DCT

2:23-cv-00083

Slyde Analytics LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00083, E.D. Tex., 02/28/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung Electronics America, Inc. has corporate offices and a regular and established place of business in the district, and because Samsung Electronics Co., Ltd is a foreign corporation that may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartwatch products infringe four patents related to power management via gesture detection, the display of simulated mechanical watch movements, and touch-based user interface navigation.
  • Technical Context: The technologies at issue concern core features of modern smartwatches, focusing on methods to conserve battery life and enhance the user's interaction with the device's small screen.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2009-07-03 Priority Date for U.S. Patent No. 9,651,922
2010-03-30 Priority Date for U.S. Patent No. 8,588,033
2011-10-18 Priority Date for U.S. Patent Nos. 9,804,678 & 10,198,085
2013-11-19 Issue Date for U.S. Patent No. 8,588,033
2017-05-16 Issue Date for U.S. Patent No. 9,651,922
2017-10-31 Issue Date for U.S. Patent No. 9,804,678
2019-02-05 Issue Date for U.S. Patent No. 10,198,085
2023-02-28 Complaint Filing Date

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

U.S. Patent No. 9,804,678 - "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode"

  • Patent Identification: U.S. Patent No. 9,804,678, titled "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode", issued on October 31, 2017.

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of distinguishing a user’s intentional command to switch a device's power mode (e.g., wake from sleep) from other gestures or accelerations that occur during normal use, which could cause undesirable power consumption (’678 Patent, col. 2:8-15).
  • The Patented Solution: The invention proposes combining two different sensors—an inertial sensor (like an accelerometer) and a touch panel—to more reliably detect a gesture (’678 Patent, col. 2:35-39). The system discriminates between an intentional gesture (such as a tap) and other movements by analyzing the specific signature of the acceleration signal, such as its frequency, direction, and/or slope, to trigger a switch from a first power mode to a second power mode (’678 Patent, Abstract; col. 2:40-45).
  • Technical Importance: This combined-sensing approach aims to provide a more robust method for waking a device, thereby reducing false activations and conserving battery life, a critical design constraint for wearable electronics (’678 Patent, col. 2:54-58).

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶21).
  • The essential elements of claim 14 are:
    • A wristwatch operable in a plurality of power modes.
    • A display, a microcontroller, and a touch panel underneath a cover glass.
    • A touch controller for interpreting touch signals.
    • An inertial sensor (comprising an accelerometer and a processor) arranged for generating an acceleration signal and discriminating between gesture and no gesture based on direction, slope, or frequency of the signal, while the microcontroller and touch controller are in a sleep power mode.
    • The touch controller is commanded to switch to the second power mode upon gesture detection by the inertial sensor and for detecting a tap gesture.
    • The microcontroller is commanded to switch to the second power mode upon a tap gesture detection by the touch controller.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,198,085 - "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode"

  • Patent Identification: U.S. Patent No. 10,198,085, titled "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode", issued on February 5, 2019.

The Invention Explained

  • Problem Addressed: As a continuation of the ’678 patent, this patent shares the same background, which identifies the difficulty of reliably waking a device from a low-power mode without accidental activations (’085 Patent, col. 2:8-15).
  • The Patented Solution: This patent claims a method for switching power modes based on detecting a specific "wristturn" gesture. The method requires detecting a sequence of events: (1) the wristwatch is in a "starting position" within a first angular range for a defined time; (2) it then moves to a "final position" in a second, different angular range; and (3) it remains "substantially immobile" for a predetermined duration thereafter (’085 Patent, col. 11:1-15, Claim 1). This sequence, detected by an accelerometer, triggers the switch from the first power mode to the second (’085 Patent, col. 12:57-60).
  • Technical Importance: The claimed method provides a specific, multi-step process for a "raise-to-wake" function, aiming to create a reliable gesture-based interaction that does not require physical contact with the watch face.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶35).
  • The essential elements of claim 1 are:
    • A method for switching a wristwatch from a first power mode to a second power mode using an accelerometer to detect a wristturn.
    • Detecting that the wristwatch's orientation is in a starting position, which includes holding it within a first range for a defined time.
    • Detecting that the wristwatch's orientation is then in a final position, which includes it being in a second range different from the first.
    • In response to detecting the orientation is in the second range, detecting that the wristwatch remains substantially immobile for a predetermined duration and that the duration between the starting and final positions is in a predefined range.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,588,033 - "Wristwatch with Electronic Display"

  • Patent Identification: U.S. Patent No. 8,588,033, titled "Wristwatch with Electronic Display", issued November 19, 2013.
  • Technology Synopsis: The patent addresses a desire to combine the visual appeal of a traditional mechanical watch with the accuracy of an electronic one (’033 Patent, col. 2:30-34). The invention is a wristwatch with an electronic display that reproduces a simulation of a mechanical watch movement, including a gear train, with the time indicated by this simulated movement being synchronized with an accurate quartz oscillator (’033 Patent, col. 10:15-25).
  • Asserted Claims: Independent claim 1 (Compl. ¶47).
  • Accused Features: The complaint alleges that Samsung’s smartwatches, such as the Galaxy Watch5, infringe by offering downloadable digital watch faces from the Galaxy Store that simulate mechanical watch movements with visible gear trains (Compl. ¶¶48-49). The complaint provides a visual of the "Mehanika-gold" watch face, which depicts an animated gear train (Compl. p. 14).

U.S. Patent No. 9,651,922 - "Wristwatch with a Touch Screen and Method for Displaying on a Touch-Screen Watch"

  • Patent Identification: U.S. Patent No. 9,651,922, titled "Wristwatch with a Touch Screen and Method for Displaying on a Touch-Screen Watch", issued May 16, 2017.
  • Technology Synopsis: The patent addresses the challenge of navigating on a small watch screen by proposing a user interface based on full-screen "cards" (’922 Patent, col. 4:15-22). The invention describes a processing circuit that interprets finger movements on a two-dimensional touch-sensitive glass to scroll through these cards, where the displayed card is lastingly replaced by a new card depending on the direction of the swipe (’922 Patent, Abstract; col. 4:10-14).
  • Asserted Claims: Independent claim 1 (Compl. ¶58).
  • Accused Features: The complaint alleges that the Samsung Galaxy Watch5 infringes by implementing a user interface where a user can swipe left or right to change the watch face or scroll through different "tiles" (widgets), which are alleged to be the claimed "cards" (Compl. ¶¶59-60). A visual from Samsung's support page shows a user swiping left/right to select a new watch face (Compl. p. 17).

III. The Accused Instrumentality

  • Product Identification: The complaint names a range of Samsung smartwatches, including the Galaxy Watch Active, Galaxy Watch Active2, Galaxy Watch, Galaxy Watch3, Galaxy Watch4, Galaxy Watch4 Classic, Galaxy Watch5, and Galaxy Watch5 Pro (Compl. ¶¶14-16). The detailed infringement allegations focus on the Samsung Galaxy Watch5 (Compl. ¶22).
  • Functionality and Market Context: The complaint identifies several functionalities of the accused products. These include operating in multiple power-saving modes and utilizing a "wake-up gesture" where a user raises their wrist to turn the screen on (Compl. ¶26). This gesture is allegedly enabled by an inertial sensor containing an accelerometer (Compl. ¶24). The products also feature a high-resolution display on which users can install digital watch faces, including those that "simulate the mechanical watch movement" (Compl. ¶48). The user interface is navigated via a touch screen, allowing users to swipe to change between different screens or "tiles" (Compl. ¶60). The complaint asserts that Samsung is a "leading manufacturer and seller of smartwatches in the world" (Compl. ¶2).

IV. Analysis of Infringement Allegations

’678 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
A wristwatch ... which can be operated in a plurality of power modes including a first power mode and a second power mode... The Samsung Galaxy Watch5 has power saving modes and can operate in a plurality of power modes. ¶22, ¶26 col. 3:12-19
a display; a microcontroller; a touch panel underneath a cover glass of said wristwatch for detecting a gesture on said cover glass; a touch controller for interpreting touch signal... The Galaxy Watch5 comprises a display, a microcontroller (Exynos W920 processor), and a touch panel under a cover glass for detecting gestures, with a touch controller for interpreting the signals. ¶22, ¶23, ¶24 col. 4:9-11, 29-34
an inertial sensor comprising an accelerometer and a processor, said accelerometer being arranged for generating an acceleration signal and the processor being arranged for discriminating between... The Galaxy Watch5 comprises an inertial sensor with a three-dimensional accelerometer and a processor. ¶24 col. 6:19-24
gesture and no gesture based on a direction of said acceleration signal ... and on a slope or frequency of said acceleration signal, while the microcontroller and the touch controller are in a sleep power mode The complaint alleges the processor discriminates based on the direction, slope, or frequency of the acceleration signal while the microcontroller and touch controller are in a sleep power mode. ¶24 col. 8:36-41
wherein touch controller is commanded so as to be switched to said second power mode upon gesture detection by said inertial sensor and for detecting a tap gesture on the cover glass... The complaint alleges the touch controller is switched to the second power mode upon gesture detection and for detecting a tap gesture. ¶25 col. 8:42-49
wherein the microcontroller ... is ... commanded so as to be switched to said second power mode upon a tap gesture detection by said touch controller... The complaint alleges the microcontroller is commanded to switch to the second power mode upon a tap gesture detection and for discriminating between gesture and no gesture based on signals from the touch panel. ¶25 col. 8:50-57
  • Identified Points of Contention:
    • Technical Questions: A primary point of contention may arise from the evidence presented. While the complaint asserts infringement of claim 14, which recites detecting a "tap gesture," the factual support and accompanying visual evidence describe a "wake-up gesture" of "raising the wrist" (Compl. ¶26). A diagram from Samsung's developer site illustrates a "wrist up and down" motion to activate the screen (Compl. p. 9). This raises the question of whether the accused wrist-raise functionality practices the claimed method for detecting a physical tap, which the patent describes as having a distinct physical signature (e.g., high frequency, perpendicular force) (’678 Patent, col. 6:36-54).

’085 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for switching a wristwatch from a first power mode to a second power mode... using an accelerometer for detecting a wristturn... The Samsung Galaxy Watch5 performs a method of switching power modes and uses an accelerometer for detecting a wristturn, which is described as the "wake-up gesture" of raising the wrist. ¶36, ¶38 col. 12:57-59
wherein said step of detecting a wristturn comprises: detecting that an orientation of the wristwatch is in a starting position, wherein said step ... comprises detecting that the orientation ... is held within a first range for a defined time; The complaint alleges that the Galaxy Watch5 "performs the step of detecting that an orientation of the wristwatch is in a starting position" and that this step "comprises detecting that the orientation of the wristwatch is held within a first range for a defined time." ¶37 col. 11:4-8
detecting that an orientation of the wristwatch is then in a final position, wherein said step ... comprises detecting that the orientation is in a second range different from said first range, The complaint alleges that the Galaxy Watch5 "performs the step of detecting that an orientation of the wristwatch is then in a final position" and that this involves detecting an orientation in a second range different from the first. ¶37 col. 11:9-12
in response to a detection that the orientation ... is in the second range, detecting that the wristwatch remains substantially immobile during a predetermined duration and that a duration between the starting position and the final position is in a predefined range. The complaint alleges the Galaxy Watch5 "performs the step of detecting that the wristwatch remains substantially immobile during a predetermined duration and that a duration between the starting position and the final position is in a predefined range in response to a detection that the orientation of the wristwatch is in the second range." ¶37 col. 11:13-19
  • Identified Points of Contention:
    • Technical Questions: The infringement analysis may focus on whether the accused "wake-up gesture" (Compl. ¶38) actually performs all the specific sub-steps required by claim 1. The claim requires not just a change in orientation, but specifically detecting a starting position held for a defined time, followed by a final position, followed by a period of substantial immobility. The complaint makes conclusory allegations tracking this language but does not provide specific evidence detailing how or if the accused products perform each distinct part of this claimed sequence.

V. Key Claim Terms for Construction

For the ’678 Patent:

  • The Term: "tap gesture"
  • Context and Importance: The definition of this term is critical because the complaint's factual allegations for the '678 patent center on a "wrist raise" gesture, not a physical tap. The outcome of the infringement analysis for claim 14 may depend on whether a "wrist raise" can be considered a "tap gesture" under the patent's definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the gesture "could be a tap, a double tap, a long tap or any other significant and recognizable gesture" (’678 Patent, col. 2:46-48). This language may be used to argue that the term is not limited to a literal physical tap.
    • Evidence for a Narrower Interpretation: The detailed description provides a highly specific technical profile for a tap, describing its "pulse function," its "high frequency," its short duration ("typically between 10 and 20 ms"), and its generation of a "maximal acceleration in a main direction perpendicular to the center of the glass" (’678 Patent, col. 6:36-65). This evidence could support a narrower construction limited to an actual physical impact on the watch.

For the ’085 Patent:

  • The Term: "detecting that an orientation of the wristwatch is in a starting position"
  • Context and Importance: Practitioners may focus on this term because the commercial "raise-to-wake" feature may be a continuous motion, whereas the claim requires the detection of discrete, defined states. The construction of this term will determine how rigidly the multi-step "wristturn" sequence is applied to the accused functionality.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the starting position as being within a wide angular range ("from 25° to 155° relatively to the horizontal") (’085 Patent, col. 11:19-21), which might support an argument that any orientation within this broad range prior to the main gesture qualifies.
    • Evidence for a Narrower Interpretation: The claim language itself requires that this orientation is "held within a first range for a defined time" (’085 Patent, col. 11:7-8). This suggests the "starting position" is not a transient state but a stable, deliberately held orientation that the system must register before the gesture can proceed, as illustrated in the sequence described in Figures 7a-7c.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all four patents. The allegations are based on Samsung providing the accused smartwatches to end users along with instructions, user manuals, and developer documentation that allegedly encourage and facilitate infringing use (Compl. ¶¶27-29, 39-41, 50-52, 61-63). For example, the complaint cites Samsung's support and developer websites that describe the "wrist up and down" gesture and how to swipe to change watch faces (Compl. pp. 9, 17).
  • Willful Infringement: For each patent, the complaint alleges that Samsung has knowledge of its infringement "at least as of the date of this Complaint" (Compl. ¶¶28, 40, 51, 62). This allegation forms a basis for potential post-suit willfulness. The complaint also alleges willful blindness, stating Samsung acted with the belief that there was a high probability that end users infringe the patents (Compl. ¶¶29, 41, 52, 63).

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

  • A central issue will be one of evidentiary alignment: Will the plaintiff's evidence of a "wrist-raise" gesture be sufficient to demonstrate infringement of the ’678 patent, whose asserted claim recites the detection of a "tap gesture" through a combination of an inertial sensor and a touch controller?
  • A key question of functional specificity will be whether the accused "wake-up gesture" in Samsung's products performs the precise, multi-part sequence required by claim 1 of the ’085 patent—including detecting a starting position held for a defined time, a distinct final position, and subsequent immobility—or if there is a fundamental mismatch in technical operation.
  • The dispute over the '033 patent may turn on a question of definitional scope: Do the animated graphics in the accused digital watch faces constitute a "simulation of a mechanical watch movement comprising a gear train" that is "synchroniz[ed]" with the watch's time base as claimed, or are they merely decorative animations that are functionally independent of timekeeping?