In MPEG LA LLC v. GXI International LLC, New York Supreme Court Judge Melvin L. Schweitzer dismissed GXI International LLC’s antitrust counterclaims in MPEG LA’s breach of contract action for allegedly unpaid patent royalties.
MPEG LA manages a pool of patents covering the technology needed to make converter boxes that allow analog televisions to receive digital signals. GXI makes and sells a converter box using technology covered by the MPEG LA-managed pool. In July 2008, GXI agreed to pay royalties to MPEG LA for sales of converter boxes using the licensed patents. MPEG LA later sued GXI for allegedly failing to pay. GXI counterclaimed, accusing MPEG LA of monopolizing the market for converter boxes and charging unreasonably high royalty rates.
In dismissing GXI’s counterclaim, the court held that GXI failed to plausibly allege that MPEG LA restrained competition in the converter box market. The court further noted that even if GXI had “adequately alleged facts” to support the antitrust claims, those claims would have been dismissed because the statute of limitations had run.