DCT
2:22-cv-00367
Kim v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Seungman Kim (Virginia)
- Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Loevy & Loevy; Wilson, Robertson & Cornelius, P.C.
- Case Identification: 2:22-cv-00367, E.D. Tex., 03/13/2023
- Venue Allegations: Venue is alleged as proper for Samsung Electronics America, Inc. based on its regular and established place of business in Plano, Texas, within the district. Venue is alleged as proper for Samsung Electronics Co., Ltd. as a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy phones and other models featuring "Smart Lock" functionality infringe eight U.S. patents related to selectively applying or bypassing a device's security mode based on predefined conditions.
- Technical Context: The technology addresses context-aware security for mobile devices, which aims to balance user convenience with data protection by automatically disabling password requirements in trusted environments.
- Key Procedural History: This First Amended Complaint follows an original complaint. The asserted patents are all part of a single, large family of continuing applications stemming from an application filed in 2014. The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-17 | Earliest Priority Date for all Asserted Patents |
| 2015-01-01 | Alleged "Smart Lock" feature included in Samsung phones "since 2015" |
| 2016-11-29 | U.S. Patent No. 9,509,822 Issued |
| 2018-05-15 | U.S. Patent No. 9,973,929 Issued |
| 2018-09-25 | U.S. Patent No. 10,085,151 Issued |
| 2018-10-23 | U.S. Patent No. 10,111,098 Issued |
| 2018-12-04 | U.S. Patent No. 10,149,164 Issued |
| 2019-05-21 | U.S. Patent No. 10,299,133 Issued |
| 2021-11-23 | U.S. Patent No. 11,184,771 Issued |
| 2023-01-10 | U.S. Patent No. 11,553,072 Issued |
| 2023-03-13 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,509,822 - "Electronic Apparatus and Method of Selectively Applying Security in Mobile Device"
The Invention Explained
- Problem Addressed: The patent's background describes the inconvenience for a user who must repeatedly input a security code (e.g., a password or gesture) to access a mobile device, even when in a "security safe zone" where such security is unnecessary. To avoid this, a user would have to manually disable and later re-enable the security mode. (’822 Patent, col. 1:31-42).
- The Patented Solution: The invention provides a system for selectively applying the security mode based on a predefined "exceptional condition." This condition can be a "safe zone" defined by both an "area condition" (e.g., a specific location like a house) and a "wireless communication condition" (e.g., connection to a specific external network like a home Wi-Fi device). When the device detects it is within this safe zone, it changes from a power-saving mode to a normal mode without requiring the user to enter a password. (’822 Patent, Abstract; col. 2:7-24).
- Technical Importance: This approach provides automated, context-aware security that enhances user convenience by removing repetitive authentication steps in trusted environments while maintaining security elsewhere. (’822 Patent, col. 1:43-50).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 19. (Compl. ¶18). Independent claim 1 includes the following essential elements:
- An interface to receive user input and wirelessly communicate with an external network.
- A switch to change the device from a power saving mode to a normal mode.
- A display unit.
- A control unit configured to:
- set a password as a security mode;
- set an "exceptional condition" as a "safe zone," where the condition comprises both a wireless communication condition and an area condition;
- not display a password screen and change to normal mode without the password when the device is in the area condition and wirelessly communicates with the external network; and
- display the password screen and change to normal mode by receiving the password when the device is not in the area condition or does not wirelessly communicate with the external network.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 9,973,929 - "Electronic Apparatus and Method of Selectively Applying Security in Mobile Device"
The Invention Explained
- Problem Addressed: The patent addresses the same problem as the ’822 Patent: the repetitive and inconvenient need for users to enter security codes to unlock their mobile devices, even when in a trusted or safe environment. (’929 Patent, col. 1:30-41).
- The Patented Solution: The ’929 Patent, a continuation of the application leading to the ’822 Patent, also describes a method for selectively applying a security mode. It claims a method where a mobile device sets an "exceptional condition" as a "safe zone" based on a wireless communication condition and an area condition. When the device's current location and communication status match this condition, it can be changed from a power-saving to a normal mode without requiring a password; otherwise, the password is required. (’929 Patent, Abstract; col. 2:5-24).
- Technical Importance: This method provides a framework for implementing context-aware security features that improve the user experience of mobile devices by intelligently managing lock-screen authentication. (’929 Patent, col. 1:50-54).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 18. (Compl. ¶20). Independent claim 1 recites a method with the following essential steps:
- Receiving a user input and wirelessly communicating with an external network.
- Changing the mobile device from a power saving mode to a normal mode via a switch.
- Setting a password as a security mode.
- Setting an "exceptional condition" as a "safe zone," comprising a wireless communication condition and an area condition.
- Not displaying a password screen and changing to normal mode without the password when the device's location matches the area condition and its wireless communication matches the wireless communication condition.
- Displaying the password screen and changing to normal mode by receiving the password when the location does not match the area condition or the wireless communication does not match the wireless communication condition.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,085,151 - "Electronic Apparatus and Method of Selectively Applying Security Mode According to Exceptional Condition in Mobile Device"
- Technology Synopsis: This patent describes a mobile device with a control unit that sets an "exceptional condition" as a "safe zone" based on an external network and an area condition. The device selectively applies a security mode, bypassing a password prompt when the safe zone conditions are met and requiring it otherwise. (’151 Patent, Abstract).
- Asserted Claims: Independent claim 1. (Compl. ¶22).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
U.S. Patent No. 10,111,098 - "Electronic Apparatus and Method of Selectively Applying Security Mode According to Exceptional Condition in Mobile Device"
- Technology Synopsis: This patent claims a method for a mobile device to selectively bypass its security mode. The method involves setting an "exceptional condition" (comprising a wireless communication and an area condition) as a "safe zone" and foregoing a password requirement when the device's current state matches that condition. (’098 Patent, Abstract).
- Asserted Claims: Independent claim 1. (Compl. ¶24).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
U.S. Patent No. 10,149,164 - "Electronic Apparatus and Method of Selectively Applying Security Mode According to Exceptional Condition in Mobile Device"
- Technology Synopsis: This patent describes a mobile device where a control unit selectively applies a "security check process." The device is configured to set an "exceptional condition" based on wireless communication and area conditions, and it bypasses the security check when those conditions are met. (’164 Patent, Abstract).
- Asserted Claims: Independent claims 1 and 19. (Compl. ¶26).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
U.S. Patent No. 10,299,133 - "Electronic Apparatus and Method of Selectively Applying Security Mode According to Exceptional Condition in Mobile Device"
- Technology Synopsis: This patent claims a method for a mobile device to apply a security check process based on an "exceptional condition." The condition includes wireless communication and area components, and meeting it allows the device to bypass the normal password requirement. (’133 Patent, Abstract).
- Asserted Claims: Independent claims 1 and 19. (Compl. ¶28).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
U.S. Patent No. 11,184,771 - "Electronic Apparatus and Method of Selectively Applying Security Mode in Mobile Device"
- Technology Synopsis: This patent claims a computer-readable medium with instructions for a method of unlocking a mobile device. The method allows unlocking via a password in a standard security mode or unlocking without a password based on an "exceptional condition" comprising wireless communication and area conditions. (’771 Patent, Abstract).
- Asserted Claims: Independent claims 1 and 20. (Compl. ¶30).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
U.S. Patent No. 11,553,072 - "Electronic Apparatus and Method of Selectively Applying Security Mode in Mobile Device"
- Technology Synopsis: This patent describes a mobile device that performs a first process in normal mode to set area and wireless communication conditions, and a second process in power-saving mode to unlock the device according to those preset conditions. (’072 Patent, Abstract).
- Asserted Claims: Claims 1-4, 6-8, 12-18, 20. (Compl. ¶32).
- Accused Features: The "Smart Lock" functionality in Samsung phones. (Compl. ¶1).
III. The Accused Instrumentality
Product Identification
All Samsung Galaxy and other phone models that include "Smart Lock" functionality, which the complaint alleges has been included in Samsung phones since 2015. (Compl. ¶¶1, 8).
Functionality and Market Context
The complaint alleges that the "Smart Lock" feature allows a user to designate a "trusted place" and/or a "trusted device." (Compl. ¶9). When this feature is enabled, the user can bypass the standard password requirement to unlock the phone if the device is either located in the trusted place or connected to the trusted device, provided less than four hours has elapsed since the last manual unlock. (Compl. ¶9). The complaint states that trusted places include locations defined by a line on a map and trusted devices include Bluetooth devices. (Compl. ¶¶13-14). The accused products are alleged to have processors configured to implement this logic, detecting the device's location, its connection to trusted devices, and its connection to Wi-Fi or carrier networks. (Compl. ¶¶12, 15-16).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’822 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a control unit: configured to set a password as a security mode and to set an exceptional condition as a safe zone of the security mode, wherein the exceptional condition comprises a wireless communication condition and an area condition | Accused Products are configured to display a Smart Lock menu for selecting a "trusted place" and/or a "trusted device" to bypass password entry. | ¶¶9, 11 | col. 2:7-12 |
| configured to not display a screen on the display unit to receive the password...without the password...when the mobile device is in the area condition and when the mobile device wirelessly communicates with the external network... | Accused Products have a processor configured to not require a password when a trusted place has been selected and the phone is located there, or when a trusted device is selected and the phone is connected to it. | ¶¶15, 16 | col. 2:15-21 |
| configured to display the screen on the display unit to receive the password...by receiving the password...when the mobile device is not in the area condition or when the mobile device does not wirelessly communicate with the external network... | By implication, the Accused Products require a password when not in a trusted place or connected to a trusted device. | ¶9 | col. 2:21-24 |
’929 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| setting a password as a security mode, and setting an exceptional condition as a safe zone of the security mode, wherein the exceptional condition comprises a wireless communication condition and an area condition | Accused Products allow a user to set a password and to configure "Smart Lock" with "trusted places" and "trusted devices" that act as safe zones. | ¶¶9, 10, 11 | col. 2:5-10 |
| not displaying a screen to receive the password...without the password...when a current location of the mobile device matches the area condition and when a current wireless communication of the mobile device matches the wireless communication condition | Accused Products have a processor configured not to require a password when the phone is in a selected trusted place (area condition) and connected to a network, or connected to a trusted device (communication condition). | ¶¶15, 16 | col. 2:10-16 |
| displaying the screen...by receiving the password...when the current location of the mobile device does not match the area condition or when the current wireless communication of the mobile device does not match the wireless communication condition | The complaint alleges the phone requires a password to unlock except under the specific "Smart Lock" conditions, implying password entry is the default. | ¶9 | col. 2:16-22 |
Identified Points of Contention:
- Scope Questions: A central question may be whether the patents' requirement for an "exceptional condition" comprising both an "area condition" and a "wireless communication condition" reads on the accused "Smart Lock" feature. The complaint alleges Smart Lock operates when a device is in a trusted location or connected to a trusted device (Compl. ¶9), which suggests two independent and alternative conditions rather than the combined condition required by the claims. The interpretation of the logical "and" in the claims versus the alleged "or" in the accused functionality could be a key point of dispute.
- Technical Questions: The complaint provides a high-level, user-facing description of Smart Lock but lacks detailed technical evidence of its implementation. A key factual question will be how Samsung's devices technically determine they are in a "trusted place" (e.g., GPS, cell tower triangulation, Wi-Fi network scanning) and how that mechanism maps to the "area condition" as described in the patent specifications. Similarly, evidence will be needed to show how connection to a "trusted device" meets the "wireless communication condition" limitation.
V. Key Claim Terms for Construction
The Term: "exceptional condition"
Context and Importance: This term is the core of the invention, defining the specific circumstances under which the security mode is bypassed. The entire infringement case hinges on whether Samsung’s "Smart Lock" criteria (e.g., being in a "trusted place" or near a "trusted device") fall within the legal scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification introduces the term broadly, stating the control unit is configured "to set an exceptional condition as a safe zone of the security mode." (’822 Patent, col. 2:9-10). This language does not inherently limit the types of conditions that may qualify.
- Evidence for a Narrower Interpretation: The claims explicitly define the term as comprising two distinct components: "a wireless communication condition and an area condition." (’822 Patent, cl. 1). Embodiments describe these conditions being met by, for example, a device being inside a house and communicating with a home Wi-Fi network, suggesting the two are co-dependent rather than alternative. (’822 Patent, col. 2:25-33).
The Term: "area condition"
Context and Importance: This term directly maps to the plaintiff's allegation regarding "trusted places." Its construction will determine whether location-based triggers, potentially determined by GPS or other means, are covered by the patent, which often describes the area in the context of wireless signal range. Practitioners may focus on this term because the complaint alleges trusted places are "defined by a line on a map" (Compl. ¶14), which mirrors language in the patent specification. (’151 Patent, col. 2:33-34).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the "area condition may include a home or an environment" and "an area defined by a line." (’151 Patent, col. 2:31-34). This could support an interpretation that covers any geographically defined zone, such as one set by a user on a map interface.
- Evidence for a Narrower Interpretation: The specification frequently links the area condition to the presence of an external network, stating it "may be associated with the data signal of the external network." (’151 Patent, col. 2:28-30). This could support an argument that the "area" is not merely a geographic coordinate but is defined by the functional range of a specific wireless signal, such as a Wi-Fi access point.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain counts for indirect infringement under 35 U.S.C. § 271(b) or (c). The infringement counts are explicitly limited to direct infringement under § 271(a). (Compl. ¶¶18, 20, 22, 24, 26, 28, 30, 32).
- Willful Infringement: The complaint does not allege willful infringement or plead facts suggesting that the defendant had pre-suit knowledge of the asserted patents.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and logic: do the asserted claims, which require an "exceptional condition" comprising both an "area condition" and a "wireless communication condition," cover the accused "Smart Lock" feature, which is alleged to operate when a device is in a trusted location or connected to a trusted device? The dispute may focus on whether these are conjunctive versus disjunctive conditions.
- A second central question will be one of technical implementation: what is the underlying mechanism by which the accused products determine they are in a "trusted place"? The case will likely require discovery into whether this feature operates based on GPS coordinates, as user-facing map interfaces might suggest, or based on proximity to specific wireless networks as described in the patents' embodiments, and whether this difference creates a functional mismatch with the claimed invention.