DCT
1:21-cv-02665
Samsung Group v. Lyne Laboratories Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
- Defendant: Lynk Labs, Inc. (Illinois)
- Plaintiff’s Counsel: O'Melveny & Myers LLP; Honigman LLP
- Case Identification: 1:21-cv-02665, N.D. Ill., 09/08/2021
- Venue Allegations: Plaintiff Samsung alleges venue is proper in the Northern District of Illinois because Defendant Lynk Labs has its principal place of business in the District, is subject to personal jurisdiction, and a substantial part of the events giving rise to the claims occurred there.
- Core Dispute: Plaintiff Samsung seeks a declaratory judgment that its various electronic products do not infringe eleven patents owned by Defendant Lynk Labs related to AC light-emitting diode (LED) drive methods and apparatus.
- Technical Context: The technology at issue relates to methods for driving LEDs, which are inherently direct current (DC) devices, using alternating current (AC) power sources, a foundational technology in modern lighting and electronics.
- Key Procedural History: The complaint alleges that this declaratory judgment action arises from a series of communications initiated by Lynk Labs beginning in December 2019, in which Lynk accused a wide range of Samsung products of infringement and provided claim charts for at least seven of the patents-in-suit. The complaint also notes that Lynk Labs previously asserted related patents against other defendants in the same judicial district. Subsequent to the filing of this complaint, a number of the patents-in-suit have been the subject of Inter Partes Review (IPR) proceedings at the U.S. Patent and Trademark Office, resulting in the cancellation or disclaimer of numerous asserted claims.
Case Timeline
| Date | Event |
|---|---|
| 2004-02-25 | Earliest Patent Priority Date |
| 2018-12-11 | U.S. Patent 10,154,551 Issued |
| 2019-11-26 | U.S. Patent 10,492,251 Issued |
| 2019-11-26 | U.S. Patent 10,492,252 Issued |
| 2019-12-03 | U.S. Patent 10,499,466 Issued |
| 2019-12-04 | Samsung receives email from Lynk Labs' CEO |
| 2019-12-10 | U.S. Patent 10,506,674 Issued |
| 2019-12-24 | U.S. Patent 10,517,149 Issued |
| 2020-05-12 | U.S. Patent 10,652,979 Issued |
| 2020-05-14 | Samsung receives letter from Lynk's counsel |
| 2020-05-29 | Samsung receives letter with claim charts |
| 2020-06-16 | U.S. Patent 10,687,400 Issued |
| 2020-07-23 | Samsung receives letter alleging willfulness |
| 2020-08-18 | U.S. Patent 10,750,583 Issued |
| 2021-03-30 | U.S. Patent 10,966,298 Issued |
| 2021-05-25 | U.S. Patent 11,019,697 Issued |
| 2021-09-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,492,252 - "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued November 26, 2019
The Invention Explained
- Problem Addressed: The patent family addresses the technical challenge of powering Light Emitting Diodes (LEDs), which are intrinsically direct current (DC) devices, from an alternating current (AC) power source. Conventional methods often require bulky and inefficient transformers and rectifiers to convert AC to DC power (’251 Patent, col. 1:30-54).
- The Patented Solution: The technology proposes circuit configurations, such as connecting LEDs in an "opposing parallel" arrangement, which allows current to flow and produce light during both the positive and negative phases of an AC cycle (’251 Patent, col. 1:66-col. 2:2). This specific patent applies such AC LED principles to an apparatus with features for wireless charging, data reception, and proximity sensing (’252 Patent, Claim 1).
- Technical Importance: This approach aims to simplify driver circuitry for LEDs, which could reduce component count, size, and cost in electronic devices and lighting systems.
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement for claims 1-20 (Compl. ¶¶ 47-49). Independent claims 1, 7, 16, and 20 are asserted as representative (Compl. ¶42).
- Independent Claim 1 includes:
- An apparatus comprising: a flat planar substrate upon which is mounted a plurality of LEDs;
- a data receiver... from an antenna;
- a transmission conductor configured to wirelessly receive an alternating electromagnetic field that is used to provide power to charge the apparatus; and
- a proximity sensor.
- Independent Claim 20 includes:
- An apparatus comprising: a flat planar substrate... sufficiently flexible to be folded without breaking;
- a data receiver... from an antenna;
- a driver comprising an input of a first AC voltage... and a driver output of DC voltage.
U.S. Patent No. 10,499,466 - "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued December 3, 2019
The Invention Explained
- Problem Addressed: This patent addresses the same foundational problem of efficiently driving DC-native LEDs with AC power (’466 Patent, col. 1:24-51).
- The Patented Solution: The invention described in this patent integrates AC LED technology into an apparatus that includes features for wireless charging, data reception, and touch sensing. Specific claims also recite a "lens doped with particles," suggesting a focus on modifying the light output in combination with these other functions (’466 Patent, Claims 1, 3, 7).
- Technical Importance: This technology suggests a system for integrating power, data reception, and user interaction (touch) into a single, compact LED-based apparatus.
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement for claims 1-16 (Compl. ¶¶ 61-63). Independent claims 1, 3, 7, 9, and 11 are asserted as representative (Compl. ¶54).
- Independent Claim 1 includes:
- An apparatus comprising: at least one LED;
- a data receiver... from an antenna;
- a transmission conductor configured to wirelessly receive an alternating electromagnetic field that is used to provide power to charge the apparatus; and
- a second circuit configured to detect touch via capacitive sensing.
- Independent Claim 11 includes:
- An apparatus comprising: a plurality of LEDs;
- a data receiver configured to receive data signals...;
- a first circuit, wherein the first circuit is configured to receive DC power and data signals from a transmission conductor.
Multi-Patent Capsule: U.S. Patent No. 10,506,674
- Patent Identification: U.S. Patent No. 10,506,674, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued December 10, 2019 (Compl. ¶12).
- Technology Synopsis: This patent relates to a portable apparatus with an LED circuit and a power supply configured to increase power to the LED circuit upon detection of a touch. It also describes a switch for controlling power to the LED circuit (Compl. ¶¶ 69, 71, 73).
- Asserted Claims: Independent claims 1, 8, 12, and 20 are identified (Compl. ¶68).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused Galaxy Products and Accused TV Products (Compl. ¶67).
Multi-Patent Capsule: U.S. Patent No. 10,966,298
- Patent Identification: U.S. Patent No. 10,966,298, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued March 30, 2021 (Compl. ¶13).
- Technology Synopsis: This patent describes an apparatus with circuits configured to detect contact with a conductive substance via capacitive sensing to control an LED. It also includes claims directed to wireless power reception via an alternating electromagnetic field or radio frequency noise (Compl. ¶¶ 85, 91, 93).
- Asserted Claims: Independent claims 1, 6, 7, 9, 10, 13, 16, 17, 18, 21, and 22 are identified (Compl. ¶84).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused Galaxy Products and Accused TV Products (Compl. ¶83).
Multi-Patent Capsule: U.S. Patent No. 10,492,251
- Patent Identification: U.S. Patent No. 10,492,251, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued November 26, 2019 (Compl. ¶14).
- Technology Synopsis: This patent is directed to an LED lighting system or device comprising an "LED driver" and an "LED circuit" or "LED packages." A key feature appears to be an LED driver that receives an AC voltage input (Compl. ¶¶ 109, 111, 113).
- Asserted Claims: Independent claims 1, 8, 11, 13, 14, and 20 are identified (Compl. ¶108).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused SmartThings Products (Compl. ¶107).
Multi-Patent Capsule: U.S. Patent No. 10,750,583
- Patent Identification: U.S. Patent No. 10,750,583, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued August 18, 2020 (Compl. ¶15).
- Technology Synopsis: This patent relates to an LED lighting system or device comprising an "LED driver" and an "LED circuit" or "LED circuit array." The technology appears focused on the combination of these specific driver and circuit components (Compl. ¶¶ 123, 125, 127).
- Asserted Claims: Independent claims 1, 8, and 11 are identified (Compl. ¶122).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused SmartThings Products (Compl. ¶121).
Multi-Patent Capsule: U.S. Patent No. 10,687,400
- Patent Identification: U.S. Patent No. 10,687,400, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued June 16, 2020 (Compl. ¶16).
- Technology Synopsis: This patent describes a lighting system or device comprising an "LED circuit" in combination with either "a plurality of LEDs" or "at least two LEDs." The claims appear to require the physical presence of both the circuit and multiple LEDs (Compl. ¶¶ 137, 139, 141).
- Asserted Claims: Independent claims 1, 7, 14, and 21 are identified (Compl. ¶136).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused SmartThings Products (Compl. ¶135).
Multi-Patent Capsule: U.S. Patent No. 10,517,149
- Patent Identification: U.S. Patent No. 10,517,149, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued December 24, 2019 (Compl. ¶17).
- Technology Synopsis: This patent is directed to a lighting system that requires the combination of an "LED circuit," "a plurality of LEDs" (or "at least two LEDs"), and "a driver." The asserted claims require all three of these components to be present in the system (Compl. ¶¶ 151, 153).
- Asserted Claims: Independent claims 1, 5, 11, and 17 are identified (Compl. ¶150).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused SmartThings Products (Compl. ¶149).
Multi-Patent Capsule: U.S. Patent No. 11,019,697
- Patent Identification: U.S. Patent No. 11,019,697, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued May 25, 2021 (Compl. ¶18).
- Technology Synopsis: This patent describes an apparatus that includes a "semiconductor device configured to emit a laser." It also includes claims directed to a "transmission conductor configured to wirelessly receive... power and data from an alternating electromagnetic field" (Compl. ¶¶ 163, 165).
- Asserted Claims: Independent claims 1, 7, and 14 are identified (Compl. ¶162).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused Galaxy Products and Accused Charger Products (Compl. ¶161).
Multi-Patent Capsule: U.S. Patent No. 10,154,551
- Patent Identification: U.S. Patent No. 10,154,551, "AC Light Emitting Diode and AC LED Drive Methods and Apparatus," Issued December 11, 2018 (Compl. ¶19).
- Technology Synopsis: This patent is directed to LED driver circuitry. The asserted claims require a driver that provides "rectified AC voltage and current" to an LED circuit, with various claims specifying inputs from a bridge rectifier or mains power and outputs of different AC or DC waveforms (Compl. ¶¶ 175, 177, 179).
- Asserted Claims: Independent claims 1, 5, 10, 16, 22-29, 33, 34, 36, and 37 are identified (Compl. ¶174).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused ACOM Products (Compl. ¶173).
Multi-Patent Capsule: U.S. Patent No. 10,652,979
- Patent Identification: U.S. Patent No. 10,652,979, "LED Lighting System," Issued May 12, 2020 (Compl. ¶20).
- Technology Synopsis: This patent describes an "LED driver circuit" that comprises a bridge rectifier and capacitor. The circuit is configured to receive an AC voltage from a mains power source and provide a DC voltage output to LED packages (Compl. ¶¶ 207, 209).
- Asserted Claims: Independent claims 1, 7, and 13 are identified (Compl. ¶206).
- Accused Features: The complaint seeks a declaration of non-infringement for the Accused ACOM Products (Compl. ¶205).
III. The Accused Instrumentality
Product Identification
Plaintiff Samsung identifies five categories of accused products for which it seeks a declaratory judgment of non-infringement: (1) "Accused Galaxy Products," including Galaxy smartphones, tablets, and watches; (2) "Accused TV Products," including Samsung smart televisions; (3) "Accused Charger Products," including the Samsung Wireless Charger Duo; (4) "Accused SmartThings Products," including the SmartThings app and hub; and (5) "Accused ACOM Products," which are identified as Samsung ACOM LED Products (Compl. ¶7).
Functionality and Market Context
The complaint asserts that specific functionalities of these products do not meet various claim limitations of the patents-in-suit. For the Galaxy products, the relevant functionality involves wireless charging and the physical properties of their substrates (Compl. ¶¶ 44, 46). For the SmartThings and ACOM products, the dispute centers on whether they constitute "lighting systems" containing the specific "LED driver" and "LED circuit" combinations required by the claims (Compl. ¶¶ 110, 112, 124). The complaint does not provide details on the market context of the accused products beyond identifying them as designed and manufactured by Samsung. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
10,492,252 Infringement Allegations
| Claim Element (from Independent Claims 1, 20) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a transmission conductor configured to wirelessly receive an alternating electromagnetic field that is used to provide power to charge the apparatus | The transmission conductors of the Accused Galaxy Products do not wirelessly receive an alternating electromagnetic field for the purpose of charging the apparatus itself. | ¶44 | col. 27:8-12 |
| wherein the flat planar substrate is sufficiently flexible to be folded without breaking | The substrates of the Accused Galaxy Products are not sufficiently flexible such that they can be folded without breaking. | ¶46 | col. 28:24-26 |
- Identified Points of Contention:
- Scope Questions: The dispute over the "transmission conductor" limitation raises the question of whether the patent's language, which may be supported by embodiments showing antenna-based reception, can be construed to cover the inductive charging coils used in the Accused Galaxy Products.
- Technical Questions: A central factual question is whether the substrates used in Samsung's products meet the physical requirement of being "sufficiently flexible to be folded without breaking." This will likely depend on evidence regarding the material properties and intended use of the accused devices compared to the patent's disclosure.
10,499,466 Infringement Allegations
| Claim Element (from Independent Claims 3, 7, 11) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first circuit, wherein the first circuit is configured to receive DC power and data signals from a transmission conductor | The circuits of the Accused Galaxy Products do not receive both DC power and data signals from a transmission conductor. | ¶58 | col. 28:51-54 |
| a lens doped with particles configured to receive and transmit light from the plurality of LEDs | The Accused Galaxy Products do not have a lens that is doped with particles that receive and transmit light from LEDs. | ¶60 | col. 28:13-16 |
- Identified Points of Contention:
- Technical Questions: The dispute raises a technical question about the operation of Samsung's circuitry: do the accused products use a single transmission conductor to convey both power and data as required by the claim, or are these functions handled by separate components or via different mechanisms?
- Factual Questions: The allegation regarding the "lens doped with particles" presents a factual question of product composition. The analysis will depend on evidence of whether the accused products contain a component that meets this specific structural and functional limitation.
V. Key Claim Terms for Construction
For the ’252 Patent:
- The Term: "a transmission conductor configured to wirelessly receive an alternating electromagnetic field that is used to provide power to charge the apparatus"
- Context and Importance: This term is central to the infringement allegations against the Accused Galaxy Products. Samsung’s non-infringement position appears to hinge on a narrow interpretation of this phrase, suggesting that its products' wireless charging systems do not operate in the manner claimed (Compl. ¶44). Practitioners may focus on this term because its construction will determine whether standard inductive charging technology falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the claim is broad and does not specify a particular mode of wireless reception (e.g., inductive vs. radiative). The term "transmission conductor" could plausibly be argued to cover any conductive element, such as an induction coil, used for power transfer.
- Evidence for a Narrower Interpretation: The specification may link the term "transmission conductor" to antenna structures. For example, the related ’252 patent shows an "Antenna" (1108) as the element for receiving a wireless signal, which may suggest a narrower, radio-frequency-based meaning rather than near-field inductive coupling (’252 Patent, Fig. 37).
For the ’466 Patent:
- The Term: "a lens doped with particles"
- Context and Importance: This term's construction is critical for claims 3 and 7. Samsung's assertion that its products "do not have a lens that is doped with particles" suggests a straightforward factual dispute, but the definition of "doped" and "particles" could be a point of contention (Compl. ¶60).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification may use the terms broadly to refer to any material added to a lens to alter its optical properties, potentially encompassing common coatings or material compositions. The patent refers to using a phosphor or nano-particle to "produce a change in the color or quality of light" (’466 Patent, col. 12:44-48).
- Evidence for a Narrower Interpretation: The patent may provide specific examples of "particles" (e.g., phosphors, nano-crystals) and "doping" methods that are materially different from any materials or coatings used in the lenses of the accused products.
VI. Other Allegations
Indirect Infringement
For each asserted patent, Samsung preemptively denies allegations of induced and contributory infringement. The primary basis for this denial is the alleged absence of any direct infringement by its products. Additionally, Samsung asserts that it has not acted with the specific knowledge or intent necessary to encourage or contribute to any infringing acts (Compl. ¶¶ 48, 49, 62, 63).
Willful Infringement
The complaint is a declaratory judgment action filed by Samsung. However, it notes that Lynk Labs, in its pre-suit correspondence, stated its belief that "further delay by Samsung is strong evidence of willful infringement," establishing this as a component of the underlying controversy between the parties (Compl. ¶29).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical and definitional scope: can terms like "transmission conductor configured to wirelessly receive" power, which are supported by patent figures depicting antenna-based systems, be construed to cover the near-field inductive charging coils used in Samsung's accused products? The outcome will depend on whether the court finds a fundamental mismatch in the disclosed and accused technologies.
- A key evidentiary question will be one of component-level infringement: do the accused SmartThings and ACOM products, which are primarily software and hub devices, actually contain the specific physical combinations of an "LED driver," "LED circuit," and "LED packages" as required by numerous asserted claims, or is this a case of overbroad patent assertion against products that lack the claimed hardware?
- An overarching procedural question is the impact of subsequent IPR proceedings. Since the filing of this complaint, numerous asserted independent claims across multiple patents-in-suit have been cancelled or disclaimed. A central question will be how these post-filing events narrow the scope of the dispute and affect the viability of any infringement counterclaims Lynk Labs may bring.