DCT

2:22-cv-00398

Mojo Mobility Inc v. Samsung Electronics Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-00398, E.D. Tex., 04/11/2023
  • Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics America (SEA) because it has a regular and established place of business in Plano, Texas, within the district. Venue is alleged to be proper for Samsung Electronics Co. (SEC) on the basis that it is a foreign entity.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, wireless chargers, and related mobile devices infringe seven patents related to wireless inductive charging technology.
  • Technical Context: The patents concern systems and methods for inductive power transfer, a technology that allows electronic devices to be charged without physical cables and is widely used in consumer electronics.
  • Key Procedural History: The complaint alleges a history of pre-suit interaction between the parties, beginning in 2013, wherein Plaintiff presented its wireless charging technology and prototypes to Defendant. Plaintiff alleges that despite these disclosures and Defendant’s knowledge of Plaintiff’s patent applications, subsequent licensing discussions failed, and Defendant proceeded to incorporate the patented technology into its products without payment.

Case Timeline

Date Event
2006-01-31 Earliest Priority Date for ’208, ’371, ’500, and ’942 Patents
2007-01-30 Earliest Priority Date for ’440 Patent
2011-01-18 Earliest Priority Date for ’777 Patent
2011-05-24 ’208 Patent Issued
2013-01-01 Pre-suit interactions alleged to have begun (approximate date)
2013-04-12 Earliest Priority Date for ’349 Patent
2016-01-01 Accused Product launches begin (approximate date)
2017-02-21 ’440 Patent Issued
2021-12-14 ’500 Patent Issued
2022-04-05 ’349 Patent Issued
2022-04-26 ’371 Patent Issued
2022-05-24 ’777 Patent Issued
2022-10-04 ’942 Patent Issued
2023-04-11 First Amended Complaint Filed

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

U.S. Patent No. 7,948,208 - “Power Source, Charging System, and Inductive Receiver for Mobile Devices” (issued May 24, 2011)

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inconvenience caused by the proliferation of mobile devices, each requiring its own specific wired charger, creating a burden for users. (’208 Patent, col. 1:19-42).
  • The Patented Solution: The invention proposes a "universal" wireless charging pad with a plurality of primary coils. A communications interface polls the coils to detect the presence of a device, determines which primary coil is best aligned with the device's receiver coil, and then selectively activates only that coil to transfer power efficiently. (’208 Patent, col. 3:5-24, Abstract). This selective activation allows for positional freedom while conserving energy.
  • Technical Importance: This approach provided a technical foundation for "drop-and-charge" wireless charging surfaces that do not require precise alignment by the user. (’208 Patent, col. 3:5-13).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶37).
  • Essential elements of Claim 1 include:
    • A charger system with a base unit having a surface and a plurality of primary coils arranged behind it.
    • Each primary coil is associated with a switching circuit capable of selective activation.
    • A communications interface that polls the primary coils to verify the presence of a mobile device.
    • The interface selects and activates only the primary coil(s) determined to be "most closely aligned" with the device's receiver coil.
    • The system uses current modulation to regulate output voltage, current, or power.
  • The complaint reserves the right to assert additional claims. (Compl. ¶38).

U.S. Patent No. 9,577,440 - “Inductive Power Source and Charging System” (issued February 21, 2017)

The Invention Explained

  • Problem Addressed: The patent addresses the need for a universal inductive charging system that can power or charge different mobile devices which have different charging characteristics. (’440 Patent, col. 1:21-27).
  • The Patented Solution: The invention is a mobile device configured for use with a universal base unit. The device contains a receiver coil, a battery, and an "identification component" that wirelessly communicates the device's specific charging characteristics to the base unit. (’440 Patent, col. 3:35-51). This allows the base unit to tailor the power transfer to the specific needs of the device, enabling a single charger to support a variety of devices.
  • Technical Importance: This device-centric approach enables interoperability, where devices actively report their power needs to a universal charger, a key concept behind industry standards like Qi. (’440 Patent, Abstract).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 3. (Compl. ¶69).
  • Essential elements of Claim 1 (a mobile device) include:
    • A battery and a receiver coil.
    • An identification component configured to provide wireless identification to a universal base unit.
    • A means for avoiding overcharging.
    • A regulator to control the output voltage or current.
    • Functionality wherein the receiver communicates its characteristics to the base unit for tailored power transfer.
  • Essential elements of Claim 3 (a system) include:
    • A universal base unit with one or more primary coils.
    • A mobile device with a receiver, an identification component, a means for avoiding overcharging, and a regulator.
    • Functionality for the receiver to communicate with the base unit to detect, identify, authenticate, and provide its characteristics.
  • The complaint reserves the right to assert additional claims. (Compl. ¶70, 123).

U.S. Patent No. 11,292,349 - “System and Method for Powering or Charging Receivers or Devices Having Small Surface Areas or Volumes” (issued April 5, 2022)

  • Technology Synopsis: This patent addresses the technical challenges of wirelessly charging very small devices, such as a stylus pen. The solution involves a charger with a patterned coil and a receiver that includes a solenoid (a wire wrapped around a magnetic core) to efficiently capture magnetic flux in a small form factor. (’349 Patent, col. 1:10-15, Abstract). The complaint mentions that this patent was subject to Inter Partes Review proceedings where several claims, including asserted claims 1 and 26, were cancelled. (’349 Patent, Inter Partes Review Certificate).
  • Asserted Claims: Claims 1 and 26. (Compl. ¶125).
  • Accused Features: The system for inductively charging the Samsung S Pen when it is placed in the housing of the Samsung Galaxy S22 Ultra smartphone. (Compl. ¶126-127).

U.S. Patent No. 11,316,371 - “System and Method for Inductive Charging of Portable Devices” (issued April 26, 2022)

  • Technology Synopsis: This patent details the specific circuitry of an inductive power system. It describes an apparatus (transmitter) with a primary coil, a drive circuit (FET driver, capacitor, switch), a sense circuit (low pass filter, amplifier), and a control circuit (microcontroller) that work together to detect and regulate power transfer to a portable device based on communications received via current modulation. (’371 Patent, Abstract, col. 2:44-53).
  • Asserted Claims: Claims 1 and 20. (Compl. ¶151).
  • Accused Features: The Samsung Galaxy S22 Ultra, particularly its "Wireless PowerShare" feature, which allows the smartphone to act as a wireless charging pad for other devices. (Compl. ¶152, 154).

U.S. Patent No. 11,201,500 - “Efficiencies and Flexibilities in Inductive (Wireless) Charging” (issued December 14, 2021)

  • Technology Synopsis: This patent describes a system with one or more primary coils and associated control circuits for powering multiple compatible devices. The system is designed to detect communications from receiver units, identify the devices, determine appropriate charging algorithms, and select the most electromagnetically aligned coil for power transfer. (’500 Patent, Abstract).
  • Asserted Claims: Claims 1 and 23. (Compl. ¶221).
  • Accused Features: The "Wireless PowerShare" functionality of the Samsung S21 Ultra smartphone. (Compl. ¶222).

U.S. Patent No. 11,342,777 - “Powering and/or Charging with More Than One Protocol” (issued May 24, 2022)

  • Technology Synopsis: The patent addresses interoperability by claiming a base system that can operate in at least two different modes using two different protocols. One mode uses uni-directional messaging at a first power level, while the second mode uses bi-directional messaging at a different, second power level, allowing the charger to support both simple and more advanced charging standards. (’777 Patent, Abstract).
  • Asserted Claims: Claims 1 and 15. (Compl. ¶261).
  • Accused Features: The Samsung Wireless Charger Duo Pad (model 5400 Duo), which allegedly supports both the standard WPC Baseline Power Profile (uni-directional, ≤5W) and Samsung's proprietary Wireless Fast Charge protocol (bi-directional, >5W). (Compl. ¶262, 271, 276).

U.S. Patent No. 11,462,942 - “Efficiencies and Method Flexibilities in Inductive (wireless) Charging” (issued October 4, 2022)

  • Technology Synopsis: This patent is directed to an inductive power system comprising specific drive, sense, and control circuits. The claims detail the interaction between these circuits to detect a device, establish communication, and regulate power transfer via a closed-loop feedback mechanism based on information received from the device's receiver. (’942 Patent, Abstract).
  • Asserted Claims: Claims 1 and 21. (Compl. ¶320).
  • Accused Features: The Samsung S22 Ultra smartphone (specifically its Wireless PowerShare feature) and the Samsung 5400 Duo wireless charger. (Compl. ¶321).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies several categories of accused products, including Samsung Galaxy smartphones (e.g., S7, S10, S22, and Z4 series), Samsung wireless chargers (e.g., Wireless Charger Duo Pad EP-P5200, Duo Pad EP-P5400, and Trio Pad EP-P6300), Samsung wearable products (e.g., Galaxy Watch), Samsung earbud products (e.g., Samsung Buds), and Samsung stylus pens (e.g., the S Pen). (Compl. ¶29, 38).

Functionality and Market Context

  • The accused functionalities fall into two main categories: devices that act as wireless power transmitters and devices that act as wireless power receivers. (Compl. ¶29).
    • Transmitting Functionality: This includes standalone charging pads like the Samsung Wireless Charger Duo and Trio models, which are designed to charge multiple devices simultaneously. (Compl. ¶38). It also includes the "Wireless PowerShare" feature in certain Galaxy smartphones (e.g., S10, S21 Ultra, S22 Ultra), which allows the phone itself to function as a charging pad for other devices like watches or earbuds. (Compl. ¶111). The complaint includes an internal image from an FCC report showing the three charging coils in the Samsung 5200 Duo charger. (Compl. ¶46).
    • Receiving Functionality: This includes the capability of Samsung smartphones, watches, and earbuds to be charged wirelessly when placed on a compatible charging surface. (Compl. ¶72). The complaint specifically details the receiver components within the Galaxy S7 smartphone, citing a teardown report. (Compl. ¶82). This iFixit teardown image shows the wireless power receiver ASIC on the S7's mainboard. (Compl. ¶87).

IV. Analysis of Infringement Allegations

’208 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a base unit having a surface, and comprising a plurality of primary coils arranged behind and parallel to the surface, wherein each of the primary coils is associated with a switching circuit… The accused Samsung wireless chargers (e.g., 5200 Duo, 5400 Duo, 6300 Trio) are base units with multiple primary charging coils and associated switching circuits to activate them. An FCC report image shows three distinct coils in the 5200 Duo. (Compl. ¶46). ¶43-46 col. 3:5-13
a communications interface that the base unit... use to communicate... to poll each of the primary coils... to verify the presence of the mobile... device... The chargers include an interface (e.g., an IDT/Renesas ASIC) that polls/senses to detect the presence of a device to be charged, in compliance with the Wireless Power Consortium (WPC) standard. (Compl. ¶58, 60). ¶57-58, 62-63 col. 4:1-12
select, based on the polling or sensing, from within the plurality of primary coils... only those one or more primary coils which are determined to be most closely aligned with a receiver coil... The chargers' communication interface, operating per the WPC standard, receives signal strength information from the device to determine which of the multiple coils is best aligned for power transfer, and then activates that specific coil. (Compl. ¶58, 64). ¶57-58, 64 col. 4:13-23
wherein the base unit, and receiver coil... use current modulation performed by the receiver coil... to determine and regulate one or more of output voltage, current, or power... The chargers receive communications via current modulation from the receiver device to implement closed-loop feedback control, regulating power transfer in accordance with the WPC standard. (Compl. ¶58, 62, 65). A circuit diagram shows the representative IDT P9236 ASIC. (Compl. ¶60). ¶57-58, 65 col. 4:32-47

Identified Points of Contention (’208 Patent)

  • Scope Questions: A central question may be whether the operations described in the WPC standard, which the complaint relies on heavily, are coextensive with the specific steps claimed in the patent. For example, does the WPC-compliant process of using signal strength packets constitute "polling each of the primary coils" and "select[ing]... only those one or more primary coils which are determined to be most closely aligned" as those phrases would be construed from the patent's specification?
  • Technical Questions: What evidence does the complaint provide that the accused chargers actually "select" a single best coil among a plurality for a given charging operation, versus activating a region or a pre-determined set of coils? The complaint alleges this function based on WPC standard documents. (Compl. ¶64).

’440 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A mobile device capable of inductive powering or charging by a universal base unit... comprising: a battery, wherein one or both of a mobile device and the battery have particular charging characteristics... Samsung Galaxy smartphones (e.g., the S7) contain a battery and are capable of being charged by universal WPC-compatible base units, with specific charging characteristics like maximum received power (5 watts for the S7). (Compl. ¶73, 76, 78). ¶71-73, 76, 78 col. 1:21-27
an identification component associated with the mobile device or battery, which is configured to provide wireless identification of the receiver to the universal base unit; The accused smartphones (e.g., S7) include hardware/software (e.g., IDT/Renesas P9221 ASIC) that transmits an identification packet with a manufacturer code and device ID to the charger base unit, as required by the WPC standard. (Compl. ¶83-85). ¶83-85, 87 col. 3:42-46
a means for avoiding overcharging one or both of the mobile device and battery inductively; The accused smartphones include hardware/software that sends an "end power transfer" message to the base unit to signal a stop to inductive charging, thereby avoiding overcharging, per the WPC standard. (Compl. ¶91-93). ¶91-93 col. 3:47-49
wherein the receiver communicates with the base unit to... communicate information describing the characteristics of the mobile device or the battery, for use by the base unit to provide power transfer... The accused smartphones (e.g., S7) communicate with the base unit, per the WPC standard, to provide their charging characteristics (e.g., via a Configuration Packet) so the base unit can provide the appropriate power transfer. An iFixit teardown shows the S7's receiver circuitry. (Compl. ¶82). ¶101, 106 col. 4:1-9

Identified Points of Contention (’440 Patent)

  • Scope Questions (Means-Plus-Function): The term "a means for avoiding overcharging" will be construed as a means-plus-function element under 35 U.S.C. § 112(f). Its scope will be limited to the corresponding structure described in the patent's specification and its equivalents. The dispute will likely focus on whether the structure in the accused devices (e.g., the ASIC and firmware implementing the WPC "end power transfer" protocol) is the same as or equivalent to the structure disclosed in the ’440 patent’s specification.
  • Technical Questions: What specific "charging characteristics" do the accused phones communicate, and does this communication serve the claimed purpose of allowing the base unit to provide power "according to their particular charging characteristics"? The complaint alleges this occurs via WPC standard protocols. (Compl. ¶101, 106).

V. Key Claim Terms for Construction

’208 Patent, Claim 1

  • The Term: "select... only those one or more primary coils which are determined to be most closely aligned"
  • Context and Importance: This term is central to the patent's claim of an intelligent, efficient charging pad. The definition of "select" and "most closely aligned" will determine whether a charger that complies with the WPC standard's method for handling multiple coils necessarily infringes. Practitioners may focus on this term because the complaint's theory relies on mapping the WPC standard to this language, a point a defendant may contest.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the process in general terms, stating the system "determines which of the coils... is in the best position to provide power to the secondary" without being limited to a single method of determination. (’208 Patent, col. 4:15-18).
    • Evidence for a Narrower Interpretation: The specification describes an embodiment where selection is based on "polling each of the primary coils, or receiving a signal from a sensor associated therewith." (’208 Patent, col. 4:8-10). This could be argued to narrow the scope of how "selection" is performed.

’440 Patent, Claim 1

  • The Term: "identification component"
  • Context and Importance: The scope of this term dictates what hardware and software on the accused device meets the limitation. Its construction is critical because the complaint identifies the component as the ASIC and associated circuitry that implements the WPC communication protocol. (Compl. ¶85). The dispute will be whether this standard-compliant hardware is what the patent describes and claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims and specification refer to the component's function—providing "wireless identification"—without limiting it to a particular type of chip or protocol, suggesting it could cover any circuitry that performs this function. (’440 Patent, col. 3:42-46).
    • Evidence for a Narrower Interpretation: The specification states the identification component is "configured to provide wireless identification... to the universal base unit," which is then used to "detect, identify and authenticate the receiver." (’440 Patent, col. 3:42-46, 4:1-3). This could be argued to require more than a simple presence signal, potentially limiting the term to structures that can transmit specific authentication and characteristic data packets.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by asserting that Samsung's user manuals, marketing materials, and technical support instruct and encourage customers to use the accused products in an infringing manner. (Compl. ¶31). It also alleges contributory infringement, stating that the accused components are material to the inventions, are not staple articles of commerce, and are known by Samsung to be especially adapted for infringement. (Compl. ¶32).
  • Willful Infringement: Willfulness allegations are based on alleged pre-suit knowledge. The complaint asserts that beginning in 2013, Mojo Mobility met with Samsung multiple times, presented its wireless charging technology, provided prototypes, and informed Samsung that it had applied for patents to protect its inventions. (Compl. ¶14-15). The complaint alleges that discussions broke down because Samsung was unwilling to pay for the technology, and that Samsung subsequently incorporated the technology into its products despite this knowledge. (Compl. ¶16-17, 35).

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

  • A core issue will be one of standards equivalence: To what extent does an accused product’s compliance with the Wireless Power Consortium (Qi) standard equate to infringement of the asserted claims? The case may turn on whether the functions and protocols described in the standard, which form the basis of many of the complaint’s technical allegations, are functionally and structurally equivalent to the specific claim limitations as construed in light of the patent specifications.
  • A key factual question will be the scope of pre-suit knowledge: The willfulness claim will depend heavily on evidence from the alleged 2013-era meetings between Mojo Mobility and Samsung. The central questions for the court will be what specific technical details and patent filings were disclosed to Samsung, and whether the technology in the accused products can be demonstrably traced to those disclosures, thereby establishing a basis for willful infringement.
  • A third question may concern claim validity in light of industry developments: Given the long period between the priority dates of the foundational patents (e.g., 2006-2007) and the filing of the lawsuit, and the concurrent development of the Qi standard, a key defensive posture may involve challenging the validity of the claims over prior art that emerged as wireless charging technology was commercialized by the industry.