DCT
2:23-cv-00054
WiPQTUS Inc v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: WiPQTUS Inc. (Delaware)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: CARSTENS, ALLEN & GOURLEY, LLP
- Case Identification: 2:23-cv-00054, E.D. Tex., 02/14/2023
- Venue Allegations: Venue is alleged to be proper for Samsung Electronics Co., Ltd. as a foreign corporation not resident in the U.S., 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 Samsung’s smartphones equipped with the "Wireless PowerShare" feature infringe a patent related to dual-mode wireless power circuitry that can both receive and transmit power.
- Technical Context: The technology concerns integrated circuits in portable electronics that enable a device to function as both a wireless power receiver (to charge its own battery) and a wireless power transmitter (to charge other devices).
- Key Procedural History: The complaint states that Plaintiff has not made, sold, or licensed any article under the asserted patent, a fact that may be relevant to the applicability of statutory marking requirements for damages calculations.
Case Timeline
| Date | Event |
|---|---|
| 2012-08-13 | ’339 Patent Priority Date |
| 2018-07-31 | ’339 Patent Issue Date |
| 2019-02-01 | Accused Samsung Galaxy S10 and Fold Launch (approximate) |
| 2019-08-01 | Accused Samsung Galaxy Note10 Launch (approximate) |
| 2023-02-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,038,339 - "Dual Mode Wireless Power Receiver"
- Patent Identification: U.S. Patent No. 10,038,339, "Dual Mode Wireless Power Receiver," issued July 31, 2018 (the "’339 Patent").
The Invention Explained
- Problem Addressed: The patent background describes the inconvenience of carrying numerous different power adapters for various mobile devices, particularly while traveling. It posits that it would be more convenient if a device with a large battery, such as a notebook, could wirelessly charge other, smaller devices like a mobile phone ('339 Patent, col. 1:15-32).
- The Patented Solution: The invention is a single, integrated "dual mode" wireless power circuit that can operate in two distinct modes. In "charging mode," the circuit is configured as a rectifier to receive wireless power and charge the host device's battery. In "communication mode" (i.e., power transmission mode), the same circuit reconfigures its switch network to function as an inverter, converting stored DC power from the battery back to AC to transmit power wirelessly to a secondary device ('339 Patent, Abstract; col. 2:50-67). This dual-functionality is illustrated in the high-level block diagram of Figure 1, which shows a reconfigurable "Switch Network" (102) as the core component.
- Technical Importance: This design proposes to eliminate the need for separate wireless power receiving and transmitting circuits, which could reduce the cost, complexity, and physical footprint of components within a mobile device ('339 Patent, col. 1:50-59).
Key Claims at a Glance
- The complaint alleges infringement of "one or more claims" of the ’339 Patent without specifying which claims are asserted (Compl. ¶33). Independent claim 1 is representative and its essential elements include:
- A dual mode wireless power receiver comprising one of a coil or capacitor electrodes, a "first circuitry," and a "second circuitry."
- The first circuitry includes an impedance network, a switch network, and a filter capacitor.
- The second circuitry includes a control logic circuit and a modulator/demodulator circuit.
- The first circuitry is configured to operate in a receiving mode, where it receives power from a transmitter and, based on input from the control logic, modifies and applies the power to a load.
- The first circuitry is also configured to operate in a transmitting mode, where it changes its topology to transmit stored power to a secondary device.
- The second circuitry is configured to identify the type and protocol of the secondary device, interpret data from it, and perform a function associated with the transmitted power.
III. The Accused Instrumentality
Product Identification
- The complaint names numerous Samsung smartphones that include a feature for "reverse wireless charging" or "Wireless PowerShare" (Compl. ¶24). These include, but are not limited to, the Galaxy S10, S20, S21, and S22 series; the Note10 and Note20 series; and various Z Flip and Z Fold models (Compl. ¶24).
Functionality and Market Context
- The complaint alleges that beginning with the Samsung Galaxy S10 in 2019, Samsung introduced the "Wireless PowerShare" feature, which allows the smartphones to function as wireless charging pads for other devices, such as wireless earbuds or other phones (Compl. ¶22). The complaint includes a photograph showing a Samsung smartphone wirelessly charging a case of earbuds, illustrating the accused "Wireless PowerShare" functionality (Compl. ¶23). The infringement allegations are further directed at the underlying wireless power transceiver chips used in these devices, such as the IDT/Renesas P9320S and Samsung's own MIW04 chip (Compl. ¶26, ¶27).
IV. Analysis of Infringement Allegations
’339 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A dual mode wireless power receiver configured to selectively apply a received power to a load device and utilize at least a part of the stored power to power-up a secondary wireless power receiver... | The Accused Products can both be charged wirelessly (receive power) and can use their own battery power to charge other devices via the "Wireless PowerShare" feature (transmit power). | ¶22, ¶23 | col. 1:11-20 |
| a first circuitry comprising: an impedance network; a switch network; a filter capacitor; | The Accused Products allegedly contain wireless power transceiver chips (e.g., P9320S, MIW04) that are "materially... the same" as a reference chip (P9415) and are alleged to contain the claimed circuitry. | ¶29, ¶30 | col. 8:35-41 |
| said first circuitry, ... configured to change impedance of said impedance network and topology of said switch network to obtain a modified form of said received power, and apply said modified form... | The Accused Products are capable of receiving wireless power to charge their internal batteries. The complaint alleges this standard functionality infringes. | ¶22 | col. 2:39-44 |
| said first circuitry, ... configured to change said topology of said switch network ... to transmit at least part of said stored power to said secondary wireless power receiver... | The Accused Products' "Wireless PowerShare" feature enables them to transmit power from their own batteries to charge external devices. | ¶22, ¶23 | col. 2:50-57 |
| said second circuitry, on power-up of said secondary wireless power receiver, configured to identify a type of said secondary wireless power receiver and identify a wireless power protocol... | The complaint does not provide specific factual allegations for how the Accused Products identify the type of secondary device or its protocol, but generally alleges that use of the "Wireless PowerShare" feature infringes. | ¶34 | col. 4:25-30 |
- Identified Points of Contention:
- Technical Question: The complaint's technical support for infringement of the internal circuit elements rests on the allegation that the transceiver chips used in the Accused Products (e.g., P9320S, MIW04) are "materially ... the same" as a different chip (P9415) for which a datasheet is attached to the complaint (Compl. ¶29). A central evidentiary question will be whether discovery confirms that the accused chips are technically equivalent to the reference P9415 chip and, further, whether the P9415 chip's architecture and operation meet every limitation of the asserted claims.
- Scope Question: Claim 1 requires the "second circuitry" to perform specific logical functions, such as "identify a type of said secondary wireless power receiver" and "receive and interpret data from said secondary wireless power receiver." The complaint does not allege specific facts about how the Accused Products perform these detailed communication and identification steps. A key issue may be whether the general operation of the "Wireless PowerShare" feature meets these specific data-handling requirements as claimed.
V. Key Claim Terms for Construction
The Term: "dual mode wireless power receiver"
Context and Importance: This term appears in the patent title and preamble of the main independent claim and defines the invention's core identity. Practitioners may focus on this term because the case hinges on whether Samsung's products, which are capable of both receiving and transmitting wireless power, fall within the patent's specific definition of a "dual mode" device.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the invention in general terms as a device that operates in a "charging mode" and a "communication mode" and is able to both "receive power" and "transmit power" ('339 Patent, col. 2:36-44). This language could support an interpretation that covers any device with this general two-way capability.
- Evidence for a Narrower Interpretation: The full text of claim 1 defines the term by its structure, requiring a specific "first circuitry" and "second circuitry" with recited components and functions. A defendant may argue that the term is implicitly limited to the specific architecture where a single "switch network" is reconfigured from a rectifier to an inverter to achieve the dual modes ('339 Patent, col. 2:60-67), rather than any system that simply has both functionalities.
The Term: "switch network"
Context and Importance: This component within the "first circuitry" is the critical element that the patent describes as reconfiguring to enable the dual-mode operation. The infringement analysis will depend on whether the circuitry within Samsung's accused chips is structurally and functionally equivalent to the claimed "switch network."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 does not specify a particular topology, which could support a construction covering any arrangement of switches that achieves the claimed functions of rectifying received power and inverting stored power for transmission.
- Evidence for a Narrower Interpretation: The specification provides detailed examples of the switch network, such as a "full bridge inverter" (Fig. 7A) and a "half bridge inverter" (Fig. 7B). A defendant may argue that the term should be construed as limited to these disclosed embodiments or their close equivalents, particularly if the prosecution history contains any disclaimers related to switch configurations.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Samsung provides the Accused Products to end-users "knowing and intending" that the users will utilize the infringing "Wireless PowerShare" feature as intended (Compl. ¶35). The basis for knowledge appears to be Samsung's own design and marketing of the feature.
- Willful Infringement: The allegation of willfulness is based entirely on post-suit conduct. The complaint alleges that Defendants had "actual notice of the '339 Patent at least by the filing of this lawsuit" and have continued their allegedly infringing acts despite this notice (Compl. ¶38). No facts suggesting pre-suit knowledge are alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical proof: The complaint's infringement theory for the internal workings of the Accused Products is predicated on an asserted technical equivalence between the chips Samsung uses and a different reference chip. A key question for the litigation will be whether discovery substantiates this equivalence and confirms that the accused circuitry embodies the specific reconfigurable "switch network" architecture required by the claims.
- A second central issue will be one of functional scope: The patent claims require not just the transmission of power, but also specific data-handling and device-identification protocols performed by the control circuitry. An evidentiary focus will likely be whether the accused "Wireless PowerShare" feature actually performs these detailed logical functions, or if there is a mismatch between the high-level operation of Samsung's feature and the specific functions recited in the claims.