Scramoge Technology Ltd v. Samsung Group

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Scramoge Technology Ltd. (Ireland)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:22-cv-00015, E.D. Tex., 01/10/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. has a regular and established place of business in Plano, Texas, and Defendant Samsung Electronics Co., Ltd. is a foreign corporation, for which venue is proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s Galaxy-series mobile devices and other products with wireless charging capabilities infringe seven patents related to the design, structure, and control of wireless power receivers and antennas.
• Technical Context: The patents address technical challenges in integrating wireless power charging (inductive or resonant) and short-range communication (e.g., NFC) functionalities into compact electronic devices.
• Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date	Event
2011-06-08	Priority Date for ’269 and ’043 Patents
2011-11-04	Priority Date for ’364 and ’666 Patents
2015-07-06	Priority Date for ’160, ’426, and ’592 Patents
2016-10-04	’364 Patent Issued
2017-03-21	’269 Patent Issued
2018-12-11	’666 Patent Issued
2019-10-29	’426 Patent Issued
2019-11-12	’160 Patent Issued
2019-11-26	’043 Patent Issued
2020-07-28	’592 Patent Issued
2022-01-10	Complaint Filed

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

U.S. Patent No. 9,461,364 - "Wireless power receiver and control method thereof"

Issued October 4, 2016

The Invention Explained

• Problem Addressed: The patent’s background section describes the technical challenge of integrating wireless charging components (receiving coil) and short-range communication antennas into electronic devices without increasing the device's overall size and thickness ('364 Patent, col. 1:44-51). It also notes issues with overcurrent flowing through the communication module and magnetic field interference causing malfunctions ('364 Patent, col. 1:52-58).
• The Patented Solution: The invention proposes a space-saving design where the wireless power receiving coil is placed within a "reception space" of a printed circuit board (PCB). A separate short-range communication antenna is then disposed on the surface of the PCB in a manner that "surround[s] the receiving coil" ('364 Patent, Abstract). This physical arrangement aims to minimize the vertical stack-up of components, thereby reducing the device's thickness ('364 Patent, col. 2:37-41).
• Technical Importance: This integrated design approach was aimed at enabling the co-location of distinct wireless systems (power and data) within the increasingly constrained physical volume of modern smartphones and other portable electronics.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶11).
• Essential elements of claim 1:
  • A wireless power receiver comprising:
  • a printed circuit board having a reception space in a predetermined area thereof;
  • a receiving coil disposed in the reception space of the printed circuit board for receiving power from a wireless power transmitter; and
  • a short-range communication antenna disposed on the printed circuit board while surrounding the receiving coil.

U.S. Patent No. 10,153,666 - "Wireless power receiver and control method thereof"

Issued December 11, 2018

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’364 Patent, the ’666 Patent addresses the same problems of component thickness, overcurrent damage to communication modules, and magnetic field interference in devices with both wireless charging and NFC ('666 Patent, col. 1:46-58).
• The Patented Solution: The ’666 Patent claims a more specific multi-layer construction. It describes a wireless power receiver where the wireless receiving coil, the short-range communication coil, and a shielding unit are all disposed "in the board" and "between the plurality of layers" of the board ('666 Patent, claim 1). The specification details how this embedded structure, potentially created through injection molding, prevents an increase in the overall thickness of the receiver module ('666 Patent, col. 5:6-16).
• Technical Importance: This approach describes a method for fabricating a highly integrated receiver module where functional components are embedded within the layers of a circuit board, rather than being mounted on its surface, to achieve a minimal profile.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶17).
• Essential elements of claim 1:
  • A wireless power receiver comprising:
  • a board comprising a plurality of layers;
  • a wireless receiving coil disposed in the board;
  • a short-range communication coil disposed in the board; and
  • a shielding unit disposed in the board,
  • wherein the shielding unit is disposed on the wireless receiving coil and the short range communication coil, and
  • wherein the coils and shielding unit are disposed between the plurality of layers.

U.S. Patent No. 9,601,269 - "Resonant coil, wireless power transmitter using the same, wireless power receiver using the same"

Issued March 21, 2017

• Technology Synopsis: This patent addresses a potential failure mode in "litz wire" coils, which consist of many fine, insulated wires bundled together to reduce electrical resistance at high frequencies. The patent states that if one of these fine wires breaks, a significant voltage difference can arise between the broken wire and its neighbors, potentially causing a spark that damages the coil (’269 Patent, col. 1:42-47). The proposed solution is to electrically short all the wires in the bundle together at predetermined intervals along the coil's length, which equalizes the potential and prevents sparks from forming (’269 Patent, Abstract).
• Asserted Claims: Independent claim 1 (Compl. ¶23).
• Accused Features: The complaint makes a general allegation that the Accused Products infringe (Compl. ¶22).

U.S. Patent No. 10,491,043 - "Resonant coil, wireless power transmitter using the same, wireless power receiver using the same"

Issued November 26, 2019

• Technology Synopsis: As a continuation of the application that led to the ’269 Patent, this patent targets the same technical problem of potential sparking in multi-wire litz coils used for wireless power transfer (’043 Patent, col. 1:45-49). The invention is a resonant coil where the plurality of insulated wires forming the coil are shorted together at a predetermined interval (’043 Patent, Abstract).
• Asserted Claims: Independent claim 1 (Compl. ¶29).
• Accused Features: The complaint makes a general allegation that the Accused Products infringe (Compl. ¶28).

U.S. Patent No. 10,476,160 - "Wireless antenna for wireless charging and NFC communication and wireless terminal to which same is applied"

Issued November 12, 2019

• Technology Synopsis: This patent, along with the co-asserted ’426 and ’592 Patents, describes a specific nested antenna architecture for combining wireless charging and NFC functions while mitigating interference. The design comprises an outer (first) wireless communication coil and an inner (second) wireless communication coil, with a wireless charging coil disposed between them (’160 Patent, Abstract). The two communication coils are electrically connected to function as a single NFC antenna, while the charging coil operates independently.
• Asserted Claims: Independent claim 1 (Compl. ¶35).
• Accused Features: The complaint makes a general allegation that the Accused Products infringe (Compl. ¶34).

U.S. Patent No. 10,461,426 - "Wireless antenna for wireless charging and NFC communication and wireless terminal to which same is applied"

Issued October 29, 2019

• Technology Synopsis: This patent claims a similar nested antenna structure for dual-mode operation, including a first (outer) NFC coil, a second (inner) NFC coil, and a charging coil located between them. A key feature is a "coil connection member traversing the wireless charging coil" to interconnect the two NFC coils, allowing them to function together while being physically separated by the charging coil (’426 Patent, Abstract).
• Asserted Claims: Independent claim 1 (Compl. ¶41).
• Accused Features: The complaint makes a general allegation that the Accused Products infringe (Compl. ¶40).

U.S. Patent No. 10,727,592 - "Wireless antenna for wireless charging and NFC communication and wireless terminal to which same is applied"

Issued July 28, 2020

• Technology Synopsis: This patent is also directed to the nested antenna structure for simultaneous wireless charging and NFC. It describes a wireless charging coil disposed inside a first wireless communication coil, and a second wireless communication coil disposed inside the wireless charging coil (’592 Patent, Abstract). This concentric arrangement is intended to optimize performance and minimize the antenna's footprint.
• Asserted Claims: Independent claim 1 (Compl. ¶47).
• Accused Features: The complaint makes a general allegation that the Accused Products infringe (Compl. ¶46).

III. The Accused Instrumentality

Product Identification

• The complaint identifies a broad range of Samsung mobile devices, including the Galaxy S-series (S7 to S21), Note-series (Note 8 to Note 20), and foldable devices (Fold, Z Flip, Z Fold2, Z Fold3, Z Flip3) (Compl. ¶10).

Functionality and Market Context

• The complaint alleges these products are capable of wireless charging and accuses them of infringement without providing specific technical details about their internal construction or operation (Compl. ¶¶10, 11, 16, 17). The complaint references claim chart exhibits that purport to provide this comparison, but these exhibits were not filed with the complaint itself (Compl. ¶¶11, 17). The complaint does not provide sufficient detail for analysis of the specific functionality of the accused products beyond their general capability for wireless charging.

IV. Analysis of Infringement Allegations

The complaint alleges that representative claim charts are attached as exhibits but does not include them in the provided filing. Therefore, the narrative infringement theory is summarized below. No probative visual evidence provided in complaint.

• '364 Patent Infringement Allegations
  • The complaint asserts that the Accused Products "satisfy all claim limitations of one or more claims of the ’364 Patent" (Compl. ¶11). The narrative does not specify how the physical structure of the accused devices meets the claimed arrangement of a receiving coil within a "reception space" on a PCB, surrounded by a communication antenna.
• '666 Patent Infringement Allegations
  • The complaint makes a similar conclusory allegation that the Accused Products "satisfy all claim limitations of one or more claims of the ’666 Patent" (Compl. ¶17). The narrative provides no facts explaining how the accused devices embody the claimed multi-layer board structure with embedded coils and a shielding unit.
• Identified Points of Contention:
  • Structural Questions: A primary point of contention for the ’364 and ’666 Patents will be factual and structural. The analysis will depend on evidence from device teardowns to determine if the physical arrangement of Samsung's coils, antennas, and PCBs matches the specific spatial relationships required by the claims (e.g., "in the reception space," "surrounding the receiving coil," "disposed between the plurality of layers").
  • Scope Questions: The interpretation of claim terms will be central. For the ’364 Patent, a key question is whether a designated area on the surface of a standard PCB constitutes a "reception space," or if the term requires a physical recess or cutout. For the ’666 Patent, a dispute may arise over whether components mounted on the surface of a multi-layer board are "disposed in the board" as required by the claim, or if the claim requires full embedment within the board's laminate structure.

V. Key Claim Terms for Construction

For the ’364 Patent:

• The Term: "reception space"
• Context and Importance: This term defines the location and nature of the area on the PCB where the receiving coil is placed. Its construction is critical because it may determine whether conventional surface-mounting of a coil on a PCB infringes, or if the claim is limited to a more specific configuration, such as placing the coil within a physical cavity in the board. Practitioners may focus on this term because its scope will likely be a dispositive issue for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not provide an explicit definition for "reception space," which could support an argument that the term should be given its plain and ordinary meaning, potentially covering any area on the board designated for the coil.
  • Evidence for a Narrower Interpretation: Figure 6 of the patent depicts the receiving coil (310) being placed into a cutout area (A) within the body of the printed circuit board (301). The specification repeatedly describes the coil as "disposed in the reception space A of the printed circuit board" (’364 Patent, col. 4:60-62), which may support a narrower construction requiring a physical depression or void.

For the ’666 Patent:

• The Term: "disposed in the board"
• Context and Importance: This term, used for the receiving coil, communication coil, and shielding unit, is central to the claimed invention. The dispute will likely focus on whether this requires the components to be physically embedded within the laminated layers of the board or if it can read on components integrated into the overall board assembly (e.g., placed in a cavity and insert-molded). The outcome of this construction will define the scope of the patent relative to common electronics manufacturing techniques.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that "in the board" could encompass being placed within a cavity or recess that is part of the overall board structure, not strictly between laminated layers.
  • Evidence for a Narrower Interpretation: Claim 1 further requires that the components are "disposed between the plurality of layers." The specification also describes a process where the shielding unit "is inserted into the printed circuit board" during its fabrication (’666 Patent, col. 8:47-52). This language, along with Figure 10, suggests a structure where components are fully embedded within the board's layered construction, supporting a narrower interpretation.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. The prayer for relief requests a finding of an "exceptional case" for the purpose of awarding attorneys' fees under 35 U.S.C. § 285, but does not plead the knowledge or intent required for enhanced damages under 35 U.S.C. § 284 (Compl. p. 12, ¶e).

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

1. A core issue will be one of structural interpretation: Does the physical assembly of the wireless charging and NFC components in Samsung's devices meet the specific spatial and structural limitations of the asserted claims? This will likely require detailed expert analysis of device teardowns to determine if components are "in a reception space" or "disposed between... layers" of a board, as opposed to being mounted on a surface or in a separate carrier.
2. A second key question will be one of claim scope: Can terms like "reception space" and "disposed in the board", which are described in the patents with specific exemplary embodiments, be construed broadly enough to cover the conventional manufacturing and assembly techniques used in high-volume consumer electronics? The court’s construction of these terms will likely be dispositive.
3. A third question will be one of technical differentiation: For the patents directed at nested antenna structures and litz coils, the case may turn on whether the accused devices achieve dual-functionality and reliability through the specific patented designs or through alternative, non-infringing technical means.