DCT

1:18-cv-00850

Satius Holding LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:18-cv-00850, D. Del., 06/05/2018
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant conducts continuous business in the district, has infringed in the district, and has established minimum contacts.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile phones and tablets, which contain certain RF transceivers, infringe a patent related to signal couplers designed to improve wireless communication quality.
  • Technical Context: The technology addresses signal degradation in wireless devices caused by reflected signals, using a specialized coupler to match the device's impedance to that of the air.
  • Key Procedural History: The patent-in-suit was the subject of an ex parte reexamination requested in 2019. In April 2022, the U.S. Patent and Trademark Office issued a certificate confirming the patentability of the asserted claims (1, 11, and 18). The reexamination certificate notes that the patent remained subject to a second, separate reexamination proceeding filed in August 2021.

Case Timeline

Date Event
2000-07-06 U.S. Patent No. 6,711,385 Priority Date
2004-03-23 U.S. Patent No. 6,711,385 Issued
2008-01-04 ’385 Patent assigned from Satius, Inc. to Satius Holding, Inc.
2018-06-05 Complaint Filed
2019-09-19 Ex parte reexamination of ’385 Patent requested (No. 90/014,378)
2021-08-11 Second ex parte reexamination of ’385 Patent requested (No. 90/014,826)
2022-04-29 Reexamination Certificate confirms patentability of claims 1, 11, 18

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

U.S. Patent No. 6,711,385 - "COUPLER FOR WIRELESS COMMUNICATIONS"

  • Issued: March 23, 2004

The Invention Explained

  • Problem Addressed: The patent describes a well-known problem where wireless signals reflect off objects like buildings, creating "notches" in the communication bandwidth that degrade signal quality and can prevent communication altogether (’385 Patent, col. 1:11-21).
  • The Patented Solution: The invention proposes a hardware solution: a "coupler" that sits between the device's transmitter/receiver and the antenna. This coupler contains a special "non-magnetic core" transformer designed to match the impedance of the device's electronics to the characteristic impedance of the air. By creating this impedance match at a specific frequency, the coupler is said to eliminate the detrimental notches, enabling more reliable, high-speed communication (’385 Patent, Abstract; col. 3:3-10). The patent discloses various physical implementations, including coaxial coils (FIG. 2) and layered plates on a chip (’385 Patent, col. 4:50-54).
  • Technical Importance: By addressing signal integrity at the physical layer, the technology purports to achieve wide linear bandwidth communication, allowing for data rates of up to "several Gbps" (’385 Patent, col. 3:39-43).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 11 and 18 (’385 Patent, col. 5:31-42; col. 7:7-14; col. 7:17-21).
  • Independent Claim 1 recites:
    • A communications apparatus for transmitting electric or electromagnetic signals over air, the air having a characteristic impedance, the communications apparatus comprising:
    • a transmitter having an output impedance, said transmitter for transmitting the electric or electromagnetic signals at a preselected frequency; and
    • a coupler connected to the transmitter, said coupler comprising a transformer having a non-magnetic core, said transformer communicating the electric or electromagnetic signals to the air, said coupler matching the output impedance of the transmitter to the characteristic impedance of the air.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a wide range of "Samsung Phones" (e.g., Galaxy S9, S8, S7 series, Note series) and "Samsung Tablets" (e.g., Galaxy Tab S3, Tab A) (Compl. ¶12). The allegations focus on specific internal components, including the Samsung Shannon series (e.g., 965, 955) and Qualcomm SDR845 RF transceivers (Compl. ¶13, ¶15-17).

Functionality and Market Context

  • The accused products are mobile communication devices. The complaint alleges that they achieve consistent call quality through the use of an "air-core or dielectric core coupler" that eliminates noise by matching impedance (Compl. ¶14). The infringement allegations center on RF transceivers and associated components like the Qualcomm QAT3550 impedance tuner, which are alleged to perform this impedance-matching function (Compl. ¶17). The complaint provides die photographs of the accused Samsung Shannon 965 RF Transceiver, identifying it as a component inside the Galaxy S9+ smartphone (Compl. p. 6, Ex. 4).

IV. Analysis of Infringement Allegations

’385 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A communications apparatus for transmitting electric or electromagnetic signals over air, the air having a characteristic impedance... The accused Samsung Phones and Tablets are identified as communications apparatuses that transmit cellular signals over the air (Compl. ¶26). A layout diagram of the Samsung Galaxy S9+ is provided to show the location of the "Main antenna" (Compl. p. 13, Ex. 8). ¶26, ¶27 col. 5:31-34
a transmitter having an output impedance, said transmitter for transmitting the electric or electromagnetic signals at a preselected frequency... The complaint identifies the Samsung Shannon 965 and Qualcomm SDR845 RF transceivers as the claimed "transmitter" that operates at a specific output impedance to transmit signals at a preselected frequency (Compl. ¶29). A system-level block diagram illustrates the connection of the Shannon 965 transceiver to the main processor (Compl. p. 15, Ex. 7). ¶29 col. 5:35-37
a coupler connected to the transmitter, said coupler comprising a transformer having a non-magnetic core... The accused transceivers are alleged to include a "coupler having a dielectric (non-magnetic) core" or an "impedance matching circuit having a non-magnetic (e.g., ceramic or dielectric) core" (Compl. ¶15, ¶18, ¶30). The Qualcomm SDR845 is alleged to include a QAT3550 impedance tuner, which is identified as the claimed coupler (Compl. ¶17). ¶15, ¶17, ¶30 col. 5:38-40
said coupler matching the output impedance of the transmitter to the characteristic impedance of the air. The complaint alleges the accused couplers, such as the impedance tuner in the Qualcomm chipset, match the impedance of the transmitter to the air to achieve reliable cellular service (Compl. ¶15, ¶17, ¶30). The complaint includes a block diagram of Qualcomm's TruSignal architecture, which explicitly identifies "Impedance tuners" (Compl. p. 8, Ex. 5). ¶15, ¶17, ¶30 col. 5:40-42

Identified Points of Contention

  • Scope Questions: A central question for the court will be whether the terms "coupler" and "transformer", described in the patent with specific physical structures like coaxial coils or layered plates, can be construed to read on the highly integrated, solid-state impedance tuners and RF transceivers found in modern smartphones.
  • Technical Questions: The complaint alleges the function of impedance matching but provides limited detail on the specific structure and mechanism of the accused components. A key technical question will be whether the accused Samsung and Qualcomm components operate via the inductive and capacitive coupling of a "transformer" as described in the patent, or if they achieve impedance matching through a fundamentally different, non-infringing technology.

V. Key Claim Terms for Construction

The Term: "coupler"

  • Context and Importance: This term is the central element of the invention. The infringement analysis will depend entirely on whether the accused RF transceivers or their sub-components are found to be a "coupler" as claimed.
  • Intrinsic Evidence for a Broader Interpretation: The specification suggests broad applicability, stating "Any wireless transmitter or receiver 12 can be used with the present invention" (’385 Patent, col. 4:4-6). Plaintiff may argue the term should be defined functionally to cover any component that connects the transmitter to the air and performs the claimed matching function.
  • Intrinsic Evidence for a Narrower Interpretation: The patent repeatedly describes the coupler in terms of specific physical structures, such as "two coaxial solenoids or air-coils" (’385 Patent, col. 3:44-46) or "very thin conductive plates separated by chip material" (’385 Patent, col. 4:52-54). Defendant may argue that these specific embodiments limit the term to such structures and exclude modern, monolithic integrated circuits.

The Term: "transformer having a non-magnetic core"

  • Context and Importance: This term defines the essential component of the "coupler". The dispute will likely focus on whether the accused solid-state circuits constitute a "transformer" and if their material composition qualifies as a "non-magnetic core."
  • Intrinsic Evidence for a Broader Interpretation: The specification discloses that the transformer plates can be formed from "doped silicon" and that integrated circuits using "active transistors can simulate and/or create an aircore transformer" (’385 Patent, col. 5:4-9, 5:23-29). This language may support reading the claim on modern semiconductor devices. "Non-magnetic" broadly includes any material that is not ferromagnetic, such as silicon or dielectrics used in chips.
  • Intrinsic Evidence for a Narrower Interpretation: The primary embodiments illustrate structures with distinct primary and secondary windings or plates that are physically separate and rely on inductive coupling through an air or dielectric gap (’385 Patent, FIG. 2; col. 4:8-12). Defendant may argue that "transformer" requires this specific type of inductive coupling, which may not be the operating principle of the accused impedance tuners.

VI. Other Allegations

Willful Infringement

  • The complaint does not make an explicit allegation of willful infringement. However, it does request a finding that the case is "exceptional" and an award of attorneys' fees pursuant to 35 U.S.C. § 285 (Compl. p. 17).

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

  • A core issue will be one of technological translation: Can the term "coupler", which is rooted in the patent’s disclosure of discrete, wound-coil or layered-plate transformers, be construed to cover the highly integrated, solid-state impedance tuning circuits found in modern smartphone RF transceivers? The patentability of the asserted claims has been confirmed in reexamination, shifting the focus to the scope of the claim language as applied to accused technology that has evolved significantly since the patent was filed.
  • A key evidentiary question will be one of structural and functional correspondence: Beyond high-level functional descriptions, what is the precise electrical mechanism by which the accused Samsung and Qualcomm components operate? The case will likely turn on whether discovery reveals a structure that functions as a "transformer having a non-magnetic core" as described in the patent, or if the accused devices achieve impedance matching through a different, non-infringing technical approach.