DCT

2:17-cv-00715

Polaris PowerLED Tech LLC v. Samsung Display Co Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:17-cv-00715, E.D. Tex., 02/02/2018
  • Venue Allegations: Venue is alleged based on Defendant Samsung Electronics America, Inc. maintaining regular and established places of business within the district, and for the foreign defendants, based on their status as foreign corporations.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and televisions infringe a patent related to dynamically controlling display brightness by combining ambient light sensor data with user-selected preferences.
  • Technical Context: The technology addresses power consumption and user ergonomics in electronic displays by automatically adjusting brightness for viewing conditions, a critical feature for both battery-operated mobile devices and stationary televisions.
  • Key Procedural History: The complaint alleges that Defendants had pre-suit knowledge of the patent-in-suit and its parent patent family, citing their appearance in the prosecution history of Defendants' own patents. The patent-in-suit, U.S. Patent No. 8,223,117, was the subject of an ex parte reexamination where the patentability of asserted independent claim 1, among others, was confirmed.

Case Timeline

Date Event
2004-02-09 '117 Patent Priority Date
2010-07-09 Alleged knowledge of parent patent ('722) by Defendant SEC
2011-03-02 Alleged knowledge of '117 published application by Defendant SEC
2012-07-17 '117 Patent Issue Date
2018-02-02 Amended Complaint Filing Date
2023-12-21 '117 Patent Reexamination Certificate Issue Date

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

U.S. Patent No. 8,223,117 - "Method and Apparatus to Control Display Brightness With Ambient Light Correction," issued July 17, 2012

The Invention Explained

  • Problem Addressed: The patent identifies the dual problems of modern displays consuming significant power and providing a poor user experience under varying light conditions. High ambient light can wash out a display, while a constantly bright screen drains batteries and can cause eye strain in dark environments. Prior art automatic brightness systems are described as "crude" and failing to account for user preferences. (’117 Patent, col. 1:23-57).
  • The Patented Solution: The invention proposes a control system that generates a display brightness signal by mathematically combining two distinct inputs: a signal from an ambient light sensor and a signal representing the user’s desired brightness level. A key component is a "dark level bias" circuit, which ensures the display maintains a minimum, predefined brightness level even when ambient light decreases to zero, preventing the screen from becoming unreadably dark. (’117 Patent, Abstract; col. 2:55-62; Fig. 1).
  • Technical Importance: The described approach sought to improve both power efficiency and user ergonomics by creating an adaptive system that responds not only to the environment but also to the user's subjective comfort level. (’117 Patent, col. 2:48-54).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶25).
  • The essential elements of independent claim 1 are:
    • A brightness control circuit with selective ambient light correction comprising:
    • a first input configured to receive a user signal indicative of a user selectable brightness setting;
    • a light sensor configured to sense ambient light and to output a sensing signal indicative of the ambient light level;
    • a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal; and
    • a dark level bias configured to adjust the combined signal to generate a brightness control signal that is used to control a brightness level of a visible display such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero.
  • The complaint alleges infringement of "one or more claims," including at least claim 1, thereby reserving the right to assert other claims (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

A broad range of Samsung consumer electronics, including smartphones (Galaxy S6, S7, S8, Note5, Note7, Note8), tablets (Galaxy Tab S2, S3), and televisions (QLED, 4K SUHD, 4K UHD, Full HD, and HD series) (Compl. ¶7, ¶24).

Functionality and Market Context

The complaint alleges that the accused products contain an automatic brightness adjustment feature. For smartphones like the Galaxy S7, this functionality is allegedly controlled via a user interface that includes a brightness slider and an "Auto" checkbox which "lets the device adjust the display brightness based on your environment" (Compl. ¶27). For televisions like the UN55MU6300F, the functionality is allegedly part of an "Eco Solution or Energy Saving function, which can include an Ambient Light Detection feature" (Compl. ¶34). The complaint alleges these features are core to the user experience and power management of the devices.

IV. Analysis of Infringement Allegations

'117 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first input configured to receive a user signal indicative of a user selectable brightness setting The user interface of the accused products, such as the Galaxy S7, provides a slide bar that can be utilized by a user to select the brightness of the display. A screenshot depicts this user-selectable slider. ¶27 col. 4:49-50
a light sensor configured to sense ambient light and to output a sensing signal indicative of the ambient light level The accused products, such as the Galaxy S7, contain a "proximity/light sensor" that "provides info to the system to adjust brightness and other display settings." A product layout diagram identifies this sensor's location. ¶28-29 col. 4:50-51
a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal "Specifically, the computer code running on the Galaxy S7 uses a mathematical function as a multiplier to generate a combined signal based on the user signal... and a sensing signal, which is a signal from the light sensor." ¶30 col. 4:58-59
a dark level bias configured to adjust the combined signal... such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero "The computer code running on the Galaxy S7 adjusts the control signal that controls the brightness... to maintain the brightness level of the display above a predetermined level when the ambient brightness is approximately zero." ¶31 col. 2:56-60

Identified Points of Contention

  • Technical Questions: The complaint alleges that "computer code" performs the functions of the "multiplier" and "dark level bias" elements (Compl. ¶30, ¶31). A central technical question will be what evidence demonstrates that the accused software performs these specific operations as claimed. For the "multiplier" element, the court will need to determine if the software actually multiplies a value derived from the user setting with a value derived from the light sensor. For the "dark level bias" element, the question is whether the software’s minimum brightness floor functions by "adjusting the combined signal" from the multiplication step, or if it operates as a separate, overriding condition.
  • Scope Questions: The ’117 patent’s specification provides detailed embodiments using analog and mixed-signal circuits (e.g., current-steering diodes, DACs) (’117 Patent, Fig. 4, Fig. 9). This raises the question of whether the claims can be construed to cover a purely software-based implementation as alleged in the complaint, or if their scope is more closely tied to the hardware structures disclosed in the specification.

V. Key Claim Terms for Construction

The Term: "multiplier"

  • Context and Importance: This term is central to the claimed invention, defining the core mechanism for combining the user and sensor inputs. The infringement case hinges on whether the accused software's "mathematical function" (Compl. ¶30) falls within the legal scope of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests a software implementation is contemplated, stating that a "software algorithm can be used to multiply the light sensor output with the user selectable brightness control" (’117 Patent, col. 2:6-9). This may support a functional interpretation not limited to specific hardware.
    • Evidence for a Narrower Interpretation: The patent’s detailed descriptions and figures heavily feature specific hardware, such as a "pair of current-steering diodes" (’117 Patent, col. 5:35-36) or a "digital-to-analog converter" (’117 Patent, col. 4:59-62). A party could argue the term should be construed in light of these specific embodiments.

The Term: "dark level bias configured to adjust the combined signal"

  • Context and Importance: This limitation defines how the circuit behaves in near-total darkness. The dispute will likely focus on the specific operational relationship between the bias, the user input, and the sensor input.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The stated purpose is to "ensure a predefined (or minimum) brightness in total ambient darkness" (’117 Patent, col. 2:60-62). This could support reading the term on any system that establishes a minimum brightness floor when auto-brightness is active.
    • Evidence for a Narrower Interpretation: Claim 1 requires the bias to "adjust the combined signal" (the output of the "multiplier"). This architecture is depicted in Figure 2, where a bias is added after the user and sensor signals are multiplied. Dependent claim 3, in contrast, describes an architecture where the bias is part of the multiplication itself. Practitioners may argue that the language of claim 1 requires a specific post-multiplication adjustment, potentially distinguishing it from a simple software-based minimum brightness setting that might operate independently of, or as an override to, the multiplication result.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Samsung’s product literature, user manuals, and FAQs instruct customers on how to use the accused automatic brightness features (Compl. ¶16, ¶27, ¶29, ¶34).

Willful Infringement

The complaint alleges both pre- and post-suit willfulness. The pre-suit willfulness claim is based on allegations that Samsung entities cited the ’117 patent’s published application and its parent patent during the prosecution of their own patent applications as early as 2010 and 2011, years before the lawsuit was filed (Compl. ¶¶38-44). Post-suit willfulness is alleged based on continued infringement after receiving notice via the complaint (Compl. ¶47).

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

  • A core issue will be one of implementation scope: Can the terms "multiplier" and "dark level bias", which are described in the patent with specific hardware circuit embodiments, be construed to cover the purely software-based "mathematical functions" and minimum brightness floors allegedly operating in the accused products?
  • A second central question will be one of evidentiary proof: What technical evidence will be required to prove, on an element-by-element basis, that the accused software routines function in the specific manner required by the claims—namely, by performing a true multiplication of user and sensor signals and then adjusting that specific "combined signal" with a bias, as opposed to using a different algorithm to achieve a similar result?
  • Finally, given the detailed allegations of pre-suit knowledge derived from Defendants’ own patent prosecution records and the subsequent confirmation of the asserted claims in reexamination, a significant focus of the litigation may be on the question of willful infringement and the potential for enhanced damages.