DCT

1:22-cv-01213

Fintech Innovations Associates LLC v. Samsung Group

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-01213, N.D. Ill., 03/08/2022
  • Venue Allegations: Venue is alleged to be proper based on Samsung having regular and established places of business within the Northern District of Illinois, and having committed acts of alleged infringement in the district.
  • Core Dispute: Plaintiff alleges that the animated graphical user interface (GUI) of the Samsung Pay feature on Samsung Galaxy products infringes its design patent for an animated display screen.
  • Technical Context: The dispute is in the field of mobile device GUIs, specifically those used for financial transactions, where user experience and visual design are significant aspects of product differentiation.
  • Key Procedural History: The complaint was filed on the same day the patent-in-suit issued. Subsequently, a Post-Grant Review (PGR) proceeding was initiated against the patent at the USPTO. During that proceeding, the patent owner filed a disclaimer dedicating the entire patent claim to the public. The USPTO later issued a certificate confirming the claim is disclaimed, which raises a potentially case-dispositive question about the continued viability of this litigation.

Case Timeline

Date Event
2021-09-16 U.S. Patent No. D945,453 Priority Date (Application Filing)
2022-03-08 U.S. Patent No. D945,453 Issued
2022-03-08 Complaint Filed
2022-06-13 Post-Grant Review (PGR2022-00046) Filed against D'453 Patent
2022-10-10 Disclaimer Dedicating Entire D'453 Patent Claim to the Public Filed
2023-05-09 Official Gazette Publication of Patent Disclaimer
2023-05-18 Post-Grant Review Certificate Issued Confirming Claim is Disclaimed

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

U.S. Patent No. D945,453 - "Display screen portion with animated graphical user interface"

  • Patent Identification: U.S. Patent No. D945,453, "Display screen portion with animated graphical user interface," issued March 8, 2022.

The Invention Explained

  • Problem Addressed: Design patents do not articulate a "problem" in the manner of utility patents. Their purpose is to protect a new, original, and ornamental design for an article of manufacture (D'453 Patent, Title).
  • The Patented Solution: The patent claims the ornamental design for an animated graphical user interface, as shown in a sequence of figures (D'453 Patent, FIGS. 1-4). The animation consists of a small, outlined square (FIG. 1) that expands into a larger, horizontally-oriented rectangle (FIG. 2 and FIG. 3), within which other elements can be displayed. The broken lines in the figures, including the outline of the mobile device and the text "Enter Amount $0," represent environmental subject matter and do not form part of the claimed design (D'453 Patent, Description). The claimed design is solely the visual appearance of the animated transition of the box shape.
  • Technical Importance: The patent protects a specific aesthetic for a GUI animation, which is a key element of the user experience in modern software applications, particularly in the competitive mobile payments space (Compl. ¶10).

Key Claims at a Glance

  • Design patents have a single claim, which is for the ornamental design as shown in the drawings. The complaint asserts infringement of the "second embodiment," which appears to refer to the animated sequence shown across the figures (Compl. ¶¶10, 12, 14).
  • The single claim consists of the following visual elements: The ornamental design for a display screen portion with an animated graphical user interface, as shown and described in Figures 1-4 (D'453 Patent, Claim).

III. The Accused Instrumentality

Product Identification

  • "Samsung Galaxy computer products with the Samsung Pay display screen graphical user interface" (Compl. ¶10).

Functionality and Market Context

  • The complaint alleges that the Samsung Pay GUI, which is a mobile payment service integrated into Samsung's smart devices, incorporates the patented design (Compl. ¶10). The functionality at issue is the animated graphical interface presented to the user during a transaction.
  • The complaint does not provide specific details on the market positioning of Samsung Pay, but it identifies it as a feature on "Samsung Galaxy computer products," suggesting it is a widely distributed application on a major smartphone platform (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint states that a side-by-side claim chart is attached as Exhibit B; however, that exhibit was not filed with the complaint. The infringement theory must therefore be summarized from the text of the complaint.

The plaintiff alleges that the Samsung Pay GUI infringes the design claimed in the '453 patent (Compl. ¶10). The legal standard for design patent infringement is the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that the accused Samsung Pay interface embodies the design of the "second embodiment" of the '453 patent (Compl. ¶12). The patent's FIG. 2 is described as a "second image" in the animated sequence, which shows the expanded rectangular box that is the core of the claimed design (D'453 Patent, Description).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

This section is not applicable. For design patents, the single claim consists of the drawings. There are no written claim terms that require judicial construction in the manner of a utility patent. The analysis is a visual comparison between the patent's drawings and the accused design.

VI. Other Allegations

  • Indirect Infringement: The prayer for relief seeks a judgment of indirect infringement, but the complaint body does not plead specific facts to support the knowledge and intent elements required for such a claim (Compl. Prayer ¶(a)).
  • Willful Infringement: The complaint does not contain an allegation of willful infringement. The filing date of the complaint is the same as the issue date of the patent, which would preclude any claim of pre-suit knowledge of the patent.

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

  • Case Viability: The central issue is the legal effect of the plaintiff's post-filing disclaimer and dedication to the public of the entire claim of the '453 patent, which was done during a Post-Grant Review proceeding. A foundational question for the court will be whether this action renders the entire case moot and extinguishes any claim for past damages, which would be a case-dispositive outcome.
  • Infringement (Hypothetical): Assuming the case could proceed despite the disclaimer, a key question would be one of visual similarity: would an ordinary observer, viewing the overall designs, find the animation in the accused Samsung Pay interface to be substantially the same as the specific animated box-expansion sequence claimed in the '453 patent, after discounting the unclaimed elements shown in broken lines?
  • Pleading Sufficiency: A procedural question is whether the complaint's repeated reference to infringing the "second embodiment" of the patent—a term without a clear antecedent in the patent document, which contains only a single claim—is sufficiently specific to state a plausible claim for relief under federal pleading standards.