DCT

1:19-cv-01103

Princeps Interface Tech LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-01103, D. Del., 06/14/2019
  • Venue Allegations: Venue is alleged against the foreign parent (Samsung Electronics Co., Ltd.) based on sales into the district. Venue is alleged against U.S. subsidiaries based on corporate residence (Samsung Austin Semiconductor, a Delaware LLC), a regular and established place of business within the district (Samsung Electronics America, via a "Store within a Store" at a Best Buy), or as a consequence of venue being proper over closely related co-defendants (Samsung Semiconductor).
  • Core Dispute: Plaintiff alleges that Samsung’s mobile devices, including the Galaxy S series, which feature software-based keyboards within the Android operating system and various applications, infringe a patent related to multifunctional input devices.
  • Technical Context: The technology addresses the challenge of designing efficient, versatile keyboards for miniaturized electronic devices, aiming to provide more functionality than simple keypads without the physical size of a traditional QWERTY keyboard.
  • Key Procedural History: The complaint notes that the asserted patent claims priority to a provisional application filed in September 2001, positioning the invention in the early era of portable digital devices preceding the modern smartphone.

Case Timeline

Date Event
2001-09-20 Priority Date for U.S. Patent No. 6,703,963
2004-03-09 Issue Date for U.S. Patent No. 6,703,963
2019-06-14 Complaint Filing Date

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

U.S. Patent No. 6,703,963 - "Universal Keyboard", issued March 9, 2004

The Invention Explained

  • Problem Addressed: The patent identifies several drawbacks of using traditional QWERTY keyboards with the increasingly small and portable electronic devices of the time. These keyboards are described as too large for single-handed use, inefficient in key layout, and typically limited to a single function (alphanumeric input), while alternatives like 12-key phone pads are slow for data entry (’963 Patent, col. 1:37-2:32; Compl. ¶28).
  • The Patented Solution: The invention is a "multifunctional input device" that uses a limited number of programmable physical keys whose functions can be changed based on a selected context. The system has two main layers of control: a "functional mode" (e.g., alphanumeric, telephone, calculator) and, within that mode, a "domain level" (e.g., letters "A-L," "M-X," or punctuation symbols). A display associated with each key visually indicates its current value or function, allowing a small physical device to manage a wide range of inputs (’963 Patent, Abstract; col. 4:20-41).
  • Technical Importance: The invention proposed a method to maximize the versatility and efficiency of data entry on small-profile devices, a key challenge in the design of PDAs and early mobile electronics (Compl. ¶27, ¶31).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 60, along with dependent claims 2, 3, 9, and 12 (Compl. ¶39).
  • Independent Claim 1 (an apparatus claim) requires:
    • A functional mode control for selecting a functional mode of operation.
    • A domain control for selecting a domain level within the functional mode.
    • A plurality of input keys, separate and distinct from the domain control.
    • A function-specific display indicating a domain-level value associated with each input key.
    • A configuration wherein the input keys and domain control are simultaneously presented.
  • The complaint reserves the right to assert additional claims (Compl. ¶49).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Samsung phones with proprietary Samsung Apps and/or third-party Apps with keyboard functionalities and an operating system such as the Android operating system" (Compl. ¶39). The complaint specifically names the "Samsung Galaxy S series devices" (Compl. ¶45).

Functionality and Market Context

The complaint targets the software-based keyboard interfaces on Samsung's mobile devices (Compl. ¶45). The relevant functionality is the on-screen keyboard that allows users to input text and symbols, including the ability to switch between different keyboard layouts (e.g., letters, numbers, special characters) (Compl. ¶39). The complaint alleges these devices are part of a massive commercial operation, with Samsung's revenues cited at approximately $221 billion per year (Compl. ¶46).

IV. Analysis of Infringement Allegations

The complaint references a claim chart exhibit (Exhibit A-1) that was not filed with the public document; therefore, the infringement allegations are summarized below in prose and table format based on the narrative in the complaint. The central theory is that the on-screen keyboards in Samsung's mobile devices practice the patented method of modal input.
No probative visual evidence provided in complaint.

’963 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a functional mode control for selecting a first functional mode of operation of multiple functional modes of operation by the input device The user's selection of different software keyboard layouts, such as switching between an alphabetic keyboard and a numeric or symbolic keyboard, is alleged to constitute selecting a functional mode (Compl. ¶39). ¶39 col. 4:1-19
a domain control for selecting one of multiple domain levels within the first functional mode wherein each domain level is associated with a set of domain-level values The complaint does not specify which feature constitutes the "domain control," but it would likely refer to a secondary level of selection, such as accessing a second page of symbols or long-pressing a key to select an alternate character (Compl. ¶39). ¶39 col. 4:20-24
a plurality of input keys, separate and distinct from the domain control, assigned to the set of domain-level values... The individual on-screen keys (e.g., 'A', 'B', 'C') displayed on the device's touchscreen are alleged to be the "plurality of input keys" (Compl. ¶39, ¶45). ¶39 col. 4:25-30
a function-specific display indicating a domain-level value associated with each input key for a currently selected functional mode and domain level combination The device's main screen, which displays the characters on the virtual keys, is alleged to be the "function-specific display" (Compl. ¶39). ¶39 col. 5:23-38
wherein the input keys and domain control are simultaneously presented by the input device The on-screen keyboard is alleged to simultaneously show the character keys and the controls for switching modes (e.g., "?123" key) (Compl. ¶39). ¶39 col. 4:45-54

Identified Points of Contention

  • Scope Questions: A primary issue may be whether the claim term "information input device", which the patent specification describes and illustrates exclusively as a physical hardware device with discrete buttons, can be construed to cover a software-based keyboard rendered on a general-purpose touchscreen. The construction of "input keys" will be central to this dispute.
  • Technical Questions: The infringement analysis raises the question of whether the accused Samsung keyboards possess two distinct controls that map to the claimed "functional mode control" and "domain control". A court may need to determine if the accused products use a single, multi-purpose mode-switching control, which might not meet the claim's requirement for separate and distinct controls.
  • Technical Questions: What evidence will support the allegation that a single, unified touchscreen meets the limitation of "a function-specific display indicating a domain-level value associated with each input key"? The patent specification consistently depicts distinct, individual displays for each key (e.g., '963 Patent, Fig. 5a, element 32), which may suggest a structural difference from the accused products.

V. Key Claim Terms for Construction

"domain control"

  • Context and Importance: The viability of the infringement claim may depend on identifying a feature in the accused products that constitutes a "domain control" that is "separate and distinct" from the "functional mode control." Practitioners may focus on this term because the defense could argue the accused keyboards either lack this element or combine its function into a single mode-switch button, thereby avoiding infringement of Claim 1.
  • Intrinsic Evidence for a Broader Interpretation: The claim requires a "control for selecting," which could be argued to encompass any user interface element, including a soft key or a long-press gesture, that allows selection of a character subset (’963 Patent, col. 13:34-37).
  • Intrinsic Evidence for a Narrower Interpretation: The patent’s preferred embodiments consistently show the "domain control" as a set of physical buttons (20) that are structurally separate from the functional mode buttons (10) (’963 Patent, Fig. 5a). This could support a narrower construction requiring a physically or logically distinct control element.

"a function-specific display indicating a domain-level value associated with each input key"

  • Context and Importance: This term is critical because the patent’s figures show discrete, individual displays located on or next to each physical key. The accused products, by contrast, use a single, large touchscreen to display all keys. The dispute will center on whether a single, shared display surface can be "associated with each input key" in the manner claimed.
  • Intrinsic Evidence for a Broader Interpretation: The claim recites "a" display, in the singular, not "a plurality of displays." Plaintiff may argue that as long as a visual indication is provided for each key, a single screen that accomplishes this for all keys meets the limitation (’963 Patent, col. 14:45-49).
  • Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly describes the one-to-one relationship: "Associated with each input key 30 is a display 32" (’963 Patent, col. 5:23-24). The consistent illustration of separate displays (e.g., Fig. 1, element 32) for each key (30) could be used to argue that the invention requires this distributed display architecture, not a monolithic one.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Samsung provides "instructional materials and/or services" that encourage and instruct customers to use the accused keyboard functionalities, thereby causing direct infringement by end-users (Compl. ¶43-44).

Willful Infringement

Willfulness is alleged based on Samsung's continued infringement after being notified of the patent by the filing of the complaint itself (Compl. ¶47). The allegations are directed at post-suit conduct.

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

  • A core issue will be one of definitional scope: can the claims for an "information input device," which are described and depicted in the patent as a physical apparatus with discrete keys and displays, be construed to cover a purely software-based keyboard rendered on a general-purpose touchscreen?
  • A key question of claim construction and factual mapping will be whether the accused software keyboards implement two distinct levels of control that correspond to the patent's "functional mode control" and "domain control", or if their architecture is fundamentally different.
  • A central evidentiary question will be one of structural correspondence: does a single, unified touchscreen that displays multiple virtual keys satisfy the claim requirement for "a... display... associated with each input key," when the patent specification consistently illustrates a one-to-one pairing of a key with its own display?