DCT

3:23-cv-00048

Golden v. Samsung Electronics America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:23-cv-00048, N.D. Cal., 01/05/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Samsung maintains a regular and established place of business in the district, transacts business and offers the accused products for sale within the district, and has committed alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy smartphones infringe three U.S. patents related to integrated systems for multi-sensor detection, remote monitoring, and access control.
  • Technical Context: The technology at issue involves embedding or connecting various environmental and security sensors to communication devices to create a networked system for detecting threats and controlling product access.
  • Key Procedural History: The complaint states that it "mirrors" a complaint previously filed against Google LLC involving the same patents. In that related case, the U.S. Court of Appeals for the Federal Circuit vacated a district court dismissal, concluding that the complaint and its claim charts were "not facially frivolous." The complaint also notes a prior case in the Court of Federal Claims where Samsung was allegedly provided notice to appear but failed to do so.

Case Timeline

Date Event
2004-11-26 Plaintiff’s first Disclosure Document filed with USPTO
2006-04-05 Earliest Priority Date for ’287, ’439, and ’189 Patents
2007-10-17 Samsung i550, first GPS phone, launch announced
2009-06-29 Samsung GT-I7500, first Android phone, released
2015-08-04 U.S. Patent No. 9,096,189 issues
2017-03-07 U.S. Patent No. 9,589,439 issues
2018-12-25 U.S. Patent No. 10,163,287 issues
2023-01-05 Complaint filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,163,287 - "Multi Sensor Detection, Stall to Stop and Lock Disabling System"

Issued Dec. 25, 2018

The Invention Explained

  • Problem Addressed: The patent background describes the continuous threat of terrorist activity and the need for security protocols to control access to vulnerable assets, such as shipping containers and vehicles, and to detect chemical, biological, and radiological hazards (ʼ287 Patent, col. 2:1-22).
  • The Patented Solution: The invention proposes a system featuring a "detector case" containing interchangeable detectors for various threats (ʼ287 Patent, col. 3:56-62). When placed on or near a product, this system can detect a hazardous agent, transmit an alert to a remote monitoring terminal, and send a signal to a "lock disabler" to secure the product and prevent unauthorized access or further contamination (ʼ287 Patent, Abstract; col. 4:25-35).
  • Technical Importance: The described technology integrates environmental sensing with remote access control, creating an automated security response system for assets in transit or static storage (ʼ287 Patent, col. 3:23-34).

Key Claims at a Glance

  • The complaint asserts independent claims 4, 5, and 6 (Compl. ¶31). The analysis focuses on claim 5, which is detailed in the complaint's claim chart.
  • Essential Elements of Independent Claim 5 (A monitoring device):
    • A central processing unit (CPU).
    • Multiple standard hardware components in communication with the CPU, including a temperature sensor, motion sensor, viewing screen, and GPS.
    • Multiple communication connections, including internet/Wi-Fi and Bluetooth/cellular/satellite.
    • A power source.
    • A locking mechanism configured to engage, disengage, or disable the device.
    • A biometric sensor for authentication.
    • At least one sensor for chemical, biological, or human detection.
    • One or more detectors for chemical, biological, radiological, or explosive agents.
    • An NFC connection.
    • A transmitter or transceiver configured to send signals for monitoring, control, or detection.

U.S. Patent No. 9,589,439 - "Multi Sensor Detection, Stall to Stop and Lock Disabling System"

Issued Mar. 7, 2017

The Invention Explained

  • Problem Addressed: The patent addresses the same security and anti-terrorism problems as the ’287 Patent, focusing on the need for proactive detection and access control for a wide range of products and locations (’439 Patent, col. 2:5-22).
  • The Patented Solution: This invention focuses on integrating threat detection capabilities directly into a personal communication device, such as a cell phone (’439 Patent, Abstract). It claims a cell phone comprising a CPU and at least one sensor (e.g., chemical, biological, explosive) capable of being disposed "within, on, upon or adjacent" the device. Upon detection, the sensor causes the cell phone to send a signal that includes location or sensor data (’439 Patent, col. 26:1-13).
  • Technical Importance: The patent describes transforming a ubiquitous device like a cell phone into a mobile, networked node for environmental threat detection and security alerts (’439 Patent, col. 11:25-34).

Key Claims at a Glance

  • The complaint asserts independent claims 13, 14, 15, and 23 (Compl. ¶35). The analysis focuses on claim 23, which is detailed in the complaint's claim chart.
  • Essential Elements of Independent Claim 23 (A cell phone):
    • A central processing unit (CPU).
    • At least one sensor (chemical, biological, explosive, human, contraband, or radiological) disposed within, on, upon, or adjacent to the cell phone.
    • A biometric lock disabler for preventing unauthorized use.
    • Interconnection to a cell phone detection device.
    • The sensor causes a signal containing location or sensor data to be sent to the cell phone.

U.S. Patent No. 9,096,189 - "Multi Sensor Detection, Stall to Stop and Lock Disabling System"

Issued Aug. 4, 2015

Technology Synopsis

The ’189 Patent claims a communication device, such as a smart phone or PDA, that serves as a central hub for monitoring and controlling external products (’189 Patent, col. 15:11-17). The device includes a CPU, a transmitter/receiver for communicating with multi-sensor or locking devices, and is equipped with a biometric lock disabler to prevent unauthorized use (’189 Patent, Claim 1). The invention centers on using a personal electronic device to manage a distributed network of security sensors and locks.

Asserted Claims

Independent claim 1 and dependent claims 2 and 3 (Compl. ¶39).

Accused Features

The complaint alleges that Samsung smartphones, with their CPUs, biometric scanners (e.g., fingerprint), and diverse communication radios (Wi-Fi, Bluetooth, cellular), infringe by functioning as the claimed central communication device for monitoring and controlling products (Compl. pp. 19-25).

III. The Accused Instrumentality

Product Identification

Various models of Samsung Galaxy smartphones, including the Galaxy S7, S8, S20, S21, and S22 series, and Note series devices ("the Accused Products") (Compl. ¶9, ¶31).

Functionality and Market Context

The complaint alleges the Accused Products are smartphones operating on the Android OS and incorporating Qualcomm chipsets (Compl. ¶5). Their functionality is alleged to include a CPU, a suite of standard sensors (e.g., ambient temperature, gravity, light), multiple communication capabilities (Wi-Fi, Bluetooth, cellular, GPS, NFC), and biometric authentication features (e.g., fingerprint) (Compl. pp. 19-22). The complaint further alleges that the Accused Products can run software such as the Android Team Awareness Kit (ATAK), which offers geospatial mapping and can integrate with plug-ins for detecting chemical, biological, radiological, and nuclear (CBRN) agents (Compl. ¶5, ¶55). Figure 4 in the complaint is a diagram titled "The Smartphones Biosensors," which illustrates how standard components like the ambient light sensor, camera, and microphone can allegedly be used to detect biomarkers, pathogens, and toxins (Compl. p. 30).

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,163,287 Infringement Allegations

Claim Element (from Independent Claim 5) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one central processing unit (CPU) The Accused Products contain octa-core CPUs as part of their System-on-a-Chip architecture. ¶42 col. 3:59-62
at least one temperature sensor in communication with the at least one CPU for monitoring temperature The Accused Products include an Ambient Temperature sensor supported by the Android platform that measures ambient room temperature. ¶5 col. 8:31-44
at least one sensor for chemical, biological, or human detection in communication with the at least one CPU The Android Team Awareness Kit (ATAK) software, used on the devices, provides an interface for CBRN-sensing technologies and human vitals detection. ¶55 col. 3:56-62
one or more detectors in communication with the at least one CPU for detecting at least one of chemical, biological, radiological, or explosive agents The complaint alleges that smartphone cameras with microfluidic lenses can function as detectors to map airborne toxins. ¶54 col. 8:31-35
at least one locking mechanism in communication with the at least one CPU for locking the communication device... The Accused Products include screen lock options and a remote unlock method via "Find My Mobile" to prevent unauthorized access. ¶57 col. 12:25-34
at least one biometric sensor in communication with the at least once CPU for providing biometric authentication to access the communication device The Android framework on the Accused Products includes support for face and fingerprint biometric authentication. ¶56 col. 9:15-32

U.S. Patent No. 9,589,439 Infringement Allegations

Claim Element (from Independent Claim 23) Alleged Infringing Functionality Complaint Citation Patent Citation
a central processing unit (CPU) for executing and carrying out the instructions of a computer program The Accused Products contain octa-core CPUs that execute instructions for the Android operating system and applications. ¶42 col. 11:4-8
at least one of a chemical sensor, a biological sensor...or a radiological sensor capable of being disposed within, on, upon or adjacent the cell phone The complaint alleges that ATAK software on the phones includes CBRN plug-ins and integrates with external sensors, and that the phone's camera can serve as a chemical sensor. ¶55 col. 11:28-34
wherein the cell phone is equipped with a biometric lock disabler that incorporates at least one of a fingerprint recognition... The Accused Products running the Android platform include fingerprint biometric authentication to secure the device. ¶56 col. 26:1-6
whereupon a signal sent to the receiver of the cell phone detection device...causes a signal that includes at least one of location data or sensor data to be sent to the cell phone The ATAK application on the Accused Products provides geospatial mapping and can relay location and sensor data from CBRN plug-ins. ¶55 col. 26:7-13

Identified Points of Contention

  • Scope Questions: A primary issue may be whether standard, general-purpose smartphone components (e.g., a camera, ambient light sensor) fall within the scope of claim terms like "sensor for chemical, biological, or human detection" or "detectors." The complaint's infringement theory appears to rely on software (like ATAK or camera analysis applications) repurposing this general hardware for specialized detection functions (Compl. p. 28, Fig. 2). This raises the question of whether the patent claims require dedicated, purpose-built hardware for such detection.
  • Technical Questions: The analysis may turn on the precise operation of the accused locking features. The complaint maps Android's user-access locks (e.g., pattern lock, remote lock) to the claimed "locking mechanism" and "biometric lock disabler" (Compl. pp. 21-22). A potential point of contention is whether a software feature that prevents user interface access is technically equivalent to the "lock disabler" described in the patent, which in some embodiments is depicted as a physical or electromechanical device for securing a product lock (ʼ287 Patent, Fig. 1).

V. Key Claim Terms for Construction

The Term: "sensor for chemical, biological, or human detection" / "detectors... for detecting... chemical, biological, radiological, or explosive agents" (’287 Patent, cl. 5)

  • Context and Importance: The viability of the infringement case largely depends on this term's construction. If construed to only cover specialized, purpose-built hardware, the infringement allegations against standard smartphone components may be difficult to sustain. If construed more broadly to include general-purpose hardware configured by software, the plaintiff's position may be strengthened. Practitioners may focus on whether the claims require a transducer designed to react to specific analytes, or if a general data-capture device like a camera qualifies.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the system is designed for "detecting harmful and dangerous chemical, biological, and radiological agents, compounds and elements" without limiting the specific structure of the detector itself (’287 Patent, col. 3:56-60). The context of integrating the system into various devices, including cell phone cases, may suggest flexibility in the form of the sensor (’287 Patent, col. 12:51-54).
    • Evidence for a Narrower Interpretation: The primary embodiment described and illustrated shows distinct, "interchangeable detectors" (46) housed within a "detector case" (12), implying discrete hardware modules designed for specific sensing tasks (’287 Patent, Fig. 1; col. 8:31-44). The patent's title, "Multi Sensor Detection...System," could also be argued to imply a system of distinct sensor components rather than a single, repurposed component.

The Term: "locking mechanism... configured to... disable (make unavailable) the communication device" (’287 Patent, cl. 5)

  • Context and Importance: The complaint equates this element with Android's screen lock and remote access control features. The dispute will likely center on the meaning of "disable (make unavailable)." Does this require rendering the device electronically inoperable, or does preventing user access suffice?
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The Abstract describes the goal of the lock disabler as "preventing untrained, unauthorized and unequipped individuals from gaining access and entry to the product," which focuses on barring access rather than functional incapacitation (’287 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The specification also describes a "stall-to-stop" functionality for vehicles, which disables the "computer, electrical, fuel and air systems" of the vehicle (’287 Patent, col. 12:25-31). This embodiment suggests a more fundamental deactivation of the device's operational capabilities, which a software screen lock on a still-running phone may not achieve.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory patent infringement (Compl. p. 1, ¶9). The factual basis appears to be that by manufacturing and selling smartphones with the Android OS, pre-installed sensors, and access to applications like ATAK, Samsung provides the means for and encourages users to operate the devices in an infringing manner (Compl. ¶5, ¶55, ¶62).
  • Willful Infringement: The complaint does not make an express allegation of "willful infringement." However, it does allege facts that could support a finding of pre-suit knowledge, stating that Samsung was provided notice to appear in a related Court of Federal Claims case and "failed to appear to protect its interest" (Compl. ¶27).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can claim terms such as "sensor for chemical... detection" and "detector" be construed to cover general-purpose smartphone components, like a high-resolution camera, when paired with specialized analytical software, or are they limited to dedicated hardware designed for that specific purpose?
  • A second key issue will be one of functional operation: does a software-based user interface lock, which prevents access but allows the underlying device to remain operational, perform the same function as the claimed "locking mechanism configured to... disable (make unavailable) the communication device," or does the claim require a more fundamental deactivation of the device's core functions?
  • A central evidentiary question will be whether the use of applications like ATAK with CBRN plug-ins on the Accused Products constitutes direct infringement of the asserted claims, and what level of knowledge and intent Samsung possessed regarding this specific use case to support the claims for indirect infringement.