DCT

5:12-cv-00630

Apple Inc v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:12-cv-00630, N.D. Cal., 08/31/2012
  • Venue Allegations: Venue is alleged to be proper in the Northern District of California because Samsung transacts business and sells the accused products within the district, and because Apple’s principal place of business is located there, where it has suffered harm.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, media players, and tablet computers infringe eight utility patents related to graphical user interfaces, data synchronization, and other mobile device functionalities.
  • Technical Context: The dispute centers on foundational user interface and system-level technologies for smartphones and tablets, a market of significant commercial importance and intense competition during the period.
  • Key Procedural History: The complaint was filed while a previous patent infringement lawsuit between the same parties, designated the "Earlier Case," was pending in the same court. This history may be relevant to allegations of willful infringement, as it suggests Defendant was on notice of Plaintiff's intellectual property portfolio and its enforcement posture.

Case Timeline

Date Event
1995-08-07 ’502 Patent Priority Date
1996-02-01 ’647 Patent Priority Date
1997-09-09 U.S. Patent No. 5,666,502 Issues
1999-08-31 U.S. Patent No. 5,946,647 Issues
2000-01-05 ’959 Patent Priority Date
2004-12-01 ’604 Patent Priority Date
2005-01-25 U.S. Patent No. 6,847,959 Issues
2005-12-23 ’721 Patent Priority Date
2006-09-06 ’760 Patent Priority Date
2007-01-05 ’172 Patent Priority Date
2007-01-07 ’414 Patent Priority Date
2010-07-20 U.S. Patent No. 7,761,414 Issues
2011-04-01 "Earlier Case" filed (approximate date)
2011-08-01 Launch period for certain accused Samsung products begins (approximate date)
2011-09-06 U.S. Patent No. 8,014,760 Issues
2011-10-25 U.S. Patent No. 8,046,721 Issues
2011-12-06 U.S. Patent No. 8,074,172 Issues
2011-12-27 U.S. Patent No. 8,086,604 Issues
2012-07-30 "Earlier Case" set for trial
2012-08-31 Complaint Filing Date

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

U.S. Patent No. 5,946,647 - "System and method for performing an action on a structure in computer-generated data"

The Invention Explained

  • Problem Addressed: The patent describes the process of manually identifying structured data (e.g., a phone number, an address) within a document and then separately initiating an action related to it (e.g., dialing the number, mapping the address) as "laborious and cognitively disruptive" for a user (’647 Patent, col. 1:21-23, col. 2:50-52).
  • The Patented Solution: The invention proposes a system comprising an "analyzer server" that automatically detects recognizable structures within computer data using pattern analysis, links one or more relevant actions to the detected structure, and presents those actions to the user. An "action processor" then executes the user-selected action on the structure (’647 Patent, Abstract, Fig. 2). This automates the process of acting on recognized data.
  • Technical Importance: This technology streamlines user workflow by programmatically linking data recognition with data utilization, a key concept for enhancing usability in operating systems and applications.

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’647 Patent (Compl. ¶19). Independent claim 1 is representative:
    • A computer-based system for detecting structures in data and performing actions on detected structures, comprising:
      • an input device for receiving data;
      • an output device for presenting the data;
      • a memory storing program routines including an analyzer server, a user interface, and an action processor;
      • a processing unit for executing the program routines.
  • The complaint does not explicitly reserve the right to assert dependent claims but does so implicitly through its broad allegations.

U.S. Patent No. 6,847,959 - "Universal interface for retrieval of information in a computer system"

The Invention Explained

  • Problem Addressed: The patent identifies the inefficiency of using separate and distinct interfaces to search for information across different locations, such as local storage media and the internet. It notes that this fragmentation is cumbersome and that search results are often "too broad," requiring the user to sift through extensive lists (’959 Patent, col. 1:16-56).
  • The Patented Solution: The invention discloses a "universal" or "unitary" interface that accepts a single user query. This query is processed by a plurality of "heuristic algorithms," each tailored to a specific location (e.g., local files, internet). The system then locates and displays a consolidated list of "candidate items of information" for user selection, aiming to provide only the most relevant results (’959 Patent, Abstract, col. 2:16-27, Fig. 5).
  • Technical Importance: The technology consolidates disparate search functions into a single user-facing tool, aiming to simplify information retrieval and improve the relevance of results in an increasingly networked computing environment.

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’959 Patent (Compl. ¶25). Independent claim 1 is representative:
    • A method for locating information in a computer system, comprising the steps of:
      • inputting an information identifier;
      • providing the identifier to a plurality of plug-in modules, each using a different heuristic to locate matching information;
      • providing at least one candidate item of information from the modules;
      • displaying a representation of the candidate item.
  • The complaint implicitly reserves the right to assert dependent claims.

U.S. Patent No. 8,046,721 - "Unlocking a device by performing gestures on an unlock image"

  • Patent Identification: 8,046,721, "Unlocking a device by performing gestures on an unlock image," Issued October 25, 2011.
  • Technology Synopsis: The patent addresses unlocking a device with a touch-sensitive display. The invention describes displaying an "unlock image" and requiring a user to perform a predefined gesture with respect to that image (e.g., moving the image along a path) to transition the device from a locked to an unlocked state (Compl. ¶12; ’721 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶31).
  • Accused Features: The complaint alleges that Samsung's smartphones, media players, and tablets infringe, suggesting the accused feature is the screen-unlocking mechanism on those devices (Compl. ¶¶16, 31).

U.S. Patent No. 8,074,172 - "Method, system, and graphical user interface for providing word recommendations"

  • Patent Identification: 8,074,172, "Method, system, and graphical user interface for providing word recommendations," Issued December 6, 2011.
  • Technology Synopsis: This patent relates to text input on a portable electronic device. The invention describes a graphical user interface that displays a current character string being typed and, in a separate area, a suggested replacement word. The user can accept the suggestion by activating a delimiter key (e.g., space bar) or performing a gesture on the suggested word (Compl. ¶12; ’172 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶37).
  • Accused Features: The infringement allegation targets the auto-correction or word recommendation functionality within the text input systems of Samsung's accused devices (Compl. ¶¶16, 37).

U.S. Patent No. 8,014,760 - "Missed telephone call management for a portable multifunction device"

  • Patent Identification: 8,014,760, "Missed telephone call management for a portable multifunction device," Issued September 6, 2011.
  • Technology Synopsis: The patent describes a user interface for managing missed telephone calls. Upon user selection of a missed call item, the interface displays contact information for the caller, including multiple "contact objects" (e.g., a second phone number, an email address), allowing the user to initiate a return communication via a different modality (Compl. ¶12; ’760 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶43).
  • Accused Features: The accused functionality is the missed call notification and management interface on Samsung's smartphones (Compl. ¶¶16, 43).

U.S. Patent No. 5,666,502 - "Graphical user interface using historical lists with field classes"

  • Patent Identification: 5,666,502, "Graphical user interface using historical lists with field classes," Issued September 9, 1997.
  • Technology Synopsis: The technology concerns a data input technique where a user is presented with a "historical list" of the most recently or frequently used data values for a particular data field. This allows the user to select from the short list rather than re-typing the information, and the patent describes sharing these historical lists between different applications (Compl. ¶12; ’502 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶49).
  • Accused Features: The complaint targets data input fields in Samsung's devices that may suggest previously entered data to the user (Compl. ¶¶16, 49).

U.S. Patent No. 7,761,414 - "Asynchronous data synchronization amongst devices"

  • Patent Identification: 7,761,414, "Asynchronous data synchronization amongst devices," Issued July 20, 2010.
  • Technology Synopsis: The patent describes a method for synchronizing data between two devices (e.g., a handheld computer and a desktop computer) while allowing other non-synchronization applications to continue running concurrently. The system uses processing threads to manage synchronization and user-level tasks simultaneously, potentially locking a database for synchronization while allowing user access to other functions (Compl. ¶12; ’414 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶55).
  • Accused Features: The infringement allegations target the underlying data synchronization systems in Samsung's devices that allow them to sync with other computers (Compl. ¶¶16, 55).

U.S. Patent No. 8,086,604 - "Universal interface for retrieval of information in a computer system"

  • Patent Identification: 8,086,604, "Universal interface for retrieval of information in a computer system," Issued December 27, 2011.
  • Technology Synopsis: This patent is related to the ’959 Patent and further describes a universal interface for retrieving information. It discloses using a plurality of heuristic algorithms, or plug-ins, to search various locations and present consolidated results to the user through a single interface (Compl. ¶12; ’604 Patent, Abstract).
  • Asserted Claims: "one or more claims" (Compl. ¶61).
  • Accused Features: The complaint targets the search functionality on Samsung's devices that aggregates results from multiple sources (e.g., local device search, web search) (Compl. ¶¶16, 61).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies at least 21 smartphones, media players, and tablets, including the Galaxy S III, Galaxy Note, Galaxy S II Skyrocket, Galaxy Nexus, and Galaxy Tab series of devices (Compl. ¶¶1, 16).

Functionality and Market Context

  • The complaint alleges that the accused products incorporate "unique functionality" that is the result of Apple's innovation (Compl. ¶17). These products are described as smartphones, media players, and tablets with which Samsung has "deluged markets with infringing devices in an effort to usurp market share from Apple" (Compl. ¶2). The complaint does not provide specific technical descriptions of how the accused products operate, focusing instead on allegations that Samsung has "systematically copied Apple's innovative technology and products, features, and designs" (Compl. ¶2). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a claim-chart analysis of any asserted patent. The infringement allegations are pleaded at a high level, asserting that one or more claims of each patent are infringed by the listed Samsung products without mapping specific product features to claim elements (e.g., Compl. ¶¶19, 25, 31).

’647 Patent Infringement Allegations

  • Identified Points of Contention:
    • Scope Questions: Claim 1 requires an "analyzer server" for detecting "structures" in data. A primary point of contention may be whether the accused Samsung software contains a component that meets the specific definition of an "analyzer server" as contemplated by the patent, or whether its functionality for acting on data (e.g., recognizing a phone number) is implemented in a fundamentally different architecture.
    • Technical Questions: A key evidentiary question will be whether the accused products perform "pattern analysis" to detect structures and then "link" actions in the manner claimed (’647 Patent, col. 2:25-34). The complaint provides no facts to suggest how this is accomplished, raising the question of whether the accused functionality is a purpose-built system as described in the patent or a more general feature that operates differently.

’959 Patent Infringement Allegations

  • Identified Points of Contention:
    • Scope Questions: Claim 1 recites a method using a "plurality of plug-in modules each using a different heuristic." The dispute may center on whether Samsung's unified search architecture, if any, can be characterized as using distinct "plug-in modules" with different "heuristics," or if it uses a monolithic search algorithm that falls outside the claim scope.
    • Technical Questions: The complaint lacks any allegation describing the architecture of the search function in the accused products. A central question for the court will be whether discovery reveals an architecture that corresponds to the claimed method of providing an identifier to multiple, distinct heuristic modules for processing.

V. Key Claim Terms for Construction

The Term: "analyzer server" (’647 Patent, Claim 1)

  • Context and Importance: This term is the central component of the system claimed in the ’647 Patent. The construction of this term will be critical to determining infringement, as its scope could either be limited to a specific software architecture or be broad enough to cover a wide range of data-parsing functionalities in modern operating systems.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the analyzer server as one of several "program subroutines," suggesting it is a software component rather than a physically distinct server (’647 Patent, col. 2:26-28).
    • Evidence for a Narrower Interpretation: The figures depict the "Analyzer Server" as a distinct block separate from other components like the "Application Program Interface," which could support an argument that the term requires a more architecturally discrete module that provides a service to other parts of the system (’647 Patent, Fig. 2).

The Term: "heuristic" (’959 Patent, Claim 1)

  • Context and Importance: The use of a "plurality of ... heuristics" is a core limitation of the claimed universal search method. Its definition will determine whether the claim applies only to systems with distinct, rule-based search algorithms for different data sources or more broadly to any system that combines search results from multiple locations.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent uses the term in the context of different search strategies, such as matching a descriptor with file names, file content, or a history of recently accessed information, suggesting "heuristic" refers to a general approach to searching a particular data set (’959 Patent, col. 5:14-23).
    • Evidence for a Narrower Interpretation: The patent consistently associates heuristics with distinct "plug-in modules" that can be selectively provided with the user input (’959 Patent, col. 6:10-14, claim 1). This may support a narrower construction requiring a specific, modular software architecture where each heuristic is embodied in its own plug-in.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges contributory and/or induced infringement without pleading specific supporting facts, such as the provision of user manuals or instructions that would encourage infringing acts (e.g., Compl. ¶¶19, 25).
  • Willful Infringement: The complaint alleges that Samsung’s infringement of each patent has been willful, basing this allegation on Samsung's "knowledge of the [asserted] patent through direct or indirect communications with Apple and/or as a result of its participation in the personal computing devices industry" (e.g., Compl. ¶¶20, 26). The complaint's reference to the "Earlier Case" provides a factual basis for alleging that Samsung had pre-suit knowledge of Apple's patent portfolio and its propensity to enforce it (Compl. ¶3).

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

  • A core issue will be one of definitional scope: The complaint's lack of factual detail places significant weight on claim construction. The viability of the infringement claims will heavily depend on whether key terms such as "analyzer server" (’647 Patent) and "plurality of plug-in modules" (’959 Patent) are construed broadly enough to cover the accused functionalities in Samsung's products.
  • A key evidentiary question will be one of architectural correspondence: Given the conclusory nature of the infringement allegations, the case will likely turn on whether discovery produces evidence that the software architecture of the accused Samsung features matches the specific systems and methods described and claimed in Apple's patents, or if Samsung achieved similar user-facing results through fundamentally different technical means.