DCT

2:23-cv-00285

Cobblestone Wireless LLC v. Samsung Electronics America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00285, E.D. Tex., 06/16/2023
  • Venue Allegations: Venue is alleged to be proper as to Samsung Electronics Co., Ltd. because it is a foreign corporation, and as to Samsung Electronics America, Inc. because it has a regular and established place of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s cellular base stations and mobile products supporting 4G LTE and 5G NR functionalities infringe five patents related to wireless communication systems and methods.
  • Technical Context: The patents-in-suit address fundamental technologies for modern wireless networks, including methods for increasing data throughput, providing efficient network coverage with beamforming, enabling seamless handoffs between networks, and allocating network resources.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2008-01-23 ’802 Patent Priority Date
2011-04-12 ’802 Patent Issue Date
2011-04-29 ’888 Patent Priority Date
2011-07-28 ’347 Patent Priority Date
2011-08-24 ’196 Patent Priority Date
2013-10-08 ’196 Patent Issue Date
2014-08-01 ’361 Patent Priority Date
2014-11-18 ’347 Patent Issue Date
2015-07-28 ’888 Patent Issue Date
2019-07-30 ’361 Patent Issue Date
2023-06-16 Complaint Filing Date

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

U.S. Patent No. 7,924,802 - "Wireless Communication Systems and Methods," issued April 12, 2011

The Invention Explained

  • Problem Addressed: The patent describes a technical challenge in wireless communications where the amount of data that can be transmitted is limited by available bandwidth and regulatory power limits at a given frequency (’802 Patent, col. 1:36-50).
  • The Patented Solution: The invention proposes a method and system for increasing data throughput or reliability by simultaneously transmitting information across two different frequency ranges using a single wireless transmitter. The system uses two distinct up-converter circuits for two separate data streams, but combines the resulting signals before they are amplified by a single, shared power amplifier for transmission via one antenna (’802 Patent, col. 5:56-65; Fig. 2).
  • Technical Importance: This approach allows a transmitter to utilize spectrum more effectively or enhance reliability by transmitting redundant data, without the cost and complexity of a fully duplicated transmission chain (e.g., two power amplifiers and antennas) (’802 Patent, col. 7:13-18).

Key Claims at a Glance

  • The complaint asserts one or more claims, with specific allegations directed to independent claim 1 (Compl. ¶12).
  • Independent Claim 1 is a method claim with the following essential elements:
    • Transmitting first information across a first frequency range using a wireless transmitter.
    • Simultaneously transmitting second information across a second, different frequency range using the same wireless transmitter.
    • The second center frequency is greater than the first center frequency.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,554,196 - "Network Coverage by Cycling Through Beam Shape Coverage Configurations," issued October 8, 2013

The Invention Explained

  • Problem Addressed: The patent notes that wireless networks serve devices with different needs; some require a continuous connection (e.g., for a voice call), while others only need intermittent updates. Providing a single type of coverage, such as a wide, low-power beam to all devices, can be inefficient and provide suboptimal performance for high-demand users (’196 Patent, col. 1:12-19).
  • The Patented Solution: The invention discloses a method of providing network coverage by cycling through a sequence of different "coverage configurations." This involves alternating between a wide beam from a first network to provide general coverage for a group of devices, and a second, narrower beam from the same network that is directed at a specific "continuous use device" to provide a higher-power, more reliable signal. During the narrow-beam phase, "interval use devices" may be covered by a second, less capable network (’196 Patent, col. 2:26-44; Figs. 1A, 1B).
  • Technical Importance: This technique aims to improve power efficiency and bandwidth for high-demand users by focusing resources where needed, while maintaining basic connectivity for low-demand devices, thereby managing network resources more effectively (’196 Patent, col. 3:60-67).

Key Claims at a Glance

  • The complaint asserts one or more claims, with specific allegations directed to independent claim 1 (Compl. ¶20).
  • Independent Claim 1 is a method claim with the following essential elements:
    • Cycling over time through a coverage sequence that includes a first and second coverage configuration.
    • The first configuration includes transmitting a first beam from a first network for a group of devices.
    • The second configuration includes transmitting a second, narrower beam from the first network to at least one "continuous use device."
    • The second configuration also includes providing coverage by a second network to a plurality of "interval use devices."
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,891,347 - "User-focusing technique for wireless communication systems," issued November 18, 2014 (Multi-Patent Capsule)

  • Technology Synopsis: The ’347 Patent discloses a technique to mitigate signal distortion from multipath propagation. The method involves a receiver performing a channel estimation to obtain path parameter information, sending that information back to the transmitter, which then "pre-distorts" the signal before transmission so that the various multipath signals combine constructively, or "focus," at the receiver (’347 Patent, Abstract).
  • Asserted Claims: Independent claims 8, 15, and 19 (Compl. ¶28).
  • Accused Features: The complaint accuses cellular base stations and user equipment that support 3GPP 5G NR beamforming (Compl. ¶25).

U.S. Patent No. 9,094,888 - "Wireless device handoff between wireless networks," issued July 28, 2015 (Multi-Patent Capsule)

  • Technology Synopsis: The ’888 Patent describes methods for a wireless device to handoff between two different wireless networks. The system involves a first network receiving coverage information for a device, determining that the device could be covered by a second network, and transmitting a handoff request to that second network (’888 Patent, Abstract). The second network can then adapt its coverage (e.g., via beamforming) to accept the handoff.
  • Asserted Claims: Independent claim 20 (Compl. ¶36).
  • Accused Features: The complaint accuses cellular base stations that support handover functionality between 4G LTE and 5G NR wireless networks (Compl. ¶33).

U.S. Patent No. 10,368,361 - "Adaptive communication resource allocation in a wireless network," issued July 30, 2019 (Multi-Patent Capsule)

  • Technology Synopsis: The ’361 Patent discloses a method for adaptively allocating frequency spectrum resources in a wireless network. Resources are assigned to different pools (e.g., downlink, uplink, or shared) based on their signal quality characteristics. A scheduler then allocates resources from these pools for either uplink or downlink channels based on traffic demands, improving efficiency for asymmetric data traffic (’361 Patent, Abstract).
  • Asserted Claims: Independent claim 10 (Compl. ¶44).
  • Accused Features: The complaint accuses cellular base stations that support 3GPP NG-RAN functionalities such as directional Supplementary Uplink (SUL) and/or Bandwidth Adaptation (Compl. ¶41).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as "base station and mobile products" manufactured, used, or sold by Samsung that support various 4G LTE and 5G NR functionalities (Compl. ¶¶9, 17, 25, 33, 41). Specific product models are not identified.
  • Functionality and Market Context: The complaint alleges that the accused products incorporate specific functionalities that correspond to the asserted patents. These functionalities include "carrier aggregation" (’802 Patent), the use of "different types of beams and networks" for coverage (’196 Patent), "3GPP 5G NR beamforming" (’347 Patent), "handover between 4G LTE and 5G NR" (’888 Patent), and "directional Supplementary Uplink (SUL) and/or Bandwidth Adaptation" (’361 Patent) (Compl. ¶¶9, 17, 25, 33, 41). The complaint does not provide further technical details on the operation of these features but asserts they are integral to modern cellular products.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not attach, claim chart exhibits detailing its infringement theories for the asserted patents (Compl. ¶¶12, 20, 28, 36, 44). The narrative allegations suggest the following infringement theories.

’802 Patent Infringement Allegations

The complaint alleges that Samsung products supporting LTE and/or 5G carrier aggregation infringe the ’802 Patent (Compl. ¶9). Carrier aggregation is a standard feature in modern wireless networks that combines multiple frequency blocks (carriers) to increase data rates. The infringement theory appears to be that this practice of combining carriers for transmission constitutes the claimed method of "simultaneously transmitting" information across different frequency ranges using the same transmitter.

  • Identified Points of Contention:
    • Scope Questions: A potential point of dispute may be whether the term "simultaneously transmitting" as used in the patent, which describes a specific hardware architecture combining signals before a single power amplifier, reads on the standardized methods of carrier aggregation, which may be implemented differently at a technical level.
    • Technical Questions: The analysis may turn on the specific implementation of carrier aggregation in Samsung's products. For example, questions may be raised as to whether separate frequency carriers are processed and amplified in a manner that maps to the claim elements requiring combination before a single, shared power amplifier as depicted in the patent's specification (’802 Patent, Fig. 2).

’196 Patent Infringement Allegations

The complaint alleges that Samsung cellular base stations infringe the ’196 Patent by providing "network coverage using different types of beams and networks" (Compl. ¶17). Modern 5G NR and LTE networks use various beamforming techniques to manage coverage, including wide beams for cell-wide signaling and narrower, user-directed beams for data transmission. The infringement theory appears to be that this practice maps to the claimed method of "cycling" between a wide "first beam" and a narrower "second beam" based on user needs.

  • Identified Points of Contention:
    • Scope Questions: The infringement analysis may focus on whether the patent's terms "continuous use device" and "interval use devices" can be construed to cover the ways modern networks classify users or traffic (e.g., by Quality of Service requirements). The patent defines these terms based on the nature of the service, such as a voice call versus an email update (’196 Patent, col. 3:45-53).
    • Technical Questions: A key factual question may be whether Samsung's base stations actually perform the claimed "cycling" sequence. The complaint does not provide evidence that the accused systems switch between wide and narrow beams based on a specific determination that a device is a "continuous" versus an "interval" user, as required by the claim.

V. Key Claim Terms for Construction

  • For the ’802 Patent:

    • The Term: "simultaneously transmitting" (from claim 1).
    • Context and Importance: This term is central to the infringement analysis. Its construction will determine whether standardized techniques like carrier aggregation, where data is sent over multiple frequency bands within the same time intervals, fall within the claim's scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discusses the general goal of transmitting "many up-converted signals" using a "single power amplifier and a single antenna," which could suggest the term encompasses any method achieving this outcome, including modern multiplexing (’802 Patent, col. 7:10-18).
      • Evidence for a Narrower Interpretation: Figure 2 and its accompanying description show two physically separate signal paths that are combined at the input of the power amplifier, which could support a narrower construction requiring this specific hardware arrangement (’802 Patent, col. 6:50-65).

  • For the ’196 Patent:

    • The Term: "continuous use device" (from claim 1).
    • Context and Importance: The entire inventive concept of claim 1 rests on distinguishing between "continuous use" and "interval use" devices and applying different beam configurations to each. Infringement requires that the accused system makes this specific distinction. Practitioners may focus on this term because the complaint alleges infringement by standard 4G/5G systems, and it is a point of contention whether these standards categorize users in a way that maps directly to the patent's definitions.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides a general definition: "a device that may be actively involved in a substantially continuous service with the network" (’196 Patent, col. 3:45-47). This could be argued to cover any device with an active, high-throughput data session.
      • Evidence for a Narrower Interpretation: The specification provides specific examples of a "continuous service," such as "a voice call, a download, a content streaming, or the like" (’196 Patent, col. 3:49-51). This list of examples could be used to argue for a narrower definition limited to services with similar characteristics.

VI. Other Allegations

  • Indirect Infringement: For all five patents, the complaint alleges induced infringement, stating that Samsung encourages and instructs customers to use the accused products in an infringing manner through user manuals and online materials. It further alleges that the products are offered in a configuration that causes them to "perform the claimed method automatically" in their ordinary use (e.g., Compl. ¶10). Contributory infringement is also alleged on the basis that the accused products are not staple articles of commerce and are especially made or adapted to infringe (e.g., Compl. ¶11).
  • Willful Infringement: The complaint alleges that Samsung has knowledge of the patents and their infringement "Through at least the filing and service of this Complaint" (e.g., Compl. ¶10). This allegation appears to lay the groundwork for a claim of post-suit willful infringement rather than pre-suit willfulness.

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

The resolution of this dispute may turn on the following central questions:

  1. A core issue will be one of mapping technical standards to claim language: Can the specific methods and device classifications recited in the patent claims, drafted before the finalization of modern 5G standards, be shown to read on the complex, multi-faceted operations of standardized LTE and 5G NR functionalities like carrier aggregation and beam management?
  2. A key evidentiary question will be one of operational proof: The complaint accuses broad categories of standard-compliant products. The case may depend on what discovery reveals about the actual, specific operation of Samsung’s accused base stations and user equipment and whether Plaintiff can produce evidence showing these products perform the patented methods as claimed (e.g., cycling beam shapes based on a "continuous vs. interval use" distinction).