Nariste Networks Pty Ltd v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nariste Networks Pty. Ltd. (Australia)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Alavi & Anaipakos PLLC
• Case Identification: 2:23-cv-00031, E.D. Tex., 01/27/2023
• Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as an alien corporation and for Samsung Electronics America, Inc. based on its regular and established places of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s mobile devices, including smartphones, tablets, and watches, infringe a patent related to adaptively managing GPS power consumption to conserve battery life.
• Technical Context: The technology addresses the trade-off between location accuracy and battery drain in mobile devices by intelligently determining when to power on the GPS module based on data from other, less power-intensive wireless networks.
• Key Procedural History: The asserted patent is a reissue patent. The complaint alleges Samsung had pre-suit knowledge via a letter dated December 3, 2020. Notably, an Inter Partes Review (IPR) Certificate included with the provided patent document, resulting from a proceeding filed after this complaint, indicates that the sole asserted independent claim (Claim 37) and all other independent claims have been cancelled. The legal effect of this post-filing cancellation will be a threshold issue for the litigation.

Case Timeline

Date	Event
2004-09-02	U.S. RE48,206 Patent Priority Date
2020-09-15	U.S. RE48,206 Patent Issued
2020-12-03	Plaintiff sends first letter to Samsung regarding the patent
2023-01-27	Complaint Filed
2023-10-03	IPR2023-01374 Filed against U.S. RE48,206 Patent
2025-07-10	IPR Certificate Issued stating claims 37-45 are cancelled

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

U.S. Reissue Patent No. RE48,206 - “Reduced Power Use in Mobile GPS-Based Technologies,” Issued Sep. 15, 2020

The Invention Explained

• Problem Addressed: The patent’s background section describes the challenge of power consumption in GPS-enabled mobile devices. A "cold start" (powering on the GPS with no current satellite data) is slow, while keeping the GPS in a "hot start" mode (continuously on) drains the battery. Existing "TricklePower" modes that periodically power the device on using a fixed interval are described as suboptimal. (RE48206 Patent, col. 10:1-54).
• The Patented Solution: The invention proposes a method for adaptively managing the GPS power-up cycle. It suggests determining when to power on the GPS module based on data obtained from a separate wireless communications network (e.g., cellular or Wi-Fi), such as the device's current position and an associated error value. This allows the device to intelligently extend the power-down period to conserve energy while still meeting pre-defined requirements for location accuracy. (’206 Patent, Abstract; col. 12:41-50).
• Technical Importance: This self-monitoring approach allows a mobile device to dynamically optimize its own power usage based on its circumstances, a critical feature for battery-dependent electronics. (’206 Patent, col. 12:56-62).

Key Claims at a Glance

• The complaint asserts independent claim 37. (Compl. ¶44).
• The essential elements of independent claim 37 are:
  • A method of acquiring a position on a mobile device that has both wireless communication network capability and an embedded GPS module.
  • The method involves determining when the GPS module should be powered on, and then powering it on.
  • The determination of when to power on is dependent on at least one of a "current radio position" and a "position error" of the device, where both are determined from the wireless communications network.
  • The wireless communications network is different from the GPS network.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies a broad range of "Accused Products," including Samsung Galaxy S, Z, and A series phones; Galaxy Tab A and S series tablets; and Galaxy Watch series smartwatches. (Compl. ¶45).

Functionality and Market Context

• The Accused Products are alleged to operate on the Android Operating System ("Android OS"), which provides location services. (Compl. ¶35, 46). The complaint alleges that the Android OS and its APIs, such as the Fused Location Provider, allow applications to request location information with varying levels of accuracy and power consumption. (Compl. ¶¶ 39, 77). For instance, an application can specify a "PRIORITY_HIGH_ACCURACY" which enables GPS, or a "PRIORITY_BALANCED_POWER_ACCURACY" which "very rarely uses GPS" and instead relies on Wi-Fi and cellular data. (Compl. ¶39, p. 10). This functionality, which allows for selective use of the GPS based on accuracy requirements, forms the basis of the infringement allegations. The complaint cites to Samsung and Google documentation showing how these location services are controlled. For example, a screenshot from Android developer documentation explains that location accuracy and battery drain are directly related, with higher accuracy settings potentially causing significant battery drain by enabling GPS and other sensors. (Compl. ¶39, p. 10).

IV. Analysis of Infringement Allegations

RE48,206 Patent Infringement Allegations

Claim Element (from Independent Claim 37)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of acquiring a position on a mobile wireless communication device...possessing wireless communications capability...and an embedded GPS module for GPS capability...	The Samsung Galaxy S20 and other Accused Products are mobile devices with GPS, Wi-Fi, and cellular network capabilities.	¶82; p. 22	col. 16:4-14
determining when said embedded GPS module should be powered on, said embedded GPS module then being powered on,	The Android OS on the Accused Products allows applications to set a desired location accuracy, which in turn determines whether the GPS module is powered on (e.g., setting "PRIORITY_HIGH_ACCURACY" enables GPS).	¶¶ 85-86; p. 24	col. 16:15-17
said when said embedded GPS module should be powered on being dependent on at least one of a current radio position and a position error of said mobile device determined from the wireless communications network,	The Android OS allegedly allows an application to acquire a "current radio position" (via getLocation()) and a "position error" (via getAccuracy()) from non-GPS sources, and the decision to use GPS is dependent on these values.	¶¶ 87-89	col. 16:18-22
said wireless communications network being different from said GPS.	The Accused Products use Wi-Fi and cellular mobile networks to determine location, which are distinct from the GPS. This is shown in user manuals and Android OS documentation.	¶¶ 83, 91; p. 23	col. 16:23-24

• Identified Points of Contention:
  • Scope Questions: A central question is whether the accused functionality—which appears to be a reactive, application-driven system of selecting a power/accuracy mode—falls within the scope of the patent's "determining" step. The patent specification discusses a more proactive, predictive system using adaptive algorithms and neural networks, which may suggest a narrower claim scope than what the complaint alleges. (RE48,206 Patent, col. 12:28-34, col. 14:41-44).
  • Technical Questions: It is an open question whether the data returned by the Android OS APIs, such as the getAccuracy() method, constitutes a "position error... determined from the wireless communications network" as that term is used in the patent. The complaint asserts this equivalence (Compl. ¶89), but the defense may argue that the patent's "position error" is a specific technical term calculated by comparing a predicted position with an actual position, a function the accused API may not perform. (’206 Patent, col. 13:10-14).

V. Key Claim Terms for Construction

• The Term: "determining when said embedded GPS module should be powered on"

• Context and Importance: This phrase defines the core action of the claimed method. Its construction will be critical because the infringement theory depends on whether the accused Android OS functionality of selecting a pre-defined accuracy/power mode (e.g., "PRIORITY_HIGH_ACCURACY") constitutes "determining" in the claimed sense.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify how the determination must be made, which could support an interpretation covering any process that results in the GPS being powered on based on the claimed criteria.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the invention in terms of "adaptive predictions," "neural networks," and a system that "systematically set[s] the period of the power-up phase," which may support a narrower construction requiring a proactive, predictive, and self-adjusting mechanism, not just a reactive selection from a list of modes. (RE48,206 Patent, col. 10:59-63; col. 12:36-40).

• The Term: "a position error of said mobile device determined from the wireless communications network"

• Context and Importance: The infringement case hinges on mapping the output of the Android OS getAccuracy() function to this claim limitation. Practitioners may focus on this term because the technical definition of "position error" in the patent may not align with the generic "horizontal accuracy radius" value provided by the accused API.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "position error" is not explicitly defined, which could allow it to be read broadly as any metric of location uncertainty, which the getAccuracy() function provides. The complaint cites an Android API screenshot describing getAccuracy() as the "estimated horizontal accuracy radius," which Plaintiff will argue is a type of position error. (Compl. ¶89, p. 26).
  • Evidence for a Narrower Interpretation: The specification describes calculating the "position error eₚ" by comparing a "predicted position" with the "actual position" of the mobile device. (RE48,206 Patent, col. 13:10-14). This suggests "position error" may be a specific, calculated value, not a generic, pre-computed accuracy estimate provided by an operating system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement. The factual basis is that Samsung provides user manuals, on-device setup wizards, and marketing materials that allegedly instruct and encourage users to enable and use the accused location features, thereby causing them to directly infringe the patent. (Compl. ¶¶ 96-104).
• Willful Infringement: The complaint alleges willful infringement based on Samsung’s alleged pre-suit knowledge of the ’206 Patent. This knowledge is alleged to stem from a letter sent by Nariste to Samsung on December 3, 2020, as well as subsequent notice from the filing of the complaint. (Compl. ¶¶ 93-95).

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

1. Case Viability: The most significant threshold issue, arising from evidence outside the complaint itself, is the cancellation of the asserted patent claim. The provided IPR Certificate indicates that Claim 37, the sole independent claim asserted, has been cancelled. The case's ability to proceed will depend entirely on the final, unappealable status of this IPR decision.
2. Functional Mismatch: A core technical dispute will be whether there is a mismatch in technical operation. The court will need to determine if the accused system—which relies on an application selecting a pre-set power/accuracy mode from an OS-provided menu—performs the same function as the patent's disclosure of a self-monitoring, predictive system that dynamically calculates and adjusts the GPS power-up period.
3. Claim Scope: The case will also turn on a key question of definitional scope: can the claim term "position error... determined from the wireless communications network," which the patent describes as being calculated from predictive models, be construed broadly enough to read on the generic accuracy value returned by the accused Android API?