Samsung Electronics America Inc v. Akhavan

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Keyless Licensing LLC ([Jurisdiction not specified])
  • Defendant: Samsung Electronics America, Inc. (New York) and Samsung Electronics Co., Ltd. (Republic of Korea)
  • Defendant’s Counsel: The Law Offices of Robert C. Brady, P.C.; Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
• Case Identification: Keyless Licensing LLC v. Samsung Electronics America, Inc., 2:24-cv-00464, E.D. Tex., 06/20/2024
• Venue Allegations: The complaint does not provide sufficient detail for analysis of the basis for venue.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe three patents, including one related to mobile device form factor and user interface technology.
• Technical Context: The technology at issue concerns the physical design and data-entry methods for mobile electronic devices, a field central to the modern smartphone market.
• Key Procedural History: The provided document is a complaint to compel discovery filed in a miscellaneous action in the Eastern District of New York, ancillary to the main patent infringement case in the Eastern District of Texas. The discovery sought relates to depositions of non-parties concerning patent transfers and commercialization efforts, which Defendant Samsung contends are relevant to calculating potential damages.

Case Timeline

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

• Patent Identification: U.S. Patent No. 11,503,144, titled "SYSTEMS TO ENHANCE DATA ENTRY IN MOBILE AND FIXED ENVIRONMENT," issued on November 15, 2022.
• The Invention Explained:
  • Problem Addressed: The patent’s background section identifies drawbacks with conventional methods for entering characters on small electronic devices, such as the slowness of multi-press systems on numeric keypads, the clumsiness of miniaturized QWERTY keyboards, and the unreliability and high processing demands of early voice recognition software (’144 Patent, col. 1:30-62).
  • The Patented Solution: The invention proposes a data input system for a keypad that aims to be "fast, reliable, and does not require large amounts of set up and energy/processing expenditures" (’144 Patent, col. 2:1-4). This is achieved by combining key interactions with other user inputs, such as voice commands, to select from multiple symbols assigned to a single key (’144 Patent, col. 7:22-62). The patent also describes a mobile phone form factor with a "substantially rectangular shape" where a display unit "substantially entirely covers the front surface" and the device "does not include a physical key on the front surface" (’144 Patent, abstract).
  • Technical Importance: The described physical form factor anticipated the now-dominant "slab" design of modern smartphones, while the proposed data entry methods address the fundamental human-computer interaction challenge of typing on compact, key-limited devices (’144 Patent, col. 1:30-36).
• Key Claims at a Glance:
  • The complaint does not specify which claims of the ’144 Patent are asserted Compl. ¶11 Independent claim 1 is analyzed here as a representative claim.
  • Essential elements of Independent Claim 1 include:
    • A mobile phone device, comprising:
    • a practically rectangular-shaped housing having a front surface, back surface, and four side surfaces;
    • wherein the length of the front surface approximately corresponds to the distance between the ear and the mouth of a user and the width is substantially shorter than the length;
    • wherein the housing has a thin thickness;
    • a display unit integrated within the front surface that practically covers the entire front surface;
    • wherein the mobile phone device does not include a physical key on the front surface; and
    • wherein the components of the mobile phone are integrated within the housing such that none are noticeably extended out. (’144 Patent, col. 103:52-104:4)
  • The complaint does not reserve the right to assert dependent claims.

III. The Accused Instrumentality

The complaint does not identify specific accused products or provide sufficient detail for analysis of any accused instrumentality Compl. ¶11 It only states that Plaintiff Keyless Licensing LLC accuses Samsung of infringing three patents. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The provided complaint is a motion to compel discovery in an ancillary proceeding and does not contain infringement allegations, claim charts, or any mapping of the patent claims to an accused product. Therefore, an analysis of infringement allegations cannot be performed based on the documents provided.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail to identify specific terms at the center of an infringement dispute. However, an analysis of the patent indicates that the construction of several terms in the independent claims will be significant.

• The Term: "practically covers the entire front surface" (from Claim 1)
• Context and Importance: This term is central to defining the "all-screen" form factor of the claimed device. Its construction will be critical for determining whether modern smartphones with bezels, speaker slits, or camera cutouts (i.e., interruptions to the display on the front surface) fall within the scope of the claim. Practitioners may focus on this term because it appears to be a primary point of novelty directed at modern device aesthetics.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "practically" suggests a meaning of "almost" or "nearly," which could be argued to tolerate minor non-display areas like bezels or sensor cutouts, consistent with the overall goal of maximizing the screen area on a mobile device (’144 Patent, col. 1:37-43). The abstract uses the similar term "substantially entirely covers," which also implies less than 100% coverage (’144 Patent, abstract).
  • Evidence for a Narrower Interpretation: The specification and its figures, which provide the context for the claims, may support a narrower reading. Numerous figures from the original 2003-era disclosure depict devices with large, distinct physical keypads separate from the display area on the front surface, which contradicts the notion of a display "practically covering" the "entire" front face (’144 Patent, Fig. 1; ’144 Patent, Fig. 3). This discrepancy between the broad claim language and the specific embodiments disclosed raises a potential written description issue under 35 U.S.C. § 112.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement.
• Willful Infringement: The complaint does not contain allegations of willful infringement.

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

As the complaint provides no details on the infringement case, the central questions arise from the patent itself in the context of a modern dispute.

• A central issue for validity will be whether the 2003-priority-date specification, which extensively describes and illustrates devices with physical keypads, provides adequate written description and enablement for claims directed to a modern "all-screen" smartphone that "does not include a physical key on the front surface" (’144 Patent, col. 104:1-2).
• A core issue for claim construction will be defining the scope of relative terms like "practically covers", "substantially shorter", and "noticeably extended out". The court’s interpretation of these indefinite terms will likely determine whether nearly all modern smartphone designs fall within or outside the patent’s scope.