DCT

2:23-cv-00319

Staton Techiya LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00319, E.D. Tex., 10/11/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Samsung Electronics America, Inc. has regular and established places of business within the Eastern District of Texas, and Defendant Samsung Electronics Co., Ltd. is a foreign corporation subject to suit in any U.S. judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s Bixby-enabled electronic devices, including smartphones, earphones, tablets, and smart appliances, infringe six patents related to personalized sound management, active noise cancellation, and other audio processing technologies.
  • Technical Context: The technology at issue resides in the highly competitive consumer electronics market, where advanced audio features such as voice assistance, noise cancellation, and environmental sound awareness are critical for product differentiation.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patents and their scope by monitoring the prosecution of the Plaintiff's patent portfolio, a fact which, if proven, could support a finding of willful infringement.

Case Timeline

Date Event
2007-01-22 U.S. Patent No. 11,710,473 Priority Date
2007-03-07 U.S. Patent No. 11,750,965 Priority Date
2007-05-06 U.S. Patent No. 11,683,643 Priority Date
2008-09-19 U.S. Patent No. 11,665,493 Priority Date
2008-09-22 U.S. Patent No. 11,610,587 Priority Date
2012-12-17 U.S. Patent No. 11,659,315 Priority Date
2023-03-21 U.S. Patent No. 11,610,587 Issued
2023-05-23 U.S. Patent No. 11,659,315 Issued
2023-05-30 U.S. Patent No. 11,665,493 Issued
2023-06-20 U.S. Patent No. 11,683,643 Issued
2023-07-25 U.S. Patent No. 11,710,473 Issued
2023-09-05 U.S. Patent No. 11,750,965 Issued
2023-10-11 Complaint Filing Date

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

U.S. Patent No. 11,610,587 - “Personalized Sound Management and Method”

The Invention Explained

  • Problem Addressed: The patent addresses the problem of "acoustic overload," where individuals are inundated with a diversity of sounds, making it difficult to distinguish important acoustic information and potentially impacting health and safety (’587 Patent, col. 1:29-41).
  • The Patented Solution: The invention is a system for personalizing a user's acoustic environment by intelligently managing sound. The system uses a microphone to capture ambient audio and analyzes it in a dedicated "audio buffer" to detect specific "sonic signatures," such as a voice command or a siren. Upon detection, it can notify the user. The system also sends a "modified" version of the microphone signal to a separate "data buffer" for storage, allowing a user to later request playback of a recorded sound segment (’587 Patent, Abstract; col. 22:25-45).
  • Technical Importance: This technology describes a framework for smart audio devices to not only react to specific sound events in real-time but also to provide an audio lookback or recording functionality, enhancing user control over their acoustic environment.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (’587 Patent, col. 24:12-45; Compl. ¶63). The essential elements are:
    • A system comprising a user interface and an audio device with a microphone, speaker, memory, an audio buffer, a data buffer, and a processor.
    • The processor is configured to perform operations including:
      • receiving a microphone signal and sending a portion to the audio buffer;
      • analyzing the audio buffer for a "sonic signature";
      • notifying a user when the sonic signature is detected;
      • sending a "modified microphone signal" to the data buffer, replacing or adding to previous data; and
      • sending a portion of data from the data buffer to the speaker in response to a user request, where the request is a voice command or manual input.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,659,315 - “Methods and Mechanisms for Inflation”

The Invention Explained

  • Problem Addressed: The patent background notes that conventional earpieces often "fail to adequately compensate for ambient noise," diminishing the user's listening experience (’315 Patent, col. 1:45-46).
  • The Patented Solution: The patent describes an earpiece with a specific three-microphone array: two ambient microphones to capture external sound and one internal ear canal microphone. A logic circuit uses signals from these microphones to generate a "noise reduction signal." This noise reduction signal is then mixed with a desired audio signal (e.g., music, voice call), and the resulting "modified audio signal" is sent to the earpiece speaker, thereby implementing an active noise cancellation (ANC) system (’315 Patent, Abstract; col. 24:1-29).
  • Technical Importance: The invention specifies a hardware configuration and signal processing method for achieving effective noise cancellation in compact in-ear devices, a key feature in the premium earphone market.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (’315 Patent, col. 23:7-29; Compl. ¶80). The essential elements are:
    • An earpiece comprising: a first ambient microphone, a second ambient microphone, and an ear canal microphone.
    • The earpiece also includes a speaker, memory, and a logic circuit.
    • The logic circuit is configured to perform operations comprising:
      • generating a noise reduction signal using a signal from at least one of the microphones;
      • receiving an audio signal;
      • generating a mixed audio signal by mixing the noise reduction signal with the audio signal; and
      • sending a modified audio signal, which includes the mixed audio signal, to the speaker.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,665,493 - “Acoustic Sealing Analysis System”

  • Technology Synopsis: This patent addresses a system for testing the quality of an acoustic seal in an earphone. The invention involves an audio device generating a test signal with a low-frequency component (30-200Hz), sending it to an earphone's speaker, and using a microphone within the earphone to receive the resulting signal inside the ear canal. The system then performs a "non-phase calculation" (e.g., coherence, correlation, difference) to determine the seal quality and provides a message to the user (’493 Patent, Abstract; Compl. ¶93).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶91).
  • Accused Features: The complaint accuses Samsung's "Galaxy Earbud fit test," which is managed by devices like the Galaxy S23 smartphone. This feature is alleged to emit a "chime, chirp, or musical signal" into a connected earphone and analyze the sound that escapes the ear canal to evaluate and report the quality of the fit to the user (Compl. ¶94-96). The complaint provides an instructional graphic for the "Galaxy Earbud fit test," showing the user interface for initiating the test and viewing the results (Compl. ¶96).

U.S. Patent No. 11,683,643 - “Method and Device for in Ear Canal Echo Suppression”

  • Technology Synopsis: This patent describes a multi-microphone earpiece designed for echo and noise suppression. The device includes two ambient microphones and one ear canal microphone. A processor uses signals from these microphones to generate a "background noise reduction signal," which is then mixed with an "audio content signal" to create a final mixed signal that is sent to the speaker. The system is designed to manage audio in environments with background noise (’643 Patent, Abstract; Compl. ¶109).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶107).
  • Accused Features: The complaint accuses Samsung's earphone products, including the Galaxy Buds series, which feature multiple microphones and Active Noise Cancellation (ANC). These products are alleged to generate a background noise reduction signal using a combination of ambient and inner ear microphone signals, which is then mixed with audio content and sent to the speaker (Compl. ¶110).

U.S. Patent No. 11,750,965 - “Acoustic Dampening Compensation System”

  • Technology Synopsis: The patent discloses an earbud system that intelligently adjusts audio when it detects the user is speaking. The system uses two ambient sound microphones (ASMs) and one ear canal microphone (ECM) to analyze signals and detect speech. Upon detection, the processor adjusts various audio signals, such as the ambient sound pass-through or the audio content, to improve the user's ability to hear their own voice in noisy environments (’965 Patent, Abstract; Compl. ¶124).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶122).
  • Accused Features: The complaint targets Bixby-enabled Samsung earpieces like the Galaxy Buds2 Pro. It alleges that when these devices detect a user speaking a wake phrase such as "Hi Bixby," the processor adjusts the ambient sound signal to allow the user to hear their own voice more clearly (Compl. ¶125).

U.S. Patent No. 11,710,473 - “Method And Device For Acute Sound Detection And Reproduction”

  • Technology Synopsis: This patent describes a system where one device (e.g., a smartphone) controls ambient sound pass-through in a separate earpiece. The control device sends an "audio content gain value" and an "ambient sound gain value" to the earpiece. The earpiece processor then applies these respective gains to the audio content and ambient sound signals before mixing them and presenting the result to the user (’473 Patent, Abstract; Compl. ¶139).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶137).
  • Accused Features: The accused system is the combination of a Samsung phone (e.g., Galaxy S23) and a connected Samsung earbud. The complaint alleges the phone connects via Bluetooth and, when a user activates the "Ambient sound" feature, sends gain values to the earpiece processor to control the mixing of ambient sound with audio content (Compl. ¶140).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a broad range of Samsung products, including the Samsung Galaxy S23 smartphone, Samsung Galaxy Buds2 Pro earphones, Samsung Galaxy Tab S8 tablet, Samsung Galaxy Watch 5, Samsung Neo QLED 8K Smart TV, and the Samsung Family Hub refrigerator. The central accused functionality is enabled by the Bixby voice-driven user interface and platform (Compl. ¶33-34). The complaint provides a representative image of the Samsung Galaxy S23 Series smartphones (Compl. ¶36).

Functionality and Market Context

  • The accused products are alleged to incorporate microphones to capture user voice commands and ambient sounds, which are then processed by the Bixby platform for speech recognition and natural language analysis (Compl. ¶57). Bixby is used to control device actions, such as initiating phone calls or changing TV channels (Compl. ¶56, ¶58). Specific accused functionalities include the "Hi Bixby" wake-word detection, Active Noise Cancellation (ANC) in earphones like the Galaxy Buds Pro, and an "Ambient Sound Mode" that allows external sounds to be passed through to the user (Compl. ¶47, ¶66, ¶81). The complaint illustrates the multi-microphone architecture of the Galaxy Buds Pro, identifying an "Inner Mic" and a "Dual mic array" for external beamforming (Compl. p. 12), and a similar layout for the Galaxy Buds+ (Compl. p. 13). Plaintiff alleges that Bixby is a key feature integrated across more than 160 million Samsung devices globally, indicating its central role in Samsung's product ecosystem (Compl. p. 16).

IV. Analysis of Infringement Allegations

'587 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
analyzing the audio buffer for detecting a sonic signature Processors in Bixby-enabled devices are configured to analyze audio signals to detect a sonic signature, such as the voice command "Hi Bixby," to initiate the function of the Bixby application. ¶66 col. 22:25-28
sending a modified microphone signal to the data buffer replacing or adding to previous data stored in the data buffer Bixby-enabled devices allegedly filter incoming microphone signals using a "voice filter" to improve speech recognition, and these modified signals are provided to a data buffer. ¶66 col. 22:32-35
sending a portion of the data stored in the data buffer, spanning a time period, to the speaker in response to a user request... Processors in Bixby-enabled devices are configured to receive speech commands that prompt playback from the data buffer, including voice recordings, music, and voice responses. ¶66 col. 22:36-45
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the functional distinction between the claimed "audio buffer" (for analysis) and "data buffer" (for storage and playback) maps onto the architecture of the accused Bixby system. The defense could argue its system uses a single or different buffering scheme that does not align with the claim's two-buffer structure.
    • Technical Questions: The complaint alleges that a "modified microphone signal" is sent to the data buffer, identifying this as a "voice filter" to improve recognition. A point of contention may be what specific modification occurs and whether it constitutes the "modifying" step as required by the claim, distinct from the initial "analyzing" step.

'315 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first ambient microphone...a second ambient microphone...an ear canal microphone Samsung earbuds such as the Galaxy Buds Pro and Buds2 Pro are alleged to have three microphones: two outer (ambient) microphones and one inner (ear canal) microphone. ¶81 col. 5:50-55
generating a noise reduction signal using at least one of the first...second...or the third microphone signal... The Active Noise Cancellation (ANC) feature in Samsung earbuds allegedly uses the onboard microphones to detect ambient noise and electronically generate opposite sound frequencies, creating a noise reduction signal. ¶81 col. 6:1-10
generating a mixed audio signal by mixing the noise reduction signal with the audio signal When ANC is active, the earbuds are allegedly configured to generate a mixed audio signal by mixing a primary audio signal (voice or music) with the generated noise reduction signal. ¶81-82 col. 6:10-14
  • Identified Points of Contention:
    • Technical Questions: What evidence does the complaint provide that the accused Broadcom chipsets (e.g., BCM43014, BCM43015) perform the specific sequence of steps of generating a noise reduction signal, receiving a separate audio signal, and then mixing the two? The infringement theory relies on specific operations within these components, which are alleged on "information and belief."
    • Scope Questions: Does the term "ear canal microphone" as used in the patent read on the "Inner Mic" of the accused Samsung earbuds? While functionally similar, the precise location and operation will be relevant to claim construction and infringement analysis.

V. Key Claim Terms for Construction

For the ’587 Patent

  • The Term: "sonic signature"
  • Context and Importance: This term is the trigger for the claimed system's core functions. The complaint alleges it is met by the "Hi Bixby" voice command. The construction of this term will determine whether the claim is limited to specific types of sounds (e.g., spoken words, alarms) or covers a broader range of acoustic events.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to sonic signatures in the context of a wide variety of sounds, including emergency vehicle sirens, and describes them generally as "acoustic information relevant for personalized sound management applications" (’587 Patent, col. 24:36-39; col. 2:2-4).
    • Evidence for a Narrower Interpretation: The summary of the invention states that "each sonic signature is identified using a Gaussian mixture model," which could be argued to limit the term to sounds identifiable by that specific technical method (’587 Patent, col. 1:63-65).

For the ’315 Patent

  • The Term: "logic circuit"
  • Context and Importance: This term defines the component responsible for executing all the claimed signal processing steps. Plaintiff identifies Broadcom chipsets as the infringing "logic circuit." Its construction is key to determining whether a single, integrated component must perform all functions or if the functions can be distributed across multiple components.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide a specific definition for "logic circuit," which may support a broad interpretation covering any processor, DSP, ASIC, or combination of hardware and software that collectively performs the claimed functions.
    • Evidence for a Narrower Interpretation: The specification lacks language that would clearly support a narrow construction. A defendant might argue that if the claimed functions are performed by separate, non-integrated processors, no single "logic circuit" meets the limitation, though this is often a difficult argument to sustain.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Samsung induces infringement by providing marketing materials and user manuals that instruct customers on how to use the accused features, such as activating Bixby and using Active Noise Cancellation on its earbuds (Compl. ¶29-31, ¶71, ¶82).
  • Willful Infringement: The complaint alleges willful infringement based on both pre- and post-suit knowledge. Pre-suit knowledge is alleged on the basis that Samsung has "monitored the prosecution of the Techiya patent portfolio" and therefore had actual notice of the patents and their scope prior to the lawsuit being filed (Compl. ¶26, ¶72, ¶86). Post-suit knowledge is based on Samsung's awareness of the patents since at least the filing of the complaint (Compl. ¶27).

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

  • A core issue will be one of definitional scope: can the patent term "sonic signature," described in the context of personalized sound management, be construed to cover the "Hi Bixby" wake-word detection implemented in Samsung's general-purpose voice assistant? Similarly, does the "chime" used in Samsung's "Earbud fit test" meet the specific claim requirements for a "test signal" used to determine seal quality?
  • A key evidentiary question will be one of operational mapping: does the signal processing architecture within Samsung's Bixby platform and its earphone chipsets perform the specific, sequential steps recited in the claims—such as creating a distinct "modified microphone signal" for a "data buffer" in the '587 Patent, or mixing a "noise reduction signal" with an "audio signal" in the '315 Patent—or does it achieve a similar outcome through a technically distinct method?
  • A central question for damages and potential enhancement will be one of pre-suit knowledge: what evidence can Plaintiff produce to support its allegation that Samsung actively monitored the prosecution of the asserted patent portfolio, thereby establishing the requisite knowledge for willful infringement before the complaint was filed?