DCT

3:24-cv-06567

Samsung Electronics Co Ltd Et Al v. CM HK Ltd Et Al

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:24-cv-06567, N.D. Cal., 09/18/2024
  • Venue Allegations: Venue is alleged to be proper based on Defendants being foreign entities subject to personal jurisdiction in the district, and Defendant CyWee Group Ltd. maintaining an office in Santa Clara, California.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its mobile devices do not infringe four patents owned by Defendants related to motion recognition technology using fused sensor data.
  • Technical Context: The technology at issue involves methods for using data from multiple sensors in a handheld device, such as accelerometers and gyroscopes, to accurately recognize user motions and gestures in three-dimensional space.
  • Key Procedural History: The complaint alleges this dispute arises after a previous lawsuit filed by CyWee against Samsung in 2017 in the Eastern District of Texas on related patents. In that prior case, the asserted claims were found unpatentable in inter partes review (IPR) proceedings, a decision affirmed by the U.S. Court of Appeals for the Federal Circuit. Following the dismissal of the Texas action, Defendants allegedly began asserting the current patents-in-suit—which issued after the IPRs—and threatened new litigation with a damages demand exceeding $500 million, prompting this declaratory judgment action by Samsung.

Case Timeline

Date Event
2009-07-14 Earliest Priority Date for ’038 and ’072 Patents
2010-01-06 Earliest Priority Date for ’846 and ’687 Patents
2017-02-XX CyWee files EDTX lawsuit against Samsung on related patents
2018-06-XX Google files IPR petitions on related patents
2018-10-XX ZTE files IPR petition on a related patent
2018-12-XX Google's IPR petitions are instituted
2019-04-30 ’038 Patent Issued
2020-10-27 ’072 Patent Issued
2020-12-01 ’846 Patent Issued
2023-07-11 ’687 Patent Issued
2024-04-04 Federal Circuit affirms PTAB invalidation of claims in prior litigation
2024-08-14 EDTX lawsuit is dismissed
2024-09-18 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 10,817,072 - "Method and Apparatus for Performing Motion Recognition Using Motion Sensor Fusion, and Associated Computer Program Product"

The Invention Explained

  • Problem Addressed: The patent describes that conventional motion recognition methods using single-type sensors (like only a G-sensor or only a gyroscope) are often inaccurate because they cannot distinguish between different types of motion or account for the device's orientation (Compl. ¶1; ’072 Patent, col. 1:54-66). For example, a G-sensor alone cannot decouple linear acceleration from the force of gravity, causing the same physical motion to produce different sensor readings if the device is tilted differently (’072 Patent, col. 2:1-9).
  • The Patented Solution: The invention proposes a method that fuses data from a plurality of motion sensors to create a more robust interpretation of user movement. The core concept involves converting sensor data measured in the device's own coordinate system into a "global coordinate system" of the user. This conversion allows the system to recognize a user's motion accurately, regardless of the device's specific orientation in 3D space, and to recognize characters drawn by the user through motion (’072 Patent, Abstract; col. 2:32-47). The system then maps the user's motion onto a plane to identify a trajectory for recognition (’072 Patent, cl. 1).
  • Technical Importance: This approach aims to make gesture and motion-based controls for handheld devices more reliable and intuitive by making them independent of the device's orientation relative to the user (’072 Patent, col. 2:26-31).

Key Claims at a Glance

  • The complaint identifies independent claims 1 and 10 as being at issue (Compl. ¶70).
  • Independent Claim 1 of the ’072 Patent includes the following essential elements:
    • A method for obtaining sensor data from inertial motion sensors.
    • Performing sensor fusion to obtain an orientation comprising resultant angles (roll, pitch, yaw).
    • Selecting one of at least one predetermined plane based on the orientation.
    • Mapping the resultant angles onto the selected plane to obtain a trajectory.
    • Performing motion recognition based on the trajectory to recognize the user's motion in 3D space.
    • The recognition includes recognizing at least one character drawn by the user in 3D space, which is then loaded into a character recognition software module.
    • The method also includes resetting the yaw angle of the device to a predetermined value.
  • The complaint does not explicitly reserve the right to assert dependent claims but references "any claims" in its prayer for relief (Compl. p. 14).

U.S. Patent No. 10,275,038 - "Method and Apparatus for Performing Motion Recognition Using Motion Sensor Fusion, and Associated Computer Program Product"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problem as the ’072 Patent: conventional motion recognition systems that rely on individual sensors are unreliable because their output is dependent on the device's tilt and orientation relative to gravity (’038 Patent, col. 1:54-66).
  • The Patented Solution: The patented solution is a method that combines data from multiple inertial sensors through "sensor fusion." This process converts motion data from the device's local coordinate system to a user-centric global coordinate system. By doing so, the system can recognize a user's motion, including characters drawn in mid-air, irrespective of how the device is held, by mapping the motion data onto a predetermined plane to form a trajectory for analysis (’038 Patent, Abstract; col. 2:32-47).
  • Technical Importance: The technology seeks to provide a more accurate and user-friendly motion control interface for portable electronics, enhancing functionalities that rely on gesture inputs (’038 Patent, col. 2:26-31).

Key Claims at a Glance

  • The complaint identifies independent claims 1 and 13 as being at issue (Compl. ¶76).
  • Independent Claim 1 of the ’038 Patent includes the following essential elements:
    • A method for obtaining sensor data from inertial motion sensors.
    • Performing sensor fusion to obtain motion data and orientation based on a global coordinate system.
    • Selecting one of at least one predetermined plane based on the orientation.
    • Mapping the motion data onto the selected plane to obtain a trajectory.
    • Performing motion recognition based on the trajectory to recognize the user's motion in 3D space and at least one character drawn by the user in 3D space.
  • The complaint does not explicitly reserve the right to assert dependent claims but references "any claims" in its prayer for relief (Compl. p. 14).

U.S. Patent No. 10,852,846 - "Electronic Device for Use in Motion Detection and Method for Obtaining Resultant Deviation Thereof"

  • Technology Synopsis: This patent describes a method for accurately determining a device's orientation in 3D space (its "resultant deviation") using a nine-axis sensor module that includes a rotation sensor, an accelerometer, and a magnetometer. The invention uses a comparison model, representing orientation with quaternions, to process sensor data by comparing "predicted axial accelerations" with measured accelerations to correct for errors and produce a more accurate orientation output (’846 Patent, Abstract; col. 7:29-46).
  • Asserted Claims: Claims 1 and 7 (Compl. ¶82).
  • Accused Features: The complaint alleges non-infringement by asserting that Samsung's mobile devices, to the extent they calculate quaternions, do so using measured angular velocity and acceleration, rather than the claimed methods of "obtaining a quaternion by predicting axial accelerations" or comparing predicted with measured accelerations (Compl. ¶82).

U.S. Patent No. 11,698,687 - "Electronic Device for Use in Motion Detection and Method for Obtaining Resultant Deviation Thereof"

  • Technology Synopsis: This patent is related to the ’846 Patent and similarly discloses a method for obtaining a device's orientation using sensor fusion. The method involves generating a "previous quaternion" corresponding to a prior time, converting current measured angular velocities into a "current quaternion," and then obtaining an "updated quaternion" by comparing predicted axial accelerations with measured axial accelerations. This process is designed to produce a more accurate resultant deviation (’687 Patent, Abstract).
  • Asserted Claims: Claims 1, 14, and 27 (Compl. ¶88).
  • Accused Features: Samsung's non-infringement argument mirrors its position on the ’846 Patent, stating that its devices do not practice the claimed steps of "obtaining a quaternion by predicting axial accelerations" or comparing predicted values with measured values to update the orientation (Compl. ¶88).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "Samsung's mobile devices" (Compl. ¶¶13, 22).

Functionality and Market Context

  • The complaint states that these devices contain "one or more sensors that are capable of determining a mobile device's position and movement" (Compl. ¶59). In its specific non-infringement allegations, the complaint asserts that to the extent these devices perform character recognition, they do so in "two-dimensional space" and without the "angle mapping with sensor fusion data" claimed in the ’072 Patent (Compl. ¶¶70-71). For the patents related to quaternion calculations (’846 and ’687 Patents), the complaint alleges that Samsung's devices utilize "measured angular velocity and acceleration," not the predicted values required by the claims (Compl. ¶¶82, 88).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

10,817,072 Infringement Allegations

Claim Element (from Independent Claim 1) Samsung's Alleged Non-Infringing Functionality Complaint Citation Patent Citation
mapping the resultant angles onto the selected one of the at least one predetermined plane to obtain a trajectory... The accused devices allegedly perform character recognition without mapping resultant angles from sensor fusion data onto a plane to obtain a trajectory. ¶70-71 col. 22:49-54
performing motion recognition based on the trajectory on the selected one of the at least one predetermined plane at the spatial reference frame in order to recognize the user's motion in 3D space... The accused devices allegedly do not recognize user motion in three-dimensional space for character recognition. ¶70 col. 22:55-58
...and at least one character drawn by the user in the 3D space... To the extent the accused devices perform character recognition, the operation is allegedly performed in two-dimensional space, not three-dimensional space. ¶70 col. 22:59-61

10,275,038 Infringement Allegations

Claim Element (from Independent Claim 1) Samsung's Alleged Non-Infringing Functionality Complaint Citation Patent Citation
performing motion recognition based on the trajectory on the selected one of the at least one predetermined plane at the global coordinate system in order to recognize the user's motion in 3D space... The accused devices allegedly do not perform motion recognition in three-dimensional space for character recognition. ¶76 col. 21:44-48
...and at least one character drawn by the user in the 3D space... To the extent the accused devices perform character recognition, such operation is allegedly performed in two-dimensional space. ¶76 col. 21:48-50

Identified Points of Contention

  • Scope Questions: A central dispute for the ’072 and ’038 patents will likely be the definitional scope of performing character recognition "in 3D space." Samsung alleges its devices operate in "two-dimensional space." The defendants may argue that capturing motion that occurs in 3D and projecting it onto a 2D plane for analysis falls within the scope of the claims. This raises the question of whether the claim term refers to the environment of the physical motion or the dimensionality of the data used in the final recognition algorithm.
  • Technical Questions: For the ’846 and ’687 patents, the dispute appears to be a direct technical mismatch. The claims require calculating orientation (quaternions) using predicted axial accelerations derived from other sensor data. Samsung alleges its devices use measured axial accelerations. The key question will be whether Samsung's method is technically distinct from the claimed method and, if so, whether it could be considered equivalent under the doctrine of equivalents.

V. Key Claim Terms for Construction

The Term: "recognizing user motion in three-dimensional space for character recognition"

  • (from ’038 Patent, cl. 1; ’072 Patent, cl. 1)
  • Context and Importance: This term is critical because Samsung’s primary non-infringement defense for the ’038 and ’072 patents rests on its assertion that its devices perform character recognition in "two-dimensional space." The construction of this term will determine whether the accused functionality can be distinguished from the claimed invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discloses embodiments where a 3D hand-writing motion is projected onto a 2D plane (e.g., an "XZ plane" or "XY plane") to extract 2D points for recognition (’038 Patent, Figs. 36-37, col. 19:1-55). A party could argue that this entire process, which begins with a 3D motion, constitutes recognition "in 3D space," even if the final algorithmic step operates on 2D data.
    • Evidence for a Narrower Interpretation: The same embodiments explicitly state that the system "extract[s] the 2D points from the 3D points" and then "runs character recognition" on those 2D points (’038 Patent, col. 19:30-33, col. 20:49-52). A party could argue this language demonstrates that the "recognition" step itself is a 2D process, and the claim requires the recognition algorithm, not just the user's physical motion, to operate in 3D.

The Term: "obtaining a quaternion by predicting axial accelerations"

  • (referenced in non-infringement allegation for ’846 Patent, Compl. ¶82). A related term appears in the ’846 patent claims, which describe comparing "predicted axial accelerations" with "measured axial accelerations" to obtain an updated state (’846 Patent, cl. 1).
  • Context and Importance: Samsung's non-infringement theory for the ’846 and ’687 patents hinges on the distinction between using predicted versus measured data. Practitioners may focus on this term because it points to a specific, potentially dispositive difference in the algorithms at issue.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that any algorithm that generates an expected acceleration value based on a model (even a simple one) and compares it to a sensor reading is performing a "prediction," and that Samsung's use of "measured" data is just a semantic distinction for a functionally similar predictive filtering process.
    • Evidence for a Narrower Interpretation: The patent specification describes a specific sequence where "predicted axial accelerations" are calculated based on the "current state" (derived from angular velocities) before being compared to the "measured axial accelerations" from the accelerometer (’846 Patent, Fig. 7, steps 730 and 735). A party could argue this requires two distinct data sources—one model-based prediction and one direct measurement—and that an algorithm using only direct measurements does not meet this limitation.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement allegations, as it is a complaint for declaratory judgment of non-infringement. It includes a blanket denial of all forms of infringement, stating Samsung "has not caused, directed, requested, or facilitated any such infringement, and never had any specific intent to do so" (Compl. ¶66). The extensive pre-suit communications cited in the complaint, however, suggest that if Defendants counterclaim for infringement, they will have a basis to allege post-suit, and potentially pre-suit, knowledge for a willfulness claim against Samsung (Compl. ¶¶20, 33-34, 44).

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

  • A core issue will be one of definitional scope: Can the claim limitation "recognizing... in three-dimensional space" be construed to cover a process where a physical 3D gesture is captured by sensors and then projected onto a 2D data plane for the final character recognition step?
  • A key evidentiary question will be one of algorithmic distinction: Do Samsung's mobile devices, as alleged, use a fundamentally different method for calculating orientation—one based on direct, measured data—than the patented methods, which require calculating and comparing "predicted" data values?
  • A central procedural question will be the relationship between the entities: The complaint alleges that Defendant CM HK is an "agent, alter ego, and/or successor" of Defendant CyWee, suggesting a unity of interest that may be relevant to jurisdiction, liability, and the history of assertions against Samsung (Compl. ¶¶47-54).