DCT

1:22-cv-00433

Mojo Mobility Inc v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-00433, E.D. Tex., 10/07/2022
  • Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign entity. For Samsung Electronics America, Inc., venue is alleged based on a regular and established place of business in Plano, Texas, where it operates a permanent office and employs personnel, and its commission of infringing acts within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless charging products, including its Galaxy line of smartphones and wireless chargers, infringe seven patents related to inductive power transfer technology.
  • Technical Context: The technology at issue is wireless inductive charging, a method for transferring power to electronic devices without physical cables, which has become a standard feature in high-end consumer electronics.
  • Key Procedural History: The complaint alleges that beginning in 2013, Plaintiff and Defendant engaged in discussions regarding Defendant’s potential use of Plaintiff’s technology, during which Plaintiff presented its technology and prototypes. The complaint alleges these discussions broke down after Defendant was unwilling to pay for the use of the technology, a history that forms the basis for Plaintiff’s willfulness allegations.

Case Timeline

Date Event
2006-01-31 Priority Date for U.S. Patent Nos. 7,948,208 and 9,577,440
2011-05-24 U.S. Patent No. 7,948,208 Issued
2013-01-01 Plaintiff alleges business discussions with Defendant began in 2013
2016-01-01 Accused Product sales began "from 2016 to the present"
2017-02-21 U.S. Patent No. 9,577,440 Issued
2017-03-20 Priority Date for U.S. Patent No. 11,201,500
2020-03-16 Priority Date for U.S. Patent No. 11,292,349
2021-10-21 Priority Date for U.S. Patent Nos. 11,316,371 and 11,462,942
2021-12-14 U.S. Patent No. 11,201,500 Issued
2022-04-05 U.S. Patent No. 11,292,349 Issued
2022-04-26 U.S. Patent No. 11,316,371 Issued
2022-05-24 U.S. Patent No. 11,342,777 Issued
2022-10-04 U.S. Patent No. 11,462,942 Issued
2022-10-07 Complaint Filed

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

U.S. Patent No. 7,948,208 - "Power Source, Charging System, and Inductive Receiver for Mobile Devices"

Issued May 24, 2011

The Invention Explained

  • Problem Addressed: The patent’s background describes the inconvenience and proliferation of different, incompatible wired chargers for various portable electronic devices (’208 Patent, col. 1:18-54).
  • The Patented Solution: The invention provides a wireless charger system, such as a flat pad, containing a plurality of primary coils. The system can detect the presence of a compatible device, determine which primary coil is best aligned with the device's receiver coil, and selectively activate only that coil to transfer power inductively (’208 Patent, col. 2:50-3:13). This selective activation allows for position-flexible charging on the pad's surface.
  • Technical Importance: This approach addresses the problem of precise alignment required in early inductive chargers, allowing users to place a device more freely on a charging surface.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶37).
  • Essential elements of Claim 1 include:
    • A charger system with a base unit having a plurality of primary coils.
    • Each coil is associated with a switching circuit capable of selective activation.
    • A communications interface to poll the coils to verify a device's presence.
    • Logic to select and activate only the primary coil(s) most closely aligned with a device's receiver coil.
    • The use of current modulation for communication to regulate power transfer.
  • The complaint reserves the right to assert additional claims, including claims 3 and 5 (Compl. ¶67).

U.S. Patent No. 9,577,440 - "Inductive Power Source and Charging System"

Issued February 21, 2017

The Invention Explained

  • Problem Addressed: The patent addresses the need for a mobile device to be able to work with a "universal base unit" that can charge different types of devices with varying power requirements (’440 Patent, col. 2:24-34).
  • The Patented Solution: The invention describes a mobile device equipped with the necessary components for inductive charging. These components include a battery, a receiver coil, an identification component to communicate its identity and charging needs to a base unit, a means to prevent overcharging, and a regulator to manage the received voltage or current (’440 Patent, col. 2:56-3:12). The device communicates with the base unit to manage the power transfer process according to its specific characteristics.
  • Technical Importance: This technology defines the capabilities required on the device side of the wireless charging ecosystem, enabling interoperability with universal chargers.

Key Claims at a Glance

  • The complaint asserts at least independent claims 1 and 3 (Compl. ¶69).
  • Essential elements of Claim 1 (a mobile device) include:
    • A battery and a receiver coil.
    • An identification component to provide wireless identification to a base unit.
    • A means for avoiding overcharging.
    • A regulator to control the output voltage or current.
    • Capability for the receiver to communicate with the base unit to detect, identify, authenticate, activate aligned coils, and communicate its charging characteristics.
  • Essential elements of Claim 3 (a system) include:
    • A universal base unit with one or more primary coils.
    • A mobile device with a receiver, an identification component, a means for avoiding overcharging, and a regulator.
    • Communication from the receiver to the base unit to manage the charging process.
  • The complaint reserves the right to assert additional claims (Compl. ¶123).

U.S. Patent No. 11,292,349 - "System and Method for Powering or Charging Receivers or Devices Having Small Surface Areas or Volumes"

Issued April 5, 2022

  • Technology Synopsis: This patent addresses the challenge of wirelessly charging very small devices. It describes a system where a charger with a planar coil transfers power to a receiver that uses a solenoid-type coil (a wire wrapped around a magnetic core), which is better suited for devices with small surface areas or volumes, such as a stylus pen (’349 Patent, Abstract).
  • Asserted Claims: Independent claims 1 and 26 (Compl. ¶125).
  • Accused Features: The Samsung Galaxy S22 Ultra smartphone, which functions as a charger, and its included S Pen, which functions as the mobile device with the receiver (Compl. ¶¶126-127).

U.S. Patent No. 11,316,371 - "System and Method for Inductive Charging of Portable Devices"

Issued April 26, 2022

  • Technology Synopsis: This patent describes an apparatus that can both provide and receive wireless power, such as a smartphone with "reverse charging" capability. The claims detail the drive circuits, sense circuits, and control logic for managing bi-directional power transfer and communication with another device, including regulating power via closed-loop feedback by adjusting operating frequency or duty cycle (’371 Patent, Abstract; Claim 1).
  • Asserted Claims: Independent claims 1 and 20 (Compl. ¶151).
  • Accused Features: The Samsung Galaxy S22 Ultra, which includes the "Wireless PowerShare" feature allowing it to charge other devices (Compl. ¶¶152-154).

U.S. Patent No. 11,201,500 - "Efficiencies and Flexibilities in Inductive (Wireless) Charging"

Issued December 14, 2021

  • Technology Synopsis: This patent describes a system for powering or charging multiple devices, focusing on the communication and control circuits that manage the process. The system detects devices, identifies their power requirements, determines the best-aligned primary coil, and regulates power transfer through closed-loop feedback based on communications from the receiver units (’500 Patent, Abstract; Claim 1).
  • Asserted Claims: Independent claims 1 and 23 (Compl. ¶221).
  • Accused Features: Samsung smartphones with Wireless PowerShare (e.g., S21 Ultra) and Samsung's multi-device wireless chargers (Compl. ¶222).

U.S. Patent No. 11,342,777 - "Powering and/or Charging with More Than One Protocol"

Issued May 24, 2022

  • Technology Synopsis: This patent addresses interoperability by describing a base system and electronic device that can operate using at least two different wireless charging protocols. The system is configured to identify the protocol being used by a device (e.g., one with uni-directional messaging vs. one with bi-directional messaging) and adapt its operation accordingly, often at different power levels associated with each protocol (’777 Patent, Abstract; Claim 1).
  • Asserted Claims: Independent claims 1 and 15 (Compl. ¶261).
  • Accused Features: The Samsung Wireless Charger Duo Pad (5400 Duo) and the Galaxy S22 Ultra smartphone, which allegedly support multiple charging modes such as the standard Qi Baseline Power Profile and Samsung's proprietary Wireless Fast Charge protocol (Compl. ¶¶262, 271, 276).

U.S. Patent No. 11,462,942 - "Efficiencies and Method Flexibilities in Inductive (wireless) Charging"

Issued October 4, 2022

  • Technology Synopsis: This patent is part of the same family as the ’371 patent and similarly describes systems and portable devices for bi-directional wireless power transfer. The claims detail the drive, sense, and control circuitry for detecting communications and regulating power transfer through closed-loop feedback based on information received from the other device (’942 Patent, Abstract; Claim 1).
  • Asserted Claims: Independent claims 1 and 21 (Compl. ¶320).
  • Accused Features: The Samsung Galaxy S22 Ultra (as a power provider) and the Samsung 5400 Duo wireless charger (Compl. ¶¶321-323).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses a wide range of Samsung products capable of providing or receiving wireless power, including Samsung Galaxy smartphones (e.g., S7, S10, S22 Ultra), wireless chargers (e.g., Wireless Charger Duo Pad, Trio Pad), wearables (e.g., Galaxy Watch), and earbuds (e.g., Samsung Buds) (Compl. ¶29).

Functionality and Market Context

  • The accused instrumentalities for the ’208 Patent are multi-device charging pads such as the Samsung Wireless Charger Duo Pad EP-P5200 ("5200 Duo"). These chargers provide multiple charging coils to power one or more devices simultaneously and are "Qi certified," indicating compliance with the Wireless Power Consortium (WPC) standard (Compl. ¶¶38, 58). An FCC filing teardown image shows the internal printed circuit board of the 5200 Duo, revealing its multiple charging coils and associated circuitry (Compl. ¶46).
  • The accused instrumentalities for the ’440 Patent are mobile devices, such as the Samsung Galaxy S7 and S10 smartphones. These devices contain an internal battery, a receiver coil, and control circuitry (ASICs) that allow them to receive power from a universal base unit (Compl. ¶¶70, 77, 82). The Galaxy S10 and later models also feature "Wireless PowerShare," which allows the smartphone itself to act as a wireless charger for other devices (Compl. ¶111). A teardown image from iFixit shows the planar receiver coil integrated into the Galaxy S7 smartphone (Compl. ¶80).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,948,208 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a base unit having a surface, and comprising a plurality of primary coils arranged behind and parallel to the surface The accused Duo and Trio chargers are base units with multiple primary charging coils arranged under the charging surface (Compl. ¶¶43, 45, 50, 52). ¶43 col. 4:1-4
wherein each of the primary coils is associated with a switching circuit in the base unit, which switching circuit is capable of being selectively switched to activate its associated primary coil The chargers include switching circuits with ASICs (e.g., IDT P9236), FETs, and FET drivers to selectively activate the coils (Compl. ¶¶49, 51, 53). ¶49 col. 4:5-15
a communications interface that the base unit, and the mobile...device...use to communicate with one another... to poll each of the primary coils...to verify the presence of the mobile...device The chargers include a communication interface (e.g., IDT/Renesas ASIC) that communicates via current modulation through the coils to poll/sense for a device, consistent with the WPC (Qi) standard (Compl. ¶¶58, 60, 62). ¶58 col. 4:26-38
select, based on the polling or sensing...only those one or more primary coils which are determined to be most closely aligned with a receiver coil The chargers are interoperable with the WPC standard, which requires the transmitter to locate the objects on its surface and select the primary coil that provides optimum power transfer (Compl. ¶¶58, 61, 64). ¶64 col. 4:39-47
wherein the base unit, and receiver coil...use current modulation performed by the receiver coil...to provide an indication that is then used by the base unit to determine and regulate...output voltage, current, or power The chargers use closed-loop feedback based on current modulation from the receiver, as required by the WPC standard, to regulate power transfer by controlling voltage and current (Compl. ¶¶58, 62, 63, 65). ¶65 col. 4:56-col. 5:2

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused products' alleged adherence to the WPC (Qi) standard is sufficient to meet the specific claim limitations. For instance, does the WPC standard's "Digital Ping" phase, which the complaint cites, constitute "poll[ing] each of the primary coils" as recited in the claim, or is there a technical distinction in how the device presence is verified?
  • Technical Questions: The complaint alleges the chargers "select...only those one or more primary coils which are determined to be most closely aligned" (Compl. ¶57). A point of contention could be the factual evidence demonstrating this selectivity, particularly in products like the 6300 Trio, which has six overlapping coils on one side (Compl. ¶52), raising the question of how "only" the most aligned coils are selected in such a dense array.

U.S. Patent No. 9,577,440 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A mobile device capable of inductive powering or charging by a universal base unit...comprising: a battery The Samsung Galaxy S7 is a mobile device that supports wireless charging from WPC-compatible base units and contains a battery (Compl. ¶¶72, 73, 77). ¶¶72, 77 col. 2:56-59
a receiver and receiver coil, for one of inductively powering the device or charging the battery...wherein the receiver coil has a generally planar shape The S7 includes an integrated planar receiver coil and an ASIC (e.g., IDT/Renesas P9221) that form a receiver for wireless power transfer (Compl. ¶¶80, 82). ¶¶80, 82 col. 2:60-67
an identification component associated with the mobile device or battery, which is configured to provide wireless identification of the receiver to the universal base unit The S7's receiver ASIC, microcontroller, and communication circuitry allegedly form an "identification component" that transmits identification packets (e.g., Manufacturer Code, Device Identifier) to the base unit per the WPC standard (Compl. ¶¶83-85). ¶85 col. 3:1-4
a means for avoiding overcharging one or both of the mobile device and battery inductively Per the WPC standard, the S7 includes means to send an "end power transfer" message to the base unit to signal that charging should stop, which allegedly corresponds to the claimed "means for avoiding overcharging" (Compl. ¶¶91-93). ¶92 col. 3:5-7
wherein the receiver communicates with the base unit to detect, identify and authenticate the receiver...determine and then activate one or more primary coils...verify the continued presence...and communicate information describing the characteristics of the mobile device or the battery The S7 communicates with the base unit per the WPC standard to provide identification packets, signal strength for coil alignment, continuous control signals to verify presence, and configuration packets describing its charging characteristics (e.g., power class, maximum power) (Compl. ¶¶101-106). ¶¶102-106 col. 3:13-23

Identified Points of Contention

  • Scope Questions (Means-Plus-Function): Claim 1 recites "a means for avoiding overcharging." The scope of this element will be limited to the corresponding structure described in the patent's specification and its equivalents. The dispute may center on whether the structure in the accused S7 (e.g., the P9221-R ASIC programmed to send an "end power transfer" message) is the same as or equivalent to the structure disclosed in the ’440 patent.
  • Technical Questions: The complaint alleges the hardware/software in the S7 that communicates per the WPC standard corresponds to the claimed "identification component" (Compl. ¶85). A potential point of contention is whether the generic communication capabilities of a standard-compliant ASIC perform the specific functions of "identification" and "authentication" as understood and required by the patent claims.

V. Key Claim Terms for Construction

For the ’208 Patent (Claim 1)

  • The Term: "poll each of the primary coils"
  • Context and Importance: The definition of "poll" is critical. The complaint relies on the WPC standard's "Digital Ping" phase to meet this limitation. The dispute will likely focus on whether sending a "ping" signal into the environment and waiting for a response from any device that happens to be present is the same as actively "polling each of the primary coils" in a sequential or targeted manner. Practitioners may focus on this term because the outcome could determine whether compliance with a major industry standard constitutes infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the process as "polling or otherwise sensing the presence of a mobile device" (’208 Patent, col. 3:1-2), which may suggest that "polling" is just one example of a broader "sensing" function.
    • Evidence for a Narrower Interpretation: Claim 1 requires the system to "poll each of the primary coils," which could be interpreted to require a specific, iterative check of every individual coil, a potentially more active process than the general ping described in the WPC standard.

For the ’440 Patent (Claim 1)

  • The Term: "means for avoiding overcharging"
  • Context and Importance: This is a means-plus-function term under 35 U.S.C. § 112(f). Its scope is not its literal dictionary meaning but is defined by the specific "corresponding structure" disclosed in the patent's specification that performs the function of avoiding overcharging. The central issue will be identifying that structure in the patent and comparing it to the accused structure in the Samsung devices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The parties may dispute what constitutes the full "corresponding structure." The patent describes a receiver that communicates information to the base unit, which then controls power transfer (’440 Patent, col. 3:13-23). A broader view might argue the structure is the entire communication and control feedback loop.
    • Evidence for a Narrower Interpretation: The specification also mentions that the receiver includes "logic to set the voltage and current to the appropriate levels" (’440 Patent, col. 2:4-6). A narrower view could argue the structure is limited to specific regulator circuits or logic within the receiver itself, rather than the entire system interaction.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement. Inducement is based on Samsung's affirmative acts of selling the accused products and providing instructions, product manuals, marketing, and technical support that allegedly encourage customers to use the products in an infringing manner (Compl. ¶31). Contributory infringement is alleged on the basis that the accused components are material to the inventions, not staple articles of commerce, and are known by Samsung to be especially made for an infringing use (Compl. ¶32).

Willful Infringement

  • Willfulness is alleged based on Samsung's alleged pre-suit knowledge of Mojo Mobility's technology and patents. The complaint asserts that Samsung engaged in years of business discussions, inspected prototypes, received technical information, and knew Plaintiff had applied for patents, yet proceeded to incorporate the technology into its products without a license (Compl. ¶¶14-17, 20, 35).

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

  • A core issue will be one of definitional scope and standard essentiality: Can the specific, multi-step process limitations recited in the patent claims (e.g., "poll each of the primary coils," "communicate information describing the characteristics of the mobile device") be met by the accused products' alleged implementation of the industry-standard Qi wireless charging protocol, or is there a fundamental mismatch between the patent's specific requirements and the standard's operation?
  • A second key question will be one of historical conduct and intent: To what extent will the detailed allegations of pre-suit meetings, prototype demonstrations, and failed licensing negotiations between the parties provide the factual basis necessary to support Plaintiff's claim for willful infringement and potentially enhanced damages?
  • A third key question will be one of claim construction under § 112(f): How will the court construe the scope of the "means for avoiding overcharging" limitation in the ’440 Patent, a determination that will depend entirely on the specific corresponding hardware or software algorithms disclosed in the patent's specification for performing that function.