2:18-cv-00506
Uniloc 2017 LLC v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc 2017 LLC (Delaware)
- Defendant: Samsung Electronics America, Inc. (New York) and Samsung Electronics Co. Ltd. (South Korea)
- Plaintiff’s Counsel: Prince Lobel Tye LLP; Nelson Bumgardner Albritton P.C.
- Case Identification: 2:18-cv-00506, E.D. Tex., 11/17/2018
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant offers its products and services to customers located in the district.
- Core Dispute: Plaintiff alleges that Defendant’s digital televisions infringe a patent related to methods for adapting the size and portion of a broadcast image for display on different screens.
- Technical Context: The technology addresses the challenge of displaying video content, such as high-definition 16:9 broadcasts, on televisions with varying resolutions and aspect ratios (e.g., 4:3) while preserving the most important part of the image.
- Key Procedural History: The complaint alleges that Samsung was put on notice of the patent-in-suit and its infringement through a prior lawsuit, [Uniloc 2017 LLC](https://ai-lab.exparte.com/party/uniloc-2017-llc) v. Samsung Electronics America Inc, et al., 2:18-cv-00355 (E.D. Tex.). This prior notice forms the basis for the willfulness and ongoing inducement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2001-05-17 | ’408 Patent Priority Date |
| 2007-03-13 | ’408 Patent Issue Date |
| 2018-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,190,408 - "TV-RECEIVER, IMAGE DISPLAY APPARATUS, TV-SYSTEM AND METHOD FOR DISPLAYING AN IMAGE"
- Patent Identification: U.S. Patent No. 7,190,408, "TV-RECEIVER, IMAGE DISPLAY APPARATUS, TV-SYSTEM AND METHOD FOR DISPLAYING AN IMAGE," issued March 13, 2007 (’408 Patent).
The Invention Explained
- Problem Addressed: The patent describes the problem of making broadcast images with different resolutions and aspect ratios (e.g., 16:9 HDTV) compatible with various display devices (e.g., 4:3 SDTV) (’408 Patent, col. 1:16-29). A key challenge is that simply down-sampling the entire image to fit a smaller screen can cause a loss of important visual details, while existing "pan & scan" techniques may not be suitable in all scenarios (’408 Patent, col. 1:49-54).
- The Patented Solution: The invention proposes a receiver that decodes a TV signal containing both image data and "control data." This control data defines the location and size of a "partition of important subject matter" within the larger image (’408 Patent, col. 7:13-19). A re-sampling unit within the receiver then uses this information to extract a new image for display, re-sampling the original at a variable rate determined at the receiver. This allows the system to adapt the size of the important partition to fit the display screen according to a specified "criterion," thereby preserving detail in the most critical part of the scene (’408 Patent, col. 7:20-26; Fig. 2).
- Technical Importance: This approach allows a receiver to intelligently adapt content for a specific display, ensuring that the most important part of an image can be shown on a screen "with only a minimal loss of details," even if the screen is smaller than the original broadcasted partition (’408 Patent, col. 2:15-19).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2 and 7-11 (Compl. ¶12).
- Independent Claim 1 requires:
- A decoder for receiving and decoding a signal with image and control data, where the control data defines a vector indicating a location of a "partition of important subject matter."
- The control data further defining the size of that partition.
- A re-sampling unit that extracts a new image by re-sampling the decoded image at a variable rate defined at the receiver.
- This re-sampling is performed such that the size of the partition in the new image is "adapted according to a criterion."
III. The Accused Instrumentality
Product Identification
The complaint identifies a wide range of Samsung digital televisions, including "The Frame, M4500B Series, NU8000, NU8500, Q65FN Series," and many others, collectively referred to as the "Accused Infringing Devices" (Compl. ¶10).
Functionality and Market Context
The complaint alleges these devices are digital televisions that implement the Advanced Television Systems Committee ("ATSC") and Active Format Description ("AFD") standards (Compl. ¶10). Their accused functionality involves incorporating video screens to display images from decoded TV signals, whereby "the size of the image may be changed by the viewer" (Compl. ¶11). An example given is viewing a 16:9 image as a "center cut in a 4:3 aspect frame to emphasize a portion of the image" (Compl. ¶11). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’408 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A receiver comprising: a decoder for receiving and decoding a signal representing an image and control data wherein the control data defines a vector indicating a location of a partition of important subject matter within said image: | The Accused Devices are digital televisions that receive and decode broadcast signals implementing ATSC and AFD standards, which provide data that allegedly serves as the claimed control data. | ¶10, ¶11 | col. 7:13-17 |
| the control data further defining the size of said partition showing said important subject matter; and | The Accused Devices allegedly use the AFD standard data, which contains information about the active picture area, to define the size of the image partition. | ¶10 | col. 7:18-19 |
| a re-sampling unit for extracting a re-sampled image to be displayed on the screen of a display device from said decoded image by re-sampling said decoded image at a variable re-sampling rate defined at the receiving end such that the size of the partition...is adapted according to a criterion. | The Accused Devices allow a viewer to change the image size (e.g., zoom or change aspect ratio), which allegedly constitutes re-sampling at a variable rate based on the criterion of the viewer's selection. | ¶11 | col. 7:20-26 |
Identified Points of Contention
- Scope Questions: A central question may be whether the "control data" described in the patent, which appears to contemplate broadcaster-defined information to preserve "artistic values" (’408 Patent, col. 1:62-64), is met by the standardized ATSC/AFD signals and user-initiated controls (e.g., "Picture Size" settings) in the accused devices (Compl. ¶10-11). The defense may argue that standardized format data is not equivalent to the patent's "partition of important subject matter."
- Technical Questions: The complaint alleges that the viewer's ability to change the image size meets the "variable re-sampling rate" limitation (Compl. ¶11). A technical question is whether selecting from a set of predefined aspect ratios (e.g., 16:9, 4:3, Zoom) constitutes re-sampling at a "variable rate" as envisioned by the patent, or if the patent requires a more dynamic or continuously adjustable process tied to a specific broadcaster-defined "partition."
V. Key Claim Terms for Construction
The Term: "partition of important subject matter"
Context and Importance: This term is the core of the invention; its definition determines what the "control data" must identify. The dispute will likely center on whether this requires a specific, content-aware region identified by a broadcaster or if it can be read more broadly to cover the entire active video frame defined by a standard like AFD.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the partition to being a sub-region of the full image or defined by a human operator.
- Evidence for a Narrower Interpretation: The specification describes the partition as a way to "maintain the artistic values of the original image" (’408 Patent, col. 1:62-64) and gives examples of a "virtual SDTV-camera that operates within the image that is captured by a HTDV-camera" to select the "most important subject matter" (’408 Patent, col. 5:32-36). This language suggests a content-specific selection rather than a simple data container for the entire active image.
The Term: "variable re-sampling rate defined at the receiving end"
Context and Importance: The infringement theory hinges on equating user-selectable picture modes with this limitation. Practitioners may focus on this term because the patent contrasts it with a fixed rate predefined by the broadcaster, suggesting the "variable" and "at the receiving end" aspects are critical points of novelty.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the rate can be "manipulated by a user watching the re-sampled image on the screen," which could support an argument that any user-initiated size change (e.g., selecting "Zoom") qualifies (’408 Patent, col. 4:30-33).
- Evidence for a Narrower Interpretation: The patent frames the variable rate as a means to adapt the size of the "partition of important subject matter" based on a "criterion" to ensure it fits the screen with minimal detail loss (’408 Patent, col. 7:20-26). This could be interpreted to require a more sophisticated adaptation than simply selecting from a few preset display modes that apply to the entire image.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Samsung "intentionally instructs its customers to use the Accused Infringing Devices in a manner that causes the devices to infringe" through "training videos, demonstrations, brochures, installation and user guides and instructional and marketing materials" (Compl. ¶14-15). The complaint provides a list of URLs to such materials.
Willful Infringement
The complaint alleges that Samsung had pre-suit knowledge of the ’408 Patent and its infringement because of a prior lawsuit, 2:18-cv-00355 (Compl. ¶17). It is alleged that Samsung's continued infringement after receiving notice in that case is willful and deliberate.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the patent’s term "partition of important subject matter," which the specification links to preserving a broadcaster’s "artistic values," be construed to cover the entire active video area as defined by standardized AFD signals? Or does the patent require a more specific, content-aware sub-region of the image?
- A key evidentiary question will be one of functional equivalence: Do the accused televisions' user-selectable picture modes (e.g., "Zoom," "Wide Fit") perform the specific technical function recited in claim 1—namely, adapting a pre-defined "partition" via a "variable re-sampling rate"—or do they perform a non-infringing function, such as a simple geometric scaling or cropping of the entire decoded image?
- A third question will relate to knowledge and intent: Assuming infringement is found, the willfulness claim will depend on what notice the prior lawsuit (2:18-cv-00355) provided to Samsung regarding the specific infringement theory and products at issue in this case.