DCT
2:22-cv-00099
Village Green Tech LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Village Green Technologies, LLC (California)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (Delaware / Texas)
- Plaintiff’s Counsel: Brundidge & Stanger, P.C.
- Case Identification: 2:22-cv-00099, E.D. Tex., 03/31/2022
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Defendant Samsung Electronics America, Inc. having a regular and established place of business in Plano, Texas, and having offered for sale and sold the accused products within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Galaxy Fold" and "Galaxy Flip" families of foldable smartphones infringe two patents related to methods and apparatuses for managing applications across multiple displays on a portable electronic device.
- Technical Context: The technology addresses user interface and functionality management for dual-screen portable devices, a key feature in the premium foldable smartphone market.
- Key Procedural History: The complaint alleges that Samsung had prior knowledge of the patents-in-suit, which may form the basis for a claim of willful infringement. No other significant procedural events are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2009-07-07 | Earliest Priority Date for '401 & '663 Patents |
| 2018-01-09 | U.S. Patent No. 9,864,401 Issued |
| 2020-04-14 | U.S. Patent No. 10,620,663 Issued |
| 2022-03-31 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,864,401 - Multiple Displays for a Portable Electronic Device and a Method of Use, Issued January 9, 2018
The Invention Explained
- Problem Addressed: The patent's background section identifies the small physical size of a single display on portable devices as a "major limitation" that prevents the simultaneous use of multiple applications, a common capability on desktop computers. Prior art solutions for dual-screen devices are characterized as "bulky" and interfering with portability (’401 Patent, col. 2:6-31).
- The Patented Solution: The invention discloses a portable device with a primary and a deployable secondary display. The system is designed to have two distinct mechanical arrangements: one where the secondary display is "stowed" (e.g., folded away and protected), and another where it is deployed to be "substantially coplanar and adjacent" to the primary screen. This configuration permits the device to run "at least two programs running simultaneously, each with its own visual user-interface operating on its own display," effectively bringing desktop-style multitasking to a portable form factor (’401 Patent, Abstract; col. 3:27-46).
- Technical Importance: The described technology sought to bridge the gap between the portability of mobile devices and the multitasking power of desktop computers, allowing users to interact with multiple applications without a significant compromise in device size or convenience (’401 Patent, col. 2:17-24).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 5, 8-10, and 17 (Compl. ¶20).
- Independent Claim 1 requires:
- A portable device with a primary and a secondary display integrated with the device.
- The secondary display is "physically protected when stowed."
- The secondary display "runs a second application, while the primary display runs a first application" in one of a plurality of operating modes.
- Both displays are visible to the user at the same time during certain operating modes.
- The act of deploying the secondary display causes a "second software application to launch" and display a graphical user interface.
- A "second screen display stack is created when the secondary display is deployed."
U.S. Patent No. 10,620,663 - Multiple Displays for a Portable Electronic Device and a Method of Use, Issued April 14, 2020
The Invention Explained
- Problem Addressed: As a continuation in the same family, the ’663 Patent addresses the same core problem of limited display real estate and multitasking capabilities on portable devices (’663 Patent, col. 2:6-31).
- The Patented Solution: The invention again describes a dual-display portable device with stowed and deployed configurations. The '663 patent further elaborates on the interaction between the two displays. A key aspect is a bidirectional, context-sensitive link: a user's selection of information on the primary display can cause "second information related to said first information" to appear on the secondary display, and a selection on the secondary display can likewise cause "fourth information related to the third information" to appear on the primary display (’663 Patent, col. 15:55-col. 16:3).
- Technical Importance: This patent extends the concept beyond simply adding a second screen, detailing an integrated system where the two displays can interact and pass information contextually, creating a more cohesive and powerful dual-screen user experience (’663 Patent, col. 6:46-59).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 24, along with numerous dependent claims (Compl. ¶29).
- Independent Claim 1 requires:
- A portable device with a primary and secondary display.
- The secondary display is "physically protected when stowed."
- The secondary display runs a "second application" while the primary runs a "first application."
- Both displays are viewable by a user in certain operating modes.
- When a user selects "first information in the primary display," it causes the secondary display to show "second information related to said first information."
- When a user selects "third information in the secondary display," it causes the primary display to show "fourth information related to the third information."
III. The Accused Instrumentality
Product Identification
The "Galaxy Fold" and "Galaxy Flip" product families of smartphones (Compl. ¶13).
Functionality and Market Context
The complaint alleges these are smartphones featuring a primary and a secondary display connected by a hinge (Compl. ¶¶20, 29). The devices are alleged to operate in modes such as "Split Screen View" and "Multi window mode," which allow a user to run a first application (e.g., a calendar) on the primary display while simultaneously running a second application (e.g., a reminder) on the secondary display (Compl. ¶¶20, 29). The complaint further alleges that these modes allow a user to "select information being displayed on one of the displays to cause a display of information in the other of the displays" (Compl. ¶¶20, 29). This functionality is a defining characteristic of the high-end foldable smartphone market segment.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'401 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a portable device comprising: a primary display and a secondary display; wherein the secondary display is integrated... | The Galaxy Fold and Galaxy Z Flip are portable devices that comprise a primary and secondary display integrated with the smartphone by a hinge. | ¶20, ¶21, ¶29, ¶30 | col. 4:8-15 |
| the secondary display is physically protected when stowed | The secondary display is physically protected when the smartphone is in the folded position, which is alleged to be the "stowed" position. | ¶20, ¶21 | col. 3:30-34 |
| the secondary display runs a second application, while the primary display runs a first application... | The Galaxy Fold/Flip runs a second application (e.g., reminder) on its secondary display while the primary runs a first application (e.g., calendar) when using "Split Screen View" or "Multi window mode." | ¶20, ¶21 | col. 2:40-52 |
| wherein the act of deploying the secondary display causes a second software application to launch... | The complaint does not provide sufficient detail for analysis of this specific element. | col. 5:48-54 | |
| wherein a second screen display stack is created when the secondary display is deployed... | The complaint alleges that after an application is opened, it is added to a "Recent apps" stack, which the user can access and from which the user can select an app to be displayed on the secondary display. | ¶20, ¶21 | col. 10:48-52 |
'663 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a portable device comprising: a primary display and a secondary display | The Galaxy Fold and Galaxy Z Flip are portable devices that comprise a primary and secondary display. | ¶29, ¶30 | Abstract |
| the secondary display is physically protected when stowed | The secondary display is physically protected when the smartphone is in the folded position, which is alleged to be the "stowed" position. | ¶29, ¶30 | col. 3:30-34 |
| the secondary display runs a second application, while the primary display runs a first application... | The Galaxy Fold/Flip runs a second application (e.g., reminder) on its secondary display while the primary runs a first application (e.g., calendar) in "Multi window mode." | ¶29, ¶30 | col. 2:40-52 |
| when the user of the device selects or identifies...first information in the primary display, said action causes the secondary display to display second information related to said first information... | It is alleged that both applications are visible, "thereby allowing the user to select information being displayed on one of the displays to cause a display of information in the other of the displays." | ¶29, ¶30 | col. 6:46-59 |
| and when the user of the device selects or identifies...third information in the secondary display, the action causes the primary display to display fourth information related to the third information... | The same general allegation of cross-display interaction is made, which appears intended to cover the reciprocal action required by this limitation. | ¶29, ¶30 | col. 6:46-59 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over whether Samsung's "Split Screen View" or "Multi window mode" (Compl. ¶¶20, 29) meets the definition of a "first application" and a "second application" as contemplated by the patents. The defense could argue that this is a single operating system managing two views or windows, not two distinct applications running as claimed.
- Technical Questions: For the ’663 Patent, the complaint makes a general assertion about selecting information on one display to cause a change on the other (Compl. ¶29). A key question for the court will be whether the accused devices' actual operation demonstrates the specific, bidirectional, and related information transfer required by Claim 1. The complaint's evidence, such as accessing a "Recent apps" list (Compl. ¶29), may not map directly to the claimed functionality of selecting substantive information within one application to trigger a display of related information in another.
V. Key Claim Terms for Construction
The Term: "second application"
- Context and Importance: This term is fundamental to the infringement theory for both patents. Its construction will determine whether a feature like "Split Screen View," where an operating system may manage two windows, qualifies as two separate applications running simultaneously. Practitioners may focus on this term because the patents’ vision of two distinct programs could be contrasted with modern mobile OS architecture.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification contemplates that a "second application" can include a "second display window managed by the same program or module that is displaying information on the first display" (’663 Patent, col. 6:15-18), which may support an argument that different views controlled by one OS satisfy the limitation.
- Evidence for a Narrower Interpretation: The abstract and summary repeatedly refer to "at least two programs running simultaneously, each with its own visual user-interface operating on its own display" (’663 Patent, Abstract), which suggests two independent, stand-alone software programs, a potentially narrower construction.
The Term: "stowed"
- Context and Importance: The claims require the secondary display to be "physically protected when stowed." The complaint equates this with the "folded position" of the accused devices (Compl. ¶20). The interpretation of "stowed" is therefore critical for establishing the baseline, non-infringing state of the device.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional definition, describing the stowed state as "out of the way mechanically and visually, when only a first display is in use" (’663 Patent, Abstract).
- Evidence for a Narrower Interpretation: The patent figures and detailed description tie the "stowed" position to specific physical configurations, such as being folded closed (Fig. 1A), rotated behind (Fig. 2A), or slid into the device body (Fig. 3A), suggesting the term requires a specific state of concealment beyond just being powered off (’663 Patent, col. 4:8-10, 19-21, 28-30).
The Term: "selects...information...related to" (’663 Patent only)
- Context and Importance: This phrase in the '663 patent’s independent claims defines the required interactive link between the two displays. The infringement case for this patent depends on whether the accused devices perform this specific type of context-sensitive data exchange.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent provides a lengthy and diverse list of examples, including selecting a web link, a contact name, a map location, or an email attachment, suggesting the term covers a wide variety of user interactions (’663 Patent, col. 15:1-68).
- Evidence for a Narrower Interpretation: The term "related to" may be construed to require a direct substantive link between the selected and displayed information (e.g., an email and its attachment), potentially excluding more general navigational actions like opening an unrelated application from a task manager.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Samsung providing user manuals, such as the "Galaxy Fold User Manual," that allegedly instruct customers on how to use the infringing features and methods (Compl. ¶¶17, 20, 22).
- Willful Infringement: The complaint makes a general allegation that Samsung acted despite having "prior knowledge, should have known, or at least been willfully blind" of the patents-in-suit (Compl. ¶12). The complaint does not specify the basis for this alleged pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional equivalence: Do Samsung's "Split Screen View" and "Multi window mode" features operate in a way that is technically equivalent to the claimed system of a "first application" and a "second application" each running on its own display, or does the underlying OS architecture create a fundamental mismatch with the patent's description?
- A key evidentiary question for the '663 patent will concern causal linkage: What specific evidence will demonstrate that the accused devices perform the bidirectional interaction required by Claim 1, where selecting substantive "information" on one screen (e.g., an address in an email) causes "related" information to appear on the other (e.g., a map of that address), and vice-versa?
- The case may also turn on a question of definitional scope: Can the term "second application," as described in a 2009-era patent, be construed to read on a modern, integrated mobile operating system's method of managing multiple application windows on a single, foldable display surface?