DCT

2:23-cv-00155

Kim v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00155, E.D. Tex., 04/05/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung transacts business and has committed acts of infringement in the district. For Defendant Samsung Electronics America, Inc., venue is additionally based on its alleged regular and established place of business in Plano, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s phones and tablets, which include features like "Lift to Wake," "Face Unlock," and "On-Body Detection," infringe six patents related to methods for selectively applying or bypassing security checks based on device motion and user identification.
  • Technical Context: The technology at issue concerns context-aware security for mobile devices, aiming to enhance user convenience by automatically unlocking a device or bypassing password entry when certain conditions, such as specific motion patterns or biometric identification, are met.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
2014-02-17 Earliest Priority Date for all Asserted Patents
2018-08-28 U.S. Patent No. 10,064,056 Issues
2019-12-17 U.S. Patent No. 10,511,975 Issues
2021-11-23 U.S. Patent No. 11,184,473 Issues
2021-12-28 U.S. Patent No. 11,212,382 Issues
2022-01-25 U.S. Patent No. 11,234,127 Issues
2023-02-28 U.S. Patent No. 11,595,507 Issues
2023-04-05 Complaint Filed

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

U.S. Patent No. 10,064,056 - Electronic apparatus and method of selectively applying security in mobile device

The Invention Explained

  • Problem Addressed: The patent describes the inconvenience for a user of having to repeatedly input a security code (e.g., a password or pattern) to access a mobile device, even when the user is in a trusted or "security safe zone" (Compl. Ex. 1, ’056 Patent, col. 1:29-35).
  • The Patented Solution: The invention proposes a mobile device that uses a "functional unit" to photograph an object and sense the device's motion. A control unit then determines whether to apply the standard security check process based on the information from the photographed object and the sensed motion, potentially bypassing the need for manual password entry (’056 Patent, Abstract; col. 2:58-65).
  • Technical Importance: This approach aimed to create a more seamless user experience by making device unlocking context-aware, reducing the friction of manual authentication while retaining a layer of security.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶10).
  • Essential elements of Claim 1 include:
    • A mobile device configured to photograph an object and generate a photographed object.
    • A display unit having a panel to display a screen to set the mobile device to a security mode requiring a security check process to enter a password for a user to access a normal mode.
    • A sensor configured to sense a motion of the mobile device.
    • A control unit configured to not apply the security check process for the normal mode according to the photographed object and the sensed motion, such that the user accesses the normal mode without the security check process.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,511,975 - Electronic apparatus and method of selectively applying security mode in mobile device

The Invention Explained

  • Problem Addressed: Similar to the ’056 Patent, this patent addresses the repetitive and inconvenient task of entering a security code each time a user wishes to access their mobile device (’975 Patent, col. 1:41-48).
  • The Patented Solution: The invention claims a method for unlocking a mobile device that links motion sensing with user identification. The method involves sensing a motion of the device and, in response, activating a user identification process (e.g., facial recognition). If this process determines the user is authorized, the device unlocks and enters a normal mode without requiring a password (’975 Patent, Claim 1).
  • Technical Importance: This patent describes a specific, trigger-based workflow (motion prompts identification, which prompts unlock) that has become a common paradigm for seamless biometric authentication on modern smart devices.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶12).
  • Essential elements of Claim 1 include:
    • Displaying a screen by using a panel of a display unit.
    • Unlocking the mobile device to access a normal mode according to a password input in a security check process.
    • Sensing a motion of the mobile device by using a sensor in a motion detection process.
    • Activating a user identification process of photographing the object to generate an object image and determining that the object image is an authorized user according to a reference, in response to the sensed motion.
    • Unlocking the mobile device to access the normal mode according to the determination of the user identification process.
  • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 11,184,473

  • Patent Identification: U.S. Patent No. 11,184,473, Electronic apparatus and method of selectively applying security mode in mobile device, issued November 23, 2021.
  • Technology Synopsis: This patent claims a method with two distinct unlocking pathways. A first process involves traditional password input, while a second, alternative process uses sensed motion to trigger the sensing of a "signal from a user" (e.g., from a paired wearable device) to determine authorization and unlock the device (’473 Patent, Abstract).
  • Asserted Claims: Independent Claim 31 (Compl. ¶14).
  • Accused Features: The complaint accuses Samsung's "On-Body Detection" and "Face Unlock" functionalities of infringement (Compl. ¶¶8, 14).

Multi-Patent Capsule: U.S. Patent No. 11,212,382

  • Patent Identification: U.S. Patent No. 11,212,382, Electronic apparatus and method of selectively applying security mode in mobile device, issued December 28, 2021.
  • Technology Synopsis: This patent claims a mobile device apparatus that includes a photographing unit and a motion sensor. The device is configured with two unlocking processes: one using a password and a second that uses the combination of a sensed motion and a photographed object image to unlock the device (’382 Patent, Abstract).
  • Asserted Claims: Independent Claim 1 (Compl. ¶16).
  • Accused Features: The complaint accuses Samsung's "Lift to Wake" and "Face Unlock" functionalities of infringement (Compl. ¶¶8, 16).

Multi-Patent Capsule: U.S. Patent No. 11,234,127

  • Patent Identification: U.S. Patent No. 11,234,127, Electronic apparatus and method of selectively applying security mode in mobile device, issued January 25, 2022.
  • Technology Synopsis: This patent claims a non-transitory computer-readable medium containing code to execute a method of unlocking. The method involves sensing motion and, in response, activating a user identification process that involves photographing an object to determine if the user is authorized (’127 Patent, Abstract).
  • Asserted Claims: Independent Claim 1 (Compl. ¶18).
  • Accused Features: The complaint accuses Samsung's "Lift to Wake" and "Face Unlock" functionalities of infringement (Compl. ¶¶8, 18).

Multi-Patent Capsule: U.S. Patent No. 11,595,507

  • Patent Identification: U.S. Patent No. 11,595,507, Electronic apparatus and method of selectively applying security mode in mobile device, issued February 28, 2023.
  • Technology Synopsis: This patent claims a mobile device apparatus that includes a functional unit for sensing a user and motion while the device is in a power-saving mode. Based on this sensing, the device can perform an unlocking operation that combines motion detection and user identification (’507 Patent, Abstract).
  • Asserted Claims: Independent Claim 1 (Compl. ¶20).
  • Accused Features: The complaint accuses Samsung's "Lift to Wake," "Face Unlock," and "On-Body Detection" functionalities of infringement (Compl. ¶¶8, 20).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "phones and tablets that include Lift to Wake, Face Unlock, and On-Body Detection functionalities" (Compl. ¶8).

Functionality and Market Context

  • The complaint does not identify specific Samsung product models or provide technical details regarding the operation of the accused features. Based on their names and general market understanding, "Lift to Wake" is a feature that uses motion sensors (e.g., accelerometers) to wake the device's screen when it is picked up. "Face Unlock" is a biometric authentication feature that uses the device's camera to identify a user's face to grant access. "On-Body Detection" is a feature that keeps a device unlocked when it detects that it is being carried by the user, such as in a hand or pocket. The complaint makes no allegations regarding the products' specific commercial importance beyond their general sale in the United States (Compl. ¶¶8-20).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides only conclusory allegations of infringement and does not contain a claim chart or a detailed explanation mapping the accused functionalities to the elements of the asserted claims. The plaintiff alleges that by making, using, and selling the Accused Products, Samsung infringes at least the specified claims of the Asserted Patents (Compl. ¶¶10, 12, 14, 16, 18, 20). The general infringement theory suggests that the "Lift to Wake" feature practices the claimed "sensing a motion" elements, while the "Face Unlock" feature practices the "photographing an object" and "user identification" elements. The combination allegedly results in the device bypassing a password-based security check, thereby practicing the core functionality described in the patents.

  • Identified Points of Contention:
    • Scope Questions: A primary question for the court will be whether performing a biometric security check (like Face Unlock) constitutes "not apply[ing] the security check process" as required by Claim 1 of the ’056 Patent, where the default "security check process" is defined as entering a password.
    • Technical Questions: For the ’975 Patent, a key factual question will be whether the accused products' "user identification process" (Face Unlock) is technically activated "in response to the sensed motion" (Lift to Wake), as the claim requires a specific causal sequence.

V. Key Claim Terms for Construction

  • For the ’056 Patent:

    • The Term: "not apply the security check process" (from Claim 1)
    • Context and Importance: This negative limitation is central to the infringement theory. Its construction will determine whether replacing one form of security check (password) with another (biometrics) meets the claim language. Practitioners may focus on this term because the accused products perform a security check (Face Unlock), raising the question of whether they truly "not apply" a check.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Claim 1 defines the "security mode" as "requiring a security check process to enter a password." This language may support an interpretation where "not apply[ing] the security check process" means not applying the password entry process, even if another process like facial recognition is used instead (’056 Patent, col. 18:48-51).
      • Evidence for a Narrower Interpretation: A party could argue that "the security check process" refers to any form of security validation. Since the accused Face Unlock is a form of security check, it could be argued that a security check process is, in fact, being applied, and thus the claim limitation is not met.

  • For the ’975 Patent:

    • The Term: "activating a user identification process... in response to the sensed motion" (from Claim 1)
    • Context and Importance: This term establishes a specific cause-and-effect relationship between motion and identification. The infringement analysis will depend on evidence showing that the accused devices' software architecture implements this precise sequence.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes a user action, such as holding the device, which causes a change in motion pattern, which in turn leads the control unit to "activate[] the functional unit 260 to photograph an object" for identification (’975 Patent, col. 14:40-48). This supports a reading where a general motion event triggers the identification process.
      • Evidence for a Narrower Interpretation: A party might argue for a more restrictive interpretation, requiring a direct and immediate software trigger where a specific, predefined motion pattern is the sole and necessary condition for activating the identification process, potentially excluding scenarios where other factors or user inputs are also involved.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement.

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

  • A core issue will be one of definitional scope: Can the phrase "not apply the security check process," which is defined in the context of password entry, be construed to cover a scenario where one security process (password) is replaced by another (biometrics)?
  • A key evidentiary question will be one of technical sequence: Does the software in Samsung's devices activate the "Face Unlock" feature directly "in response to" motion detected by the "Lift to Wake" feature, or are these processes sufficiently independent such that the causal link required by certain claims is broken?
  • An initial procedural question may be one of pleading sufficiency: Given the complaint’s lack of specific factual allegations mapping accused features to claim elements, the court may need to address whether the complaint meets the plausibility standard established by Twombly and Iqbal, or whether more detailed infringement contentions will be required early in the proceedings.