DCT

5:11-cv-01846

Apple Inc v. Samsung Electronics Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:11-cv-01846, N.D. Cal., 06/16/2011
  • Venue Allegations: Venue is alleged to be proper because Samsung transacts business and offers infringing products for sale within the Northern District of California, and because Apple's principal place of business is in the district, where it has suffered harm.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy line of smartphones and tablet computers infringes numerous utility patents, design patents, and trademarks, and copies the trade dress of Apple's iPhone, iPod touch, and iPad products.
  • Technical Context: The dispute centers on the industrial design, user interface, and overall "look and feel" of smartphones and tablet computers in the period following the introduction of the original iPhone.
  • Key Procedural History: The filing is an Amended Complaint, which adds and refines claims from a prior version. The complaint alleges a consistent pattern of copying by Samsung, starting shortly after the announcement and release of Apple's iPhone and iPad products.

Case Timeline

Date Event
1994-09-30 U.S. Patent No. 6,493,002 Priority Date
2002-12-10 U.S. Patent No. 6,493,002 Issued
2007-01-07 U.S. Patent No. 7,469,381 Priority Date
2007-01-XX Apple introduces first iPhone product
2007-06-XX Apple releases first iPhone product for sale
2007-11-XX Samsung releases the Samsung F700
2008-01-22 U.S. Patent No. 7,469,381 Issued
2008-06-XX Apple introduces iPhone 3G
2008-07-XX Apple releases iPhone 3G for sale
2009-06-XX Apple releases iPhone 3GS for sale
2010-01-XX Apple introduces the iPad
2010-03-XX Samsung announces Samsung Galaxy S i9000 phone
2010-06-XX Apple releases iPhone 4 for sale
2010-11-XX Samsung introduces the Samsung Galaxy Tab
2011-02-XX Photographs of Samsung Galaxy S 2 phone published
2011-03-XX Apple announces and releases iPad 2
2011-06-08 Samsung commences U.S. sales of Galaxy Tab 10.1
2011-06-16 Complaint Filing Date

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

U.S. Patent No. 6,493,002 - "Method and Apparatus for Displaying and Accessing Control and Status Information in a Computer System," Issued Dec. 10, 2002

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty of accessing system and control programs, which often requires locating and executing a program, a process that can be "unduly long" (ʼ002 Patent, col. 1:45-49). It also notes that multiple overlapping windows on a display can obscure important system or control information, making it desirable to have certain windows that are "always visible to the user" (ʼ002 Patent, col. 2:1-4).
  • The Patented Solution: The invention provides for a "control strip," which is a window that can be configured to permanently display control and status information in an easily accessible format (ʼ002 Patent, col. 2:4-6). This control strip is implemented in a private window layer that appears "in front of the windows of all the application layers," preventing other application windows from obscuring it (ʼ002 Patent, col. 6:40-45). The strip contains individual modules for specific functions, such as a battery monitor or file sharing status (ʼ002 Patent, col. 7:59-62, 8:10-16). Figure 2A shows the control strip (200) at the bottom of a computer desktop display.
  • Technical Importance: This approach provides a persistent, non-overlapping user interface element for system-level controls, improving user efficiency by consolidating status indicators and controls into a single, always-accessible location.

Key Claims at a Glance

  • The complaint asserts infringement of one or more claims of the ʼ002 Patent (Compl. ¶186). Independent claim 1 is representative:
    • An interactive computer-controlled display system comprising:
    • a processor, a data display screen, and a cursor control device.
    • window generation and control logic to generate and display a "first window region having a plurality of display areas."
    • The first window region is "independently displayed and independently active of any application program."
    • The window is implemented in a "window layer that appears on top of application programming windows."
    • indicia generation logic to generate information for display within the display areas, with at least one area being "sensitive to user input."
    • The logic uses "message-based communication to exchange information to coordinate activities."
  • The complaint reserves the right to assert other claims.

U.S. Patent No. 7,469,381 - "List Scrolling and Document Translation, Scaling, and Rotation on a Touch-Screen Display," Issued Jan. 22, 2008

The Invention Explained

  • Problem Addressed: The patent background notes that on portable electronic devices with small touch screens, "frequently only a portion of a list or of an electronic document of interest to a user can be displayed on the screen at a given time" (ʼ381 Patent, col. 2:15-19). This necessitates scrolling and translating documents, which can be "awkward to perform" with conventional user interfaces (ʼ381 Patent, col. 2:23-28).
  • The Patented Solution: The invention describes a method for translating an electronic document on a touch-screen display in response to user finger movement. A key aspect is the behavior when a user scrolls to the edge of a document: if an edge is reached while the user's finger is still moving on the screen, "an area beyond the edge of the document is displayed" (ʼ381 Patent, Abstract; Fig. 5). After the finger is lifted, the document is translated in a second, opposite direction "until the area beyond the edge of the document is no longer displayed," creating a "bounce-back" or "rubber-banding" effect (ʼ381 Patent, Abstract; Fig. 5).
  • Technical Importance: This user interface behavior provides a clear, intuitive visual cue that the user has reached the end of a list or document, improving usability on touch-screen devices where traditional scrollbars are often absent.

Key Claims at a Glance

  • The complaint asserts infringement of one or more claims of the ʼ381 Patent (Compl. ¶192). Independent claim 1 is representative:
    • A computer-implemented method comprising:
    • displaying a portion of an electronic document.
    • detecting movement of an object on the touch screen display.
    • translating the electronic document in a first direction.
    • if an edge of the document is reached while the object is still detected, displaying an area beyond the edge of the document.
    • after the object is no longer detected, translating the document in a second direction until the area beyond the edge is no longer displayed.
  • The complaint reserves the right to assert other claims.

Multi-Patent Capsule: U.S. Patent No. 7,663,607 ("Multipoint Touchscreen")

  • Patent Identification: U.S. Patent No. 7,663,607, "Multipoint Touchscreen," Issued Feb. 16, 2010.
  • Technology Synopsis: The patent addresses the problem of conventional touchscreens being able to report only a single point of contact, making them unable to track multiple fingers simultaneously (Compl. ¶¶ 13, 27; ’607 Patent, col. 1:59-63). The invention discloses a touch panel with a transparent capacitive sensing medium configured to detect multiple, simultaneous touches at distinct locations and produce distinct signals for each touch (ʼ607 Patent, Abstract).
  • Asserted Claims: One or more claims (Compl. ¶198).
  • Accused Features: The complaint alleges that Samsung's accused products incorporate Apple's "Multi-Touch™ user interface" technology (Compl. ¶13) and that the accused products infringe the ’607 Patent (Compl. ¶198).

Multi-Patent Capsule: U.S. Design Patent No. D593,087 ("Electronic Device")

  • Patent Identification: U.S. Design Patent No. D593,087, "Electronic Device," Issued May 26, 2009.
  • Technology Synopsis: This design patent claims the ornamental design for an electronic device, characterized by a rectangular shape with rounded corners, a flat front face with a surrounding bezel, and specific proportions and placement of a display screen and speaker slot.
  • Asserted Claims: The single claim covering the ornamental design as shown in the figures (Compl. ¶264).
  • Accused Features: The complaint alleges that the design of Samsung's Galaxy S 4G phone misappropriates the patented design of the 'D087 patent (Compl. ¶94). The complaint provides a side-by-side visual comparison showing the patented design figure next to a photograph of the accused Samsung Galaxy S 4G phone (Compl. p. 30).

III. The Accused Instrumentality

  • Product Identification: The accused products include a wide range of Samsung's smartphones and tablets, primarily from the "Galaxy" line (Compl. ¶92). Specific models named include the Acclaim, Captivate, Continuum, Droid Charge, Epic 4G, Fascinate, Galaxy S (i9000), Galaxy S 4G, Vibrant, Galaxy Tab, and Galaxy Tab 10.1, among others (Compl. ¶92).
  • Functionality and Market Context: The complaint alleges that these products were designed to "slavishly copy Apple's innovative technology, distinctive user interfaces, and elegant and distinctive product and packaging design" (Compl. ¶8). The accused functionality is not a single feature, but rather the entire "look and feel" of the products. This includes physical characteristics such as a "rectangular product with four evenly rounded corners, a flat clear face covering the front of the product, a large display screen under the clear surface, [and] substantial black borders," as well as user interface elements like "a matrix of colorful square icons with evenly rounded corners, and a bottom dock" (Compl. ¶¶ 81, 96). The complaint includes a side-by-side comparison of an Apple iPhone 3GS and a Samsung Galaxy S i9000 to illustrate the alleged copying of the overall product appearance and user interface layout (Compl. p. 33). The complaint positions these products as direct competitors that capitalize on Apple's success by imitating its products (Compl. ¶¶ 3-4, 8-9).

IV. Analysis of Infringement Allegations

The complaint makes general allegations of infringement for each patent-in-suit but does not provide specific factual allegations or a claim chart mapping individual claim elements to accused functionalities. The infringement counts consist of boilerplate language stating that Samsung has infringed "one or more claims" of the respective patent through its making, using, selling, or importing of the accused products (Compl. ¶¶ 186, 192). The complaint's substantive infringement theory is presented through narrative descriptions of copying and side-by-side photographic comparisons rather than technical claim charts (Compl. ¶¶ 79-90, 94-103). For example, the complaint includes a visual comparison between design patent figures and the Samsung Galaxy S i9000's user interface, highlighting similarities in the grid of icons and the bottom dock (Compl. p. 31). Therefore, a detailed claim chart summary cannot be constructed from the complaint.

  • Identified Points of Contention:
    • Scope Questions: For the ’002 Patent, a central question may be whether the user interfaces in Samsung's Android-based products contain a "control strip" or an equivalent "independently displayed and independently active" window region that appears "on top of application programming windows" as the claim requires.
    • Technical Questions: For the ’381 Patent, a key technical question will be whether the scrolling mechanism in the accused Samsung products performs the specific functions required by the claims. The analysis will focus on whether the accused products, when a user scrolls to the end of a list, "display[] an area beyond the edge of the electronic document" and subsequently translate the document in the opposite direction to remove that area from view, as claimed.

V. Key Claim Terms for Construction

  • For U.S. Patent No. 6,493,002:

    • The Term: "control strip" (recited in the specification and representative of the "first window region" in claim 1).
    • Context and Importance: The definition of this term is central to determining infringement. The patent describes this as a window in a private layer that is always visible on top of other applications. Practitioners may focus on whether this term is limited to the specific dock-like bar shown in the patent's figures or can be construed more broadly to cover other types of persistent UI elements, such as a notification bar in the accused Android operating system.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the invention as a "control and/or status window for display on the desktop" that contains various modules, suggesting the form is not as important as the function of providing persistent access to controls (ʼ002 Patent, col. 5:60-63).
      • Evidence for a Narrower Interpretation: The figures consistently depict the "control strip" as a discrete, user-movable, horizontal bar at the bottom of the screen (ʼ002 Patent, Figs. 2A, 2B). The detailed description focuses on this embodiment, describing its "drag/size tab" and scroll arrows, which may suggest a narrower construction limited to that specific implementation (ʼ002 Patent, col. 7:1-26).

  • For U.S. Patent No. 7,469,381:

    • The Term: "displaying an area beyond the edge of the electronic document".
    • Context and Importance: This term describes the "rubber-banding" or "bounce-back" visual effect. The infringement analysis will depend on whether this claim language is construed to cover any visual indication of reaching a boundary, or if it requires a specific technical implementation where a literal "area beyond" the document's content is rendered and displayed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's summary describes the invention in functional terms, suggesting the key is providing a visual cue to the user (ʼ381 Patent, col. 4:10-15). The purpose is to make the interface more transparent and intuitive, which could support reading the claim on various technical implementations that achieve the same user-facing effect.
      • Evidence for a Narrower Interpretation: The detailed description states that this "area beyond the terminus of the list" can be displayed "in white" or as "visually indistinct from the background of the list" (ʼ381 Patent, col. 23:35-38, Fig. 5). This specific description of how the "area" is rendered might be used to argue for a narrower construction that does not cover alternative visual effects for reaching a boundary.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement for the patent counts.
  • Willful Infringement: For each asserted patent, the complaint alleges that Samsung's infringement "has been and continues to be intentional, willful, and without regard to Apple's rights" (Compl. ¶¶ 187, 193, 199). The basis for this allegation is pre-suit knowledge, grounded in the overarching narrative that Samsung engaged in a deliberate and "slavish" campaign to copy the "look and feel" of Apple's revolutionary products after their public launch (Compl. ¶¶ 8, 79-90).

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

  • A central issue will be one of holistic versus feature-specific infringement: The complaint's strength lies in its narrative and visual evidence of wholesale "look and feel" copying. A key question is whether Apple can successfully map this broad allegation of copying onto the specific, technical limitations of its individual utility patent claims, or if the case will ultimately turn more on the less technical trade dress and design patent claims.
  • A key evidentiary question will be one of functional operation: For patents like the '381 "bounce-back" patent, the case may turn on evidence of how the accused Samsung software actually operates. Does it perform the specific method steps recited in the claims (e.g., rendering an "area beyond" the document), or does it achieve a similar visual effect through a different, non-infringing technical method?
  • A significant legal and factual question will be willfulness: The complaint is replete with allegations of intentional, blatant, and "slavish" copying. A core question for the fact-finder will be whether Samsung's conduct, if found to be infringing, was egregious enough to support a finding of willful infringement, which could lead to an award of enhanced damages.