable

Case
Barco, Inc. et al. v. Yealink (USA) Network Technology Co., Ltd. et al.
Court
U.S. District Court for the Eastern District of Texas
Judge
Roy S. Payne
Date Decided
August 22, 2025
Docket No.
2:23-cv-00521-JRG-RSP
Topics
Patent infringement; Indirect infringement; Discovery; Jury trial

Background

At the August 5, 2025 pretrial conference, the parties disputed whether Yealink had admitted ongoing indirect infringement or whether that issue remained for trial. The court ordered supplemental briefing.

Yealink had made admissions of infringement during discovery. Its Second Amended Answer admitted infringement of one claim from each asserted patent, but the court held that those limited admissions did not eliminate the need for technical discovery. After Barco again sought liability discovery, Yealink obtained leave to file a Third Amended Answer admitting infringement of all asserted claims.

The Court’s Holding

The court held that Yealink admitted the technical aspects of infringement, but did not admit all factual predicates necessary to establish ongoing induced infringement.

In particular, Yealink did not admit that it continued inducing infringement after the point at which it contends it withdrew the accused products from the U.S. market. Liability for indirect infringement after that asserted withdrawal therefore remains a live issue for the jury.

Key Takeaways

  • Admissions of technical infringement do not necessarily concede ongoing indirect infringement.
  • The alleged timing and effect of Yealink’s withdrawal of accused products remain material to inducement liability.
  • The jury will decide whether Yealink remained liable for indirect infringement after the asserted withdrawal.

Why It Matters

The order narrows the effect of Yealink’s infringement admissions. Although those admissions resolve the technical aspects of infringement, Barco must still prove the additional facts required for post-withdrawal induced-infringement liability.

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