DCT
2:21-cv-00105
Solas OLED Ltd v. Samsung Electronics Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Solas OLED Ltd. (Ireland)
- Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Russ August & Kabat
- Case Identification: 2:21-cv-00105, E.D. Tex., 03/22/2021
- Venue Allegations: Venue is alleged to be proper as to Samsung Electronics Co., Ltd. as a foreign corporation and as to Samsung Electronics America, Inc. based on its alleged commission of infringing acts and its regular and established places of business within the district.
- Core Dispute: Plaintiff alleges that Defendants’ electronic devices containing OLED panel displays, such as its Galaxy-brand mobile phones and tablets, infringe patents related to touch sensor hub architecture and state-machine-based gesture recognition.
- Technical Context: The technology at issue concerns the underlying systems in modern consumer electronics that manage power by coordinating multiple sensors and interpret complex user interactions with touch-sensitive surfaces.
- Key Procedural History: The complaint alleges that Defendant Samsung Electronics Co., Ltd. had knowledge of the ’767 patent prior to the lawsuit, based on the issuance of its own U.S. Patent No. 9,207,792, which cites the ’767 patent on its face. This allegation may be used to support claims of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-01 | '767 Patent Priority Date |
| 2012-07-12 | '144 Patent Priority Date |
| 2013-09-03 | '767 Patent Issue Date |
| 2015-12-08 | U.S. Patent 9,207,792 issues, citing '767 Patent |
| 2016-03-22 | '144 Patent Issue Date |
| 2021-03-22 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,292,144 - “Touch-Sensor-Controller Sensor Hub” (Issued Mar. 22, 2016)
The Invention Explained
- Problem Addressed: The patent addresses the need for efficient management of multiple sensors within a mobile device to conserve power ('144 Patent, col. 2:48-62). Modern devices use not only touch sensors but also a variety of other sensors (e.g., accelerometers, gyroscopes) to understand their environment, and coordinating these without constantly waking the main processor is a technical challenge (Compl. ¶1, Ex. 1).
- The Patented Solution: The invention proposes a dedicated "sensor hub" controller that manages both the touch sensor and other device sensors. This controller can operate through distinct processing cycles for touch signal acquisition, pre-processing, and processing, while concurrently polling other sensors like accelerometers or ambient light sensors ('144 Patent, Abstract; col. 3:20-40). This architecture allows the main, power-intensive application processor to remain in a low-power state until the sensor hub detects a significant event, thereby extending battery life ('144 Patent, col. 2:50-54).
- Technical Importance: This sensor hub approach enables "always-on" sensing capabilities, a key feature of modern mobile devices, without imposing a significant power penalty ('144 Patent, col. 2:1-18).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶25).
- Independent Claim 1 (Method):
- By a controller, controlling a touch sensor of a device, where the control comprises:
- acquisition of touch-sensor signals from the touch sensor;
- pre-processing of the touch-sensor signals; and
- processing the signals to determine if a touch/proximity input occurred and, if so, its location.
- By the same controller, controlling one or more other sensors of the device.
- The control of the other sensors occurs at least in part concurrently with the acquisition or pre-processing of the touch-sensor signals.
- By a controller, controlling a touch sensor of a device, where the control comprises:
U.S. Patent No. 8,526,767 - “Gesture Recognition” (Issued Sep. 3, 2013)
The Invention Explained
- Problem Addressed: The patent’s background section describes the difficulty in reliably and efficiently coding software to distinguish between a large and growing number of user gestures (e.g., tap, flick, pinch, rotate) from a raw time series of touch data. It notes that traditional programming approaches can become overly complex and difficult to extend or test ('767 Patent, col. 3:1-8).
- The Patented Solution: The invention discloses a modular, state-machine-based approach for gesture recognition ('767 Patent, Abstract). Instead of a single, complex program, the system uses a plurality of linked "state-machine modules." For multi-touch gestures, the system employs distinct "one-touch" state machines to process the data from each individual touch point. The outputs from these one-touch modules are then fed into a separate "multi-touch" state machine that recognizes gestures like pinching or rotation ('767 Patent, Fig. 4; col. 4:41-49).
- Technical Importance: This architecture provides a structured and scalable framework for interpreting the complex vocabulary of single and multi-touch gestures that are fundamental to modern graphical user interfaces ('767 Patent, col. 14:11-20).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶47).
- Independent Claim 1 (Device):
- A sensor with a sensitive area for outputting sense signals.
- A processor executing position-processing logic to calculate interaction positions and output a time series of data.
- A processor executing gesture-processing logic coded with a plurality of distinct state-machine modules to analyze the time series data and distinguish gesture inputs. The modules comprise:
- A first one-touch state-machine module to recognize a first one-touch gesture and generate a first output.
- A second one-touch state-machine module to recognize a second one-touch gesture and generate a second output.
- A multi-touch state-machine module that receives the first and second outputs to recognize and output at least one multi-touch gesture.
III. The Accused Instrumentality
- Product Identification: The Accused Products are the OLED panel displays and their associated touch controller chips, as integrated into Defendants' consumer electronic devices, including Samsung laptop computers, Galaxy mobile phones, and tablet devices (Compl. ¶¶ Intro, 6). The complaint specifically identifies the Samsung Galaxy S9 and S20 as exemplary products (Compl. ¶16).
- Functionality and Market Context: The complaint alleges the Accused Products contain touch controller chips (e.g., Samsung S6SY761X) and processors (e.g., Qualcomm Snapdragon) that perform the patented methods (Compl. ¶¶ 18, 38). For the ’144 Patent, the allegations focus on the touch controller's role as a sensor hub that manages both the touch sensor and an electrostatic discharge (ESD) sensor concurrently (Compl. ¶23). For the ’767 Patent, the allegations center on the processor's use of Android operating system components, such as "MotionEvent" and "ScaleGestureDetector", to implement a state-machine architecture for recognizing multi-touch gestures (Compl. ¶¶ 41, 44). The complaint provides a teardown photograph of a Samsung Galaxy S9 to identify the accused touch controller chip (Compl. p. 5).
IV. Analysis of Infringement Allegations
’144 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| by a controller, controlling a touch sensor of a device, the control of the touch sensor comprising: | The Accused Products contain a touch controller chip (e.g., Samsung S6SY761X) that controls the touch sensor. | ¶¶17-18 | col. 2:66-67 |
| acquisition of touch-sensor signals from the touch sensor; | The controller acquires touch-sensor signals from the touch sensor grid. A complaint figure illustrates this signal acquisition path. (Compl. p. 7). | ¶19 | col. 3:1-3 |
| pre-processing of the touch-sensor signals; | The controller performs pre-processing of the touch-sensor signals. | ¶20 | col. 3:3-4 |
| and processing of the touch-sensor signals to determine: whether a touch or proximity input has occurred with respect to the touch sensor; | The controller processes the signals to detect different modes of touch, such as normal, hover, glove, and stylus touches, as shown in an excerpt of driver code. (Compl. p. 9). | ¶21 | col. 3:5-7 |
| if the touch or proximity input has occurred with respect to the touch sensor, a location of the touch or proximity input; and | The controller driver code outputs the X and Y coordinates of a detected touch to the operating system. | ¶22 | col. 3:8-10 |
| by the controller, controlling one or more other sensors of the device, the control of the other sensors occurring at least in part concurrently with the acquisition of the touch-sensor signals from the touch sensor or the pre-processing of the touch-sensor signals. | The touch controller also controls an electrostatic discharge (ESD) sensor to detect environmental characteristics, and this control allegedly occurs concurrently with touch sensing operations. A diagram alleges the ESD sensor is one of the "one or more other sensors." (Compl. p. 11). | ¶23 | col. 3:20-40 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether an "electrostatic discharge (ESD) sensor" (Compl. ¶23) qualifies as one of the "one or more other sensors of the device" as construed from the patent. The patent's specification lists examples such as an accelerometer, gyroscope, and ambient light sensor for detecting the device's environment ('144 Patent, col. 2:10-12), raising the question of whether an ESD sensor, which detects an electrical characteristic, falls within the same class.
- Technical Questions: The claim requires the control of the "other sensors" to occur "concurrently" with specific touch processing cycles. The complaint asserts this concurrency (Compl. ¶23), but a key factual question for the court will be what technical evidence demonstrates this specific timing relationship.
’767 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sensor having a sensitive area extending in at least one-dimension and arranged to output sense signals responsive to proximity of an object to the sensitive area; | The Accused Products include a touchscreen with a one- or two-dimensional sensitive area that outputs signals when a user's finger is proximate. | ¶37 | col. 4:26-29 |
| a processor operable to execute position-processing logic... to: calculate positions of interactions...; and output a times series of data indicative of the interaction positions...; | The Snapdragon processor and touchscreen controller are alleged to execute logic based on the Multi-touch (MT) Protocol to calculate touch positions and output a time series of data for each touch. | ¶¶38-39 | col. 4:29-34 |
| a processor operable to execute gesture-processing logic... configured to analyze the time series of data to distinguish one or more gesture inputs... | The Accused Products' processor is alleged to execute Android logic to analyze the time series of data and distinguish gestures like spreading and pinching. | ¶¶40-41 | col. 4:35-38 |
| the gesture-processing logic being coded with gesture-recognition code comprising a plurality of state-machine modules, the plurality of state-machine modules comprising: a first one-touch state-machine module... | The Android "MotionEvent" system is alleged to be the first one-touch state-machine module, which recognizes a first touch gesture (e.g., "ACTION_DOWN") and generates an output. | ¶42 | col. 21:5-9 |
| a second one-touch state-machine module... | The "MotionEvent" system is also alleged to function as the second one-touch state-machine module by recognizing a second touch (e.g., "ACTION_POINTER_DOWN"). | ¶43 | col. 21:10-14 |
| a multi-touch state-machine module operable to: receive... the first output; receive... the second output; and recognize... at least one multi-touch gesture... the... modules being distinct state-machine modules; and output the recognized multi-touch gesture. | The Android "ScaleGestureDetector" is alleged to be a distinct multi-touch finite state machine (FSM) that receives outputs from the "MotionEvent" modules to recognize and output multi-touch gestures like pinch and stretch. A diagram illustrates this FSM. (Compl. p. 24). | ¶¶44-45 | col. 21:15-25 |
- Identified Points of Contention:
- Scope Questions: The infringement case hinges on whether the software architecture of the Android operating system can be properly mapped onto the patent's claimed structure of distinct "first," "second," and "multi-touch" state-machine modules. A key dispute may be whether components like "MotionEvent" and "ScaleGestureDetector" are "distinct state-machine modules" as required by the claim, or if this is a post-hoc characterization of an integrated event-handling system.
- Technical Questions: A technical question is whether an event-driven system like Android's "MotionEvent" constitutes a "state-machine module" in the manner described by the patent, which depicts discrete finite-state-machine blocks ('767 Patent, Fig. 4), or if there is a fundamental architectural difference. The complaint alleges recognition of a two-finger swipe gesture, providing a screenshot from a Samsung guide (Compl. p. 30).
V. Key Claim Terms for Construction
For the ’144 Patent:
- The Term: "controlling one or more other sensors of the device"
- Context and Importance: This term is the central limitation distinguishing the invention. The infringement analysis depends entirely on whether the accused controller's interaction with an alleged "ESD sensor" meets this definition. Practitioners may focus on this term because the patent's examples of "other sensors" (accelerometer, gyroscope) are for sensing the physical environment, whereas an ESD sensor detects an electrical condition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of what the "other sensors" might detect, including "contact, pressure, force, vibration, temperature, humidity, proximity, or any other suitable characteristic," which is a broad and open-ended list ('144 Patent, col. 2:6-9).
- Evidence for a Narrower Interpretation: The patent’s primary examples are inertial and environmental sensors like an "accelerometer 26, a gyroscope 28, an ambient light sensor (ALS) 30, or a magnetometer 32" ('144 Patent, col. 2:10-12). This could support an argument that the term is limited to sensors that detect the device’s physical state or external environment, not its internal electrical state.
For the ’767 Patent:
- The Term: "state-machine module"
- Context and Importance: The infringement theory for the ’767 patent rests on mapping components of the Android operating system to the claimed "state-machine modules." The construction of this term will determine whether the accused software architecture falls within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the invention as a "state machine approach" using a "plurality of linked state modules," which could be interpreted broadly to cover any software architecture that is functionally modular and operates based on defined states ('767 Patent, col. 3:11-12, 22-24).
- Evidence for a Narrower Interpretation: The patent’s abstract and figures consistently depict discrete, separate blocks for each state machine (e.g., "1-touch FSM," "N-touch FSM" in Fig. 4). The background criticizes monolithic code, suggesting "module" implies a level of structural independence and separability not present in all software systems ('767 Patent, col. 3:1-8).
VI. Other Allegations
- Indirect Infringement: The complaint alleges Defendants induce infringement by instructing customers on how to use the Accused Products in an infringing manner (Compl. ¶¶ 15, 34). For the ’767 patent, the complaint alleges pre-suit knowledge based on Defendant SEC's own patent, U.S. Patent No. 9,207,792, which cited the ’767 patent on its face during prosecution (Compl. ¶46).
- Willful Infringement: Willfulness is alleged for both patents. For the ’144 patent, the allegation is based on knowledge from the filing of the complaint (Compl. ¶26). For the ’767 patent, the allegation is supported by the claim of pre-suit knowledge, asserting Defendants knew or were willfully blind to their infringement (Compl. ¶¶ 46, 48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue for the ’767 patent will be one of architectural mapping: does the accused Android software framework, with components like "MotionEvent" and "ScaleGestureDetector", embody the claimed structure of distinct "one-touch" and "multi-touch" state-machine modules, or is there a fundamental mismatch between the patent's modular architecture and the operation of the accused system?
- A central dispute for the ’144 patent will likely be one of definitional scope: can the term "other sensors," which the patent exemplifies with environmental sensors like accelerometers and gyroscopes, be construed to cover an internal "electrostatic discharge (ESD) sensor" that monitors an electrical property of the touch system itself?
- A key evidentiary question for the ’144 patent will be one of functional proof: what technical evidence will be presented to prove that the accused controller's management of the alleged ESD sensor occurs concurrently with the specific touch-signal acquisition or pre-processing cycles, as required by the claim's precise timing limitation?