The complaint
The case is Genesis Growth Tech LLC v. iMotions A/S, No. 2:26-cv-00967 (E.D. Tex.), a seven-page complaint for patent infringement filed October 26, 2026, in the Marshall Division, ECF No. 1. The complaint says Genesis Growth Tech LLC is a corporation organized and existing under the laws of the Cayman Islands with its principal place of business in Grand Cayman, Cayman Islands. It says iMotions A/S is a corporation organized and existing under the laws of Denmark with an established place of business in Copenhagen, Denmark. The complaint is signed by Isaac Rabicoff of Rabicoff Law LLC in Chicago, Illinois.
Jurisdiction and venue
The complaint pleads subject matter jurisdiction under 28 U.S.C. 1331 and 1338(a). It pleads personal jurisdiction because iMotions has engaged in systematic and continuous business activities in the district and has committed acts of patent infringement in the district. It pleads venue under 28 U.S.C. 1391(c) because iMotions is a foreign corporation, and alleges that iMotions has committed acts of infringement in the district and that Genesis Growth Tech has suffered harm there.
The patents
The complaint alleges that Genesis Growth Tech is the assignee of all right, title and interest in both patents, including the right to enforce them. It says the '100 patent issued on March 9, 2021, from an application filed on January 19, 2018, and the '053 patent issued on November 8, 2022, from an application filed on August 24, 2020. The '053 patent is a continuation of the '100 patent.
USPTO assignment records show an assignment of the '100 patent application from its inventors to Mindmaze Holding SA, recorded May 31, 2018 (Reel/Frame 45941/0761), and a change of name from Mindmaze Holding SA to Mindmaze Group SA, effective November 22, 2021, recorded against both patents. They show an assignment of both patents from Mindmaze Group SA to Genesis Growth Tech LLC, executed November 17, 2023 and recorded October 29, 2025 (Reel/Frame 72711/0442).
U.S. Patent 10,943,100 covers a system for determining a facial expression from EMG (electromyography) signals. Claim 1 requires an apparatus with a plurality of EMG electrodes configured for contact with the user's face and a computational device that processes the EMG signals and classifies a facial expression using a classifier, where the processing determines a roughness of the EMG signals according to a predefined window and the classifier classifies the expression according to that roughness.
U.S. Patent 11,495,053 covers a method, operated by a computational device, for determining a facial expression from EMG electrode signals. Claim 1 requires receiving EMG signals from electrodes in contact with the user's face, processing them by determining roughness according to a defined window, determining whether the expression is neutral or non-neutral, and classifying a non-neutral expression according to the roughness. The processing also removes noise before determining roughness and normalizes the signals after.
The infringement allegations
The complaint pleads two counts, one for each patent, in parallel terms. For each, it alleges direct infringement of one or more claims in the district, literally or under the doctrine of equivalents, by making, using, offering to sell, selling, or importing exemplary defendant products identified in attached charts, and by employees' internal testing and use of those products. It alleges, on information and belief, that numerous other devices that infringe have been made, used, sold, imported, and offered for sale by iMotions and/or its customers. It alleges that service of the complaint, together with the claim charts and references cited, constitutes actual knowledge of infringement, and alleges, on information and belief, that iMotions has continued to sell the exemplary products and distribute product literature and website materials inducing end users to use its products in a manner that infringes. It alleges induced infringement at least since service of the complaint and the corresponding claim charts. The complaint says Exhibits 1 and 2 include charts comparing the exemplary claims of the '100 and '053 patents to the exemplary products. The exhibits filed with the complaint, including the claim charts, are not on the public docket.
The relief sought
The prayer asks for judgments that each patent is valid and enforceable and that iMotions has infringed directly and indirectly one or more claims of each, an accounting of damages not presented at trial, a declaration that the case is exceptional under 35 U.S.C. 285 with reasonable attorneys' fees, costs and expenses, and further relief at law or in equity. Each count alleges that Genesis Growth Tech is entitled to damages adequate to compensate for the infringement. The complaint demands a jury under Rule 38(b).
An earlier suit on the '100 patent
Genesis Growth Tech filed an earlier suit in the same court on March 24, 2026, Genesis Growth Tech LLC v. Varjo Technologies Oy, No. 2:26-cv-00236 (E.D. Tex.), asserting the '100 patent and U.S. Patent 10,515,474, titled System, method and apparatus for detecting facial expression in a virtual reality system. The public claim chart for the '100 patent in that case, Exhibit 4 to the complaint, compares claim 1 to the Varjo XR-3 headset. The docket shows the case is assigned to Judge Robert W. Schroeder III and referred to Magistrate Judge Roy S. Payne, that Varjo filed an answer on August 12, 2026, and that the court entered a docket control order on September 24, 2026. Isaac Rabicoff of Rabicoff Law LLC is counsel for Genesis Growth Tech in that case as well.
What to watch next
Watch for service on iMotions A/S, a Danish corporation, and for an answer or a Rule 12 motion.