A federal jury in the Western District of Washington ruled in favor of Valve Corporation on all counts in its lawsuit against Display Technologies, LLC on February 17, 2026. The verdict found violations of Washington's Patent Troll Prevention Act (PTPA, RCW 19.350), the Consumer Protection Act (CPA, RCW 19.86), and breach of a 2016 global licensing agreement. Damages totaled approximately $152,093, with personal liability imposed on the principal individual through piercing the corporate veil.

Prior to trial, the court ruled in January 2026 that the CPA provides a private right of action for PTPA violations, rejecting the argument that enforcement is limited to the state Attorney General. The case originated from a July 2023 complaint filed by Valve after receiving infringement demands over patents already covered by an existing license.

Damages Awarded

$152,093

Jury verdict, February 17, 2026

Historic First

1st

U.S. jury verdict under a state patent troll prevention statute

Statute Enacted

2015

Washington Patent Troll Prevention Act (RCW 19.350)

Background on the Washington Patent Troll Prevention Act

Enacted in 2015, the PTPA prohibits bad-faith assertions of patent infringement under RCW 19.350 . The statute lists factors courts may consider as evidence of bad faith, including demands lacking detailed infringement analysis, threats disproportionate to potential recovery, and assertions without a reasonable basis for infringement or patent validity.

Violations constitute unfair or deceptive acts under the CPA, with the legislature declaring such practices as matters vitally affecting the public interest under RCW 19.350.030. The PTPA applies to assertions targeting Washington businesses or entities and is not limited to specific industries such as video games or software. Any Washington-based company receiving a bad-faith infringement demand may invoke the statute.

Case Timeline and Key Rulings

{[ { date: '2016', event: 'Valve enters Global Settlement and License Agreement (GSLA) with Display Technologies, LLC entities, granting a perpetual, irrevocable, royalty-free license to covered patents in exchange for a settlement payment.', }, { date: '2022', event: 'Display Technologies, LLC sues Valve for infringement of a patent covered by the GSLA, then voluntarily dismisses the case.', }, { date: 'June 2023', event: 'Additional demand letter asserts infringement of U.S. Patent No. 8,856,221, a patent claimed to be covered by the existing license.', }, { date: 'July 2023', event: 'Valve files suit (No. 2:23-cv-01016-JNW, Western District of Washington) alleging breach of the GSLA and bad-faith assertions under the PTPA and CPA.', }, { date: 'January 2026', event: 'Court denies motion for partial summary judgment, confirming that PTPA violations constitute unfair or deceptive acts under the CPA and that private parties may sue under RCW 19.86.090.', }, { date: 'February 17, 2026', event: 'Jury returns verdict for Valve on all counts. Damages of $130,001 awarded for contract breach and $22,092 for PTPA/CPA violations. Personal liability imposed on the principal through corporate veil piercing.', }, ].map(({ date, event }, i) => (

{date}

{event}

))}

Private Enforcement Under the PTPA via Consumer Protection Act

The court's January 2026 ruling clarified that PTPA violations qualify as unfair or deceptive acts under the CPA, which explicitly provides a private right of action for injured persons under RCW 19.86.090. The PTPA incorporates the CPA and declares covered practices as vitally affecting the public interest, enabling private suits without requiring the Attorney General to initiate the action.

This interpretation aligns with prior federal decisions applying similar logic to the statute, including Microsoft Corp. v. MediaPointe, 626 F. Supp. 3d 1129 (C.D. Cal. 2022). The ruling is significant for Washington businesses that receive patent troll demands: they now have a confirmed judicial path to sue for bad-faith assertions without waiting for state enforcement action. The decision does not change the text of the PTPA; it clarifies the mechanism through which private parties access existing rights.

Court Order Key Point -- January 2026

"PTPA violations constitute unfair or deceptive acts under the Consumer Protection Act. Private parties injured by such violations may bring suit under RCW 19.86.090 without requiring Attorney General initiation."

Paraphrase. Western District of Washington, No. 2:23-cv-01016-JNW.

Broader Application and First Jury Verdict Details

This case marks the first U.S. jury verdict finding liability under a state patent troll prevention statute, with personal liability imposed through corporate veil piercing. Prior enforcement examples under similar statutes involved state Attorneys General, such as actions in Washington against entities like Landmark Technology. Valve pursued this case independently, with no state enforcement involvement.

The verdict does not amend the PTPA text or restrict its application to the video game industry. The law covers bad-faith patent assertions across all industries targeting Washington entities. Damages broke down as $130,001 for breach of the Global Settlement and License Agreement and $22,092 for PTPA/CPA violations.

Veil piercing allowed the jury to impose personal liability on the principal behind Display Technologies, LLC, meaning the individual cannot use the corporate entity as a shield against the judgment. This component of the verdict is notable for plaintiffs pursuing similar claims against single-person patent assertion entities.

Component	Amount	Basis
Contract Breach (GSLA)	$130,001	Violation of 2016 perpetual license agreement
PTPA / CPA Violations	$22,092	Bad-faith patent assertions under RCW 19.350 / RCW 19.86
Total Awarded	$152,093	Jury verdict, Western District of Washington

Key Statistics Summary

{[ ['Jury verdict date', 'February 17, 2026'], ['Total damages awarded', '$152,093'], ['Contract breach damages', '$130,001'], ['PTPA/CPA damages', '$22,092'], ['PTPA enactment year', '2015'], ['Statute citation', 'RCW 19.350'], ['Private right confirmed', 'January 2026 court order'], ['Case number', 'No. 2:23-cv-01016-JNW, Western District of Washington'], ['Patent at issue', 'U.S. Patent No. 8,856,221 (among others)'], ['License agreement date', '2016 (perpetual, irrevocable, royalty-free)'], ['Personal liability mechanism', 'Corporate veil piercing'], ['Historic significance', 'First U.S. jury verdict under a state patent troll prevention statute'], ].map(([label, value], i) => ( ))}

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