DCT
2:22-cv-00423
Resonant Systems Inc v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Resonant Systems, Inc., d/b/a RevelHMI (Washington)
- Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Russ August & Kabat
- Case Identification: 2:22-cv-00423, E.D. Tex., 10/26/2022
- Venue Allegations: Venue is alleged to be proper for Samsung Electronics Co., Ltd. as a foreign corporation, and for Samsung Electronics America, Inc. based on its alleged commission of infringing acts and its regular and established place of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that certain Samsung Galaxy smartphones incorporating linear vibration motors infringe two patents related to controllable linear haptic feedback modules.
- Technical Context: The technology concerns haptic feedback systems in consumer electronics, which generate tactile sensations for notifications, alerts, and user interface interactions.
- Key Procedural History: The complaint alleges that from 2017-2019, Plaintiff engaged in extensive licensing discussions with Samsung, which included providing physical samples, technical details, and identifying the asserted patents or their pending applications. These pre-suit communications form the primary basis for the willfulness allegations. A disclaimer for claims 15 and 16 of the ’081 Patent was filed on April 16, 2024; however, the complaint asserts independent claim 1.
Case Timeline
| Date | Event |
|---|---|
| 2009-05-18 | Priority Date ('081 & ’830 Patents) |
| 2016-06-14 | U.S. Patent No. 9,369,081 Issues |
| 2017-2019 | Alleged licensing discussions between Plaintiff and Samsung |
| 2018-04-10 | U.S. Patent No. 9,941,830 Issues |
| 2022-10-26 | Complaint Filing Date |
| 2024-04-16 | Disclaimer filed for claims 15 and 16 of '081 Patent |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,369,081 - Linear vibration modules and linear-resonant vibration modules, Issued June 14, 2016
The Invention Explained
- Problem Addressed: The patent describes conventional vibration mechanisms, based on rotating an unbalanced weight with an electric motor, as inefficient, prone to rapid wear, and limited in the range and type of vibration they can produce. Specifically, they generate elliptical, not linear, vibrations and are restricted to a narrow band of frequencies ('081 Patent, col. 1:12 - col. 2:67).
- The Patented Solution: The invention proposes a linear vibration module where a moveable component (e.g., a magnet) oscillates linearly within a housing, driven by an electromagnetic coil with a rapidly alternating current ('081 Patent, Abstract). This architecture, illustrated in configurations like Figure 4A, allows for direct, efficient conversion of electrical energy into linear vibration, enabling independent control over a wide range of vibration frequencies and amplitudes ('081 Patent, col. 4:13-36).
- Technical Importance: This approach overcomes the limitations of rotational motors by enabling more power-efficient, durable, and sophisticated haptic effects across a broad operational space, which was a significant advance for user interfaces in handheld devices ('081 Patent, col. 8:50-67).
Key Claims at a Glance
- The complaint asserts exemplary independent claim 1 and reserves the right to assert others (Compl. ¶12).
- Independent Claim 1 requires:
- a housing;
- a moveable component;
- a power supply;
- user-input features;
- a driving component that drives the moveable component in two opposite directions within the housing; and
- a control component that controls power to the driving component to cause oscillation at a frequency and amplitude specified by user input received from the user-input features.
U.S. Patent No. 9,941,830 - Linear vibration modules and linear-resonant vibration modules, Issued April 10, 2018
The Invention Explained
- Problem Addressed: The ’941 Patent shares its specification with the ’081 Patent and addresses the identical problems of inefficiency, wear, and limited operational range in conventional unbalanced rotational motors (’830 Patent, col. 1:21 - col. 2:62).
- The Patented Solution: The patent describes the same linear vibration module technology, where an electromagnetic driving component causes a moveable component to oscillate linearly, enabling precise control over haptic feedback (’830 Patent, col. 4:15-43).
- Technical Importance: As with the '081 Patent, the technology enables a broader and more sophisticated range of haptic effects than was possible with prior art motors (’830 Patent, col. 8:51 - col. 9:10).
Key Claims at a Glance
- The complaint asserts exemplary independent claim 1 and reserves the right to assert others (Compl. ¶19).
- Independent Claim 1 requires:
- a housing;
- a moveable component;
- a power supply;
- user-input features;
- a driving component that drives the moveable component to oscillate within the housing; and
- a control component that controls power to the driving component to cause oscillation at a frequency and amplitude specified by one or more stored values.
III. The Accused Instrumentality
Product Identification
The complaint identifies Samsung’s Galaxy S22, Galaxy S22+, Galaxy S22 Ultra, Galaxy Z Fold 3, and Galaxy Z Fold 4 smartphones as the Accused Products (Compl. ¶11, ¶18).
Functionality and Market Context
The complaint alleges these products are smartphones that incorporate "linear vibration motor technology" to provide haptic feedback to users (Compl. ¶11, ¶18). The complaint does not provide further technical detail on the specific operation of the accused motors but identifies the products as part of Samsung's consumer electronics lineup distributed in the United States (Compl. ¶5).
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶12, ¶19). The following summary is based on the complaint’s narrative allegations.
'081 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing; a moveable component; a power supply; user-input features; | The Accused Products allegedly contain a physical chassis (housing), an internal linear vibration motor (moveable and driving components), a battery (power), and a touchscreen (user input) | ¶11, ¶12 | col. 15:36-40 |
| a driving component that drives the moveable component in each of two opposite directions within the housing | The linear vibration motor within the Accused Products is alleged to contain a component that oscillates back and forth to create vibrations | ¶11, ¶12 | col. 15:41-43 |
| a control component that controls supply of power...to cause the moveable component to oscillate at a frequency and an amplitude specified by user input received from the user-input features | The Accused Products' processor allegedly acts as a control component, executing instructions to operate the motor based on user selections (e.g., choosing a vibration pattern in a settings menu) | ¶11, ¶12 | col. 15:44-49 |
'830 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing; a moveable component; a power supply; user-input features; a driving component that drives the moveable component to oscillate within the housing | The Accused Products allegedly contain a physical chassis (housing), an internal linear motor (moveable and driving components), a battery (power), and a touchscreen (user input) | ¶18, ¶19 | col. 16:56-62 |
| a control component that controls supply of power...to cause the moveable component to oscillate at a frequency and an amplitude specified by one or more stored values | The Accused Products' processor allegedly acts as a control component, operating the motor based on pre-programmed parameters (stored values) for events like notifications or calls | ¶18, ¶19 | col. 16:63-67 |
Identified Points of Contention
- Scope Questions: A primary dispute for the ’081 Patent may concern the scope of "specified by user input." The question is whether this requires a direct, contemporaneous user action to define the vibration's frequency and amplitude, or if it can be read to cover a user's one-time selection of a pre-set vibration pattern that is later triggered automatically. For the ’830 Patent, the dispute may focus on the breadth of "one or more stored values" and whether the accused system's operation falls within a reasonable construction of that term.
- Technical Questions: A key question will be how the functionality of the accused smartphones' general-purpose processors and operating systems maps to the "control component" as claimed. The defense may argue that the complex software architecture of a modern smartphone does not perform the specific control functions described and claimed in the patents.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The Term: "control component" ('081 Claim 1; '830 Claim 1)
- Context and Importance: This term is central to infringement, as it defines the "brains" of the claimed invention. Practitioners may focus on this term because its construction will determine whether a general-purpose CPU in a smartphone, executing high-level software, can be considered the claimed "control component."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explicitly describes the control component as potentially being a "CPU microprocessor" that executes a "control program" stored in memory, which supports reading the term on general-purpose hardware running software (’081 Patent, col. 5:11-16; Fig. 6).
- Evidence for a Narrower Interpretation: The specification also provides detailed flow charts (Figs. 7A-C) illustrating specific control logic, such as monitoring sensors and adjusting frequency to seek resonance. A party could argue the claimed "control component" must be interpreted as one that performs these specific, detailed functions, potentially narrowing the term's scope away from a general-purpose processor executing unrelated operating system tasks (’081 Patent, col. 5:46 - col. 6:65).
The Term: "specified by user input received from the user-input features" ('081 Claim 1)
- Context and Importance: This limitation is a key point of distinction for the ’081 Patent. Its interpretation will be critical to determining whether system-generated haptic events, as opposed to user-commanded ones, can infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification mentions "user-input features, including buttons, sliders, and other types" that allow a user to control vibration amplitude and frequency (’081 Patent, col. 4:33-36). This could support an interpretation where an initial user setting (e.g., in a menu) "specifies" the parameters for all subsequent vibrations of that type.
- Evidence for a Narrower Interpretation: The claim language links the oscillation parameters ("frequency and an amplitude") directly to the "user input received." This could support a reading that requires the parameters to be determined by a present user action, not a stored preference from a prior, unrelated input.
VI. Other Allegations
Indirect Infringement
The complaint does not contain separate counts for indirect infringement. The allegations focus on direct infringement by Defendants for making, using, selling, and importing the Accused Products (Compl. ¶13, ¶20).
Willful Infringement
The complaint alleges willful infringement based on pre-suit knowledge. It claims that during extensive licensing negotiations from 2017-2019, Samsung was made aware of the asserted patents and underlying technology, was provided with physical samples, and yet continued to infringe after rejecting a license (Compl. ¶2, ¶15, ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and scope: can the phrase "specified by user input" in the ’081 Patent be construed to cover system-triggered haptic alerts based on a user's prior menu selections? Correspondingly, how broadly can the term "specified by one or more stored values" in the ’830 Patent be interpreted, and what is the evidentiary burden to prove the accused devices operate in this manner?
- A second central question will be factual and relates to willfulness: what was the precise nature of the technical information and notice provided to Samsung during the 2017-2019 discussions? The determination of willfulness will likely depend on whether the evidence shows Samsung had knowledge of infringement of valid patent claims and proceeded with "wanton disregard" of Plaintiff's patent rights.
- A key evidentiary question will be one of technical mapping: can Plaintiff demonstrate that the complex hardware and software architecture of the accused smartphones, particularly the operation of their application processors and operating systems, constitutes the "control component" and performs the specific control functions as required by the asserted claims?