The complaint

The case is Apple Inc. v. Hannibal IP, LLC, No. 5:26-cv-12069 (N.D. Cal.), a 30-page complaint filed October 16, 2026. The plaintiff is Apple Inc., a California corporation based in Cupertino, California. Citing Hannibal's own Texas complaint, Apple describes Hannibal IP, LLC as a Texas limited liability company based in Plano, Texas. Apple pleads breach of contract, breach of FRAND contractual commitments, and declaratory judgment of noninfringement, and demands a jury. Apple alleges that Hannibal acted in bad faith and broke promises to negotiate fairly, including by suing Apple for patent infringement without warning. Parts of the public complaint are redacted, including much of the opening section, the negotiation history, and most of the First Count.

The related Western District of Texas suit

The complaint identifies the related action, Hannibal IP, LLC v. Apple Inc., No. 7:26-cv-00341 (W.D. Tex.), filed August 28, 2026 (the WDTX Action), and attaches Hannibal's complaint there as Exhibit 4. Apple says Hannibal accuses it in that case of infringing the same six patents. Citing that complaint, Apple says the accused products include at least iPhone models that support 5G beginning with the iPhone 12 and later models, and iPad models beginning with the iPad Pro (3rd generation) and later models. Apple also says that in the WDTX Action Hannibal accuses both Apple modems and seven modems made by a third-party chip supplier.

The negotiations

According to the complaint, Hannibal first contacted Apple by a May 27, 2022 letter sent to Apple's California offices, and Apple responded on May 31, 2022. Apple alleges that the parties met virtually on at least eight occasions between August 18, 2022 and June 16, 2026, exchanged more than ninety emails, and kept negotiating through August 2026.

The patents

The six patents are U.S. Patent Nos. 11,057,896; 11,641,661; 11,272,535; 11,683,142; 10,911,201; and 12,108,412. Each declaratory judgment count gives the patent's title and issue date and quotes one claim. The complaint says Hannibal claims to own all rights in each patent, and it lists FG Innovation Company Limited as the assignee on the face of the '896 and '201 patents and Hannibal IP LLC as the assignee of the other four.

The '896 patent, Methods and Apparatuses of Determining Quasi Co-Location (QCL) Assumptions for Beam Operations, issued July 6, 2021. The '661 patent, Methods and apparatuses for determining quasi co-location (QCL) assumptions for beam operations, issued May 2, 2023. The '535 patent, Method and Apparatus for LBT Failure Detection, issued March 8, 2022. The '142 patent, Method of Deriving QCL Assumption in Multi-Panel Transmission and Related Device, issued June 20, 2023. The '201 patent, Methods and Apparatuses for Multi-TRP Transmission, issued February 2, 2021. The '412 patent, Method and Apparatus for Uplink Transmission, issued October 1, 2024.

FRAND and ETSI allegations

Apple alleges that Hannibal claims patents in its portfolio are essential to 5G wireless standards and that Hannibal is obligated to negotiate in good faith toward a fair, reasonable, and non-discriminatory (FRAND) license. Apple quotes Hannibal's Texas complaint as alleging that Hannibal "is the assignee of numerous patents, originally assigned to FG Innovation Company Limited ('FGI'), that are, and remain, essential to practicing the 3GPP 5G Standard." Apple alleges, on information and belief, that FG Innovation Company Limited submitted ETSI IPR Information Statements and Licensing Declarations covering patents in Hannibal's portfolio, including ISLD-201908-021, ISLD-202004-011, ISLD-202009-062, ISLD-202009-063, and ISLD-202104-054, and it alleges that Hannibal, as successor in interest, is bound by the ETSI IPR Policy and that FRAND commitment. Apple also quotes Hannibal's statement in the Texas case that it "informed Apple that it [was] prepared to grant Apple an irrevocable license to Hannibal's standard essential patents, including the Asserted Patents, on FRAND or better terms." Apple alleges that it is an intended third-party beneficiary of the commitment, and it disputes that the patents are essential.

The counts

The First Count is for breach of contract, and most of it is redacted. Apple alleges damages from that breach in excess of $75,000, including attorneys' fees it calls foreseeable consequential damages. The Second Count, for breach of FRAND obligations, quotes Clauses 3.1, 6.1, 6.1bis, and 15.6 of the ETSI IPR Policy and alleges that Hannibal has breached, and continues to breach, its FRAND commitment, including by failing to negotiate in good faith toward a FRAND license and by filing and pursuing the WDTX Action. Apple claims damages under that count, including attorney's fees and the cost of litigating the WDTX Action, in excess of $75,000.

Counts Three through Eight seek declarations of noninfringement of the '896, '661, '535, '142, '201, and '412 patents, respectively. For the '896 and '661 patents, Apple quotes claim 1 and alleges noninfringement at least because its products do not satisfy the limitation requiring monitoring at least one of a plurality of CORESETs configured for the UE within an active Bandwidth Part of a serving cell in a time slot, and alleges that the standard does not require applying a QCL assumption among all CORESETs a UE monitors in an active Bandwidth Part. For the '535 patent, Apple quotes claim 1 and alleges noninfringement of Listen-Before-Talk (LBT) failure-indication and LBT failure-event threshold limitations. For the '142 patent, Apple quotes claim 10 and alleges noninfringement of multi-TRP capability-reporting and CORESET-group default QCL limitations. For the '201 patent, Apple quotes claim 11 and alleges noninfringement of TRP-information and multi-TRP correspondence limitations. For the '412 patent, Apple quotes claim 1 and alleges noninfringement of overlapping PUSCH-duration configured-grant and PUSCH-repetition identification limitations. Across those counts, Apple also alleges that no third party infringes by using the accused products, and it quotes a warranty by Hannibal, in Exhibit 1, that "there is no basis to allege that Apple willfully or knowingly infringed the Patents, or has induced others to infringe or contributed to infringement by others."

The relief sought

The prayer asks for judgment in Apple's favor; a declaration that Hannibal breached its obligations under the ETSI IPR Policy; a declaration that, in light of its FRAND commitment, Hannibal is not entitled to injunctive or exclusionary relief against Apple based on the Patents-in-Suit; damages, including costs and fees, from the WDTX Action; declarations that Apple does not infringe, induce, or contribute to infringement of the Patents-in-Suit, literally or under the doctrine of equivalents; a finding that the case is exceptional under 35 U.S.C. 285; costs and attorneys' fees; and further relief. One further requested declaration, that Hannibal breached, is redacted after that word.

What to watch next

Watch for Hannibal's response in the Northern District of California, any motion tied to the parallel WDTX Action, and any less-redacted filing. The case can end at any time, including by settlement or voluntary dismissal.