Unknown Case Title

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Keyless Licensing LLC
  • Defendant: Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
  • Plaintiff’s Counsel: Not identified in the provided document
• Case Identification: 2:24-cv-00464, E.D. Tex., 06/20/2024
• Venue Allegations: The underlying patent infringement action was filed in the United States District Court for the Eastern District of Texas. The provided complaint, a miscellaneous action to compel discovery from non-parties, was filed in the Eastern District of New York, where the non-parties reside.
• Core Dispute: Plaintiff alleges that Defendant infringes three patents, including U.S. Patent No. 11,503,144, related to systems for data entry on mobile devices.
• Technical Context: The technology relates to the design of mobile phone user interfaces, specifically concerning devices that maximize screen real estate by eliminating physical front-facing keys, a design paradigm that became dominant with modern smartphones.
• Key Procedural History: The provided document is a complaint to compel discovery filed by Samsung in a separate, ancillary proceeding. Samsung seeks to depose individuals associated with the inventor and a related entity, Classicom L.L.C., regarding prior patent transfers and commercialization efforts. Samsung alleges this discovery is relevant to determining the value and potential damages of the asserted patents in the primary infringement litigation.

Case Timeline

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

• Patent Identification: U.S. Patent No. 11,503,144, "Systems to Enhance Data Entry in Mobile and Fixed Environment," issued November 15, 2022.
• The Invention Explained:
  • Problem Addressed: The patent's background describes drawbacks with data entry methods on mobile devices prevalent at the time, noting that multi-press systems on numeric keypads are slow, miniaturized QWERTY keyboards are clumsy and cause errors, and voice recognition software is too processor-intensive and unreliable for small devices (’144 Patent, col. 1:31-62).
  • The Patented Solution: The invention proposes a mobile phone form factor with a large display that covers nearly the entire front surface and lacks any physical keys on that surface (’144 Patent, Abstract). Data entry is enhanced by combining user interactions, such as key presses on a virtual keypad, with voice/speech recognition to disambiguate the intended character from multiple characters assigned to a single key, thereby improving speed and accuracy (’144 Patent, col. 7:27-32; col. 8:25-47).
  • Technical Importance: This approach sought to provide a fast and reliable method for character entry on compact devices that did not require the extensive processing power or energy expenditure of pure voice recognition systems (’144 Patent, col. 2:1-4).
• Key Claims at a Glance:
  • The complaint does not identify the specific claims asserted in the underlying litigation. Claim 1 is the first independent claim of the patent.
  • Independent Claim 1 Elements:
    • A mobile phone device, comprising:
    • a housing having a substantially rectangular shape wherein its height dimension substantially corresponds to a distance between an ear and a mouth of a user and wherein its width dimension is less than its height dimension;
    • a display unit integrated within the front surface of the mobile phone device;
    • wherein the display unit substantially entirely covers the front surface of the mobile phone device; and
    • wherein the mobile phone device does not include a physical key on the front surface.

III. The Accused Instrumentality

• Product Identification: The complaint does not identify the specific accused instrumentalities.
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint, which is a motion to compel discovery in an ancillary proceeding, does not contain specific infringement allegations or a claim chart mapping the asserted patent claims to any accused instrumentality.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide a basis for identifying claim terms in dispute. However, based on the language of independent claim 1 and the likely context of modern smartphones, the construction of the following terms may be central to the infringement analysis.

• The Term: "substantially entirely covers the front surface"

  • Context and Importance: Practitioners may focus on this term because modern smartphones feature bezels, speaker grilles, and camera cutouts (e.g., "notches" or "islands") that prevent the display from covering 100% of the front surface. The definition of "substantially entirely" will be critical to determining whether these common design features fall within the scope of the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of the word "substantially" suggests the patentee did not intend to require 100% coverage, allowing for minor, insignificant gaps.
    • Evidence for a Narrower Interpretation: Figures in the patent, such as Figure 3, depict a device where the display unit extends very close to the physical edges of the housing, with minimal non-display area, which could be argued to set a high bar for what "substantially entirely" means (’144 Patent, Fig. 3).

• The Term: "physical key on the front surface"

  • Context and Importance: The infringement determination for this limitation may depend on the location and function of buttons on an accused device. Modern smartphones often have physical volume and power buttons on their side surfaces. The dispute will likely center on whether a key on a side surface is considered "on the front surface."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "front surface" should be interpreted broadly to mean the entire front-facing half of the device, potentially including buttons on beveled edges.
    • Evidence for a Narrower Interpretation: The specification consistently distinguishes the "front surface" from other parts of the housing and depicts keypads and displays on a single plane (’144 Patent, Fig. 3, Fig. 13). This could support an interpretation that limits the "front surface" to the primary, flat plane occupied by the screen, thereby excluding side-mounted buttons.

VI. Other Allegations

• Indirect Infringement: The complaint does not provide details regarding allegations of indirect infringement.
• Willful Infringement: The complaint does not provide details regarding allegations of willful infringement.

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

• Claim Scope: A central issue will be one of claim construction: can terms from a patent with a 2003 priority date, such as "substantially entirely covers the front surface" and "does not include a physical key on the front surface", be interpreted to read on modern smartphone designs that incorporate features like camera notches, minimal bezels, and side-mounted physical buttons?
• Relevance of Discovery: The ancillary proceeding raises a key question regarding damages: is discovery into historical patent transfers and commercialization attempts by Classicom L.L.C., an entity related to the patent’s inventor, relevant and proportional to the needs of the case for establishing the value of the asserted patents? Compl. ¶¶ 26-27