Redstone Logics LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Redstone Logics LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:23-cv-00485, E.D. Tex., 10/17/2023
• 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 allegedly has regular and established places of business within the district.
• Core Dispute: Plaintiff alleges that certain Samsung System-on-Chip (SoC) architectures and thermal management components used in its mobile devices infringe two patents related to multi-core processor communication and thermal conduction panels.
• Technical Context: The patents address distinct technical challenges in modern electronics: managing power and communication between different processor core groups, and efficiently dissipating heat in compact electronic assemblies.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or specific licensing history concerning the patents-in-suit.

Case Timeline

Date	Event
2010-02-26	U.S. Patent No. 8,549,339 Priority Date
2013-01-11	U.S. Patent No. 9,253,925 Priority Date
2013-10-01	U.S. Patent No. 8,549,339 Issued
2016-02-02	U.S. Patent No. 9,253,925 Issued
2023-10-17	Complaint Filed

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

U.S. Patent No. 8,549,339 - “Processor core communication in multi-core processor,” issued October 1, 2013

The Invention Explained

• Problem Addressed: In conventional multi-core processors, all processor cores typically share the same supply voltage and clock signal to simplify their interfaces. However, for power management, it is desirable to dynamically adjust the voltage and clock speed for different groups of cores based on their workload, which complicates communication between these independently-clocked groups (’339 Patent, col. 1:5-14).
• The Patented Solution: The invention describes a multi-core processor divided into distinct regions or "stripes," where each stripe can receive an independent supply voltage and clock signal (’339 Patent, col. 2:20-31). To manage communication between these asynchronous regions, an "interface block" is used. This block can idle communications when a region's clock frequency is changing and then resume communication once the new clock signal is stable, ensuring data integrity (’339 Patent, col. 4:17-24, col. 8:56-65). Figure 3 illustrates this concept, showing interface blocks (300, 304) mediating between processor cores (152, 154, 156) that are each driven by separate clock signals.
• Technical Importance: This approach allows for granular, per-region power management in complex SoCs without sacrificing reliable communication between different parts of the chip.

Key Claims at a Glance

• The complaint’s allegations reference independent claim 1 (Compl. ¶12).
• Independent Claim 1 recites a multi-core processor comprising:
  • A first set of processor cores configured to dynamically receive a first supply voltage and a first output clock signal from a first phase lock loop (PLL).
  • A second set of processor cores configured to dynamically receive a second, independent supply voltage and a second, independent output clock signal from a second PLL.
  • An interface block coupled between the first and second sets of cores, configured to facilitate communication between them.
• The complaint reserves the right to assert other claims (Compl. ¶9).

U.S. Patent No. 9,253,925 - “Panel for enhancing thermal conduction in an electronic assembly,” issued February 2, 2016

The Invention Explained

• Problem Addressed: Electronic assemblies require structures that both provide physical stiffness and dissipate heat generated by components. Traditional solutions can be heavy or inefficient at spreading heat away from localized hot spots on a circuit board (’925 Patent, col. 1:6-18).
• The Patented Solution: The patent describes a composite material panel designed to be part of a "heat frame" for an electronic assembly (’925 Patent, col. 2:56-65). The panel is made of "contiguous sections" and is constructed from a material (e.g., embedded graphite fibers) with anisotropic thermal properties. It is highly conductive in directions parallel to its surface but has low conductivity in the direction perpendicular to its surface (’925 Patent, col. 5:44-65). This allows the panel to rapidly spread heat laterally away from a hot electronic device towards the edges of the assembly where it can be dissipated. The abstract notes the panel has sections with inner surfaces oriented "within twenty-five degrees of parallel" to the device mounting surface.
• Technical Importance: This technology enables the creation of lightweight, stiff, and highly effective thermal management solutions for densely packed, high-power electronics, such as those in modern mobile devices.

Key Claims at a Glance

• The complaint’s allegations reference independent claim 3 (Compl. ¶19).
• Independent Claim 3 recites an electronic assembly comprising:
  • A support structure with walls enclosing a space.
  • A circuit substrate with a mounting surface.
  • An electronic device attached to the mounting surface within the space.
  • A panel coupled to the support structure, comprising "contiguous sections."
  • Each section has an inner surface facing the mounting surface and is "oriented within twenty-five degrees of parallel to said mounting surface."
  • Each section has a first thermal conductivity (substantially parallel to its inner surface) that is greater than a second thermal conductivity (substantially perpendicular to its inner surface).
• The complaint reserves the right to assert other claims (Compl. ¶17).

III. The Accused Instrumentality

Product Identification

The complaint names the Samsung Galaxy S23 as a representative product infringing the ’339 Patent and the Samsung Galaxy S22 as a representative product infringing the ’925 Patent (Compl. ¶9, ¶17). More broadly, the accused instrumentalities are:

• For the ’339 Patent: Products with SoCs that comprise "two or more sets of processors supporting or based on the DynamIQ Shared Unit architecture (e.g., ARMv8.2, ARMv9 ARMv9.2, and successors)" (Compl. ¶9).
• For the ’925 Patent: Products "comprising graphite thermal conduction transfer panels" (Compl. ¶17).

Functionality and Market Context

The complaint alleges that the accused SoCs perform infringing methods of processor communication and that the accused thermal panels provide infringing heat dissipation (Compl. ¶9, ¶17). The complaint does not provide further detail on the technical operation or market positioning of the accused features beyond these high-level identifications.

IV. Analysis of Infringement Allegations

The complaint states that claim charts are attached as exhibits but does not include them in the filing. It alleges infringement of independent claim 1 of the ’339 Patent and independent claim 3 of the ’925 Patent (Compl. ¶12, ¶19).

For the ’339 Patent, the infringement theory is that Samsung products incorporating ARM's DynamIQ Shared Unit architecture necessarily practice the claimed method of managing communication between processor core sets operating in different voltage and frequency domains (Compl. ¶9).

For the ’925 Patent, the infringement theory is that "graphite thermal conduction transfer panels" found in certain Samsung products, such as the Galaxy S22, embody the claimed structure with contiguous sections, specific orientation, and anisotropic thermal properties (Compl. ¶17).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question for the ’925 Patent will be whether a commercially used "graphite thermal conduction transfer panel" meets the structural definition of "contiguous sections," each "oriented within twenty-five degrees of parallel" to the mounting surface, as recited in the claims. The interpretation of "contiguous sections" may be disputed, particularly whether it can read on a single, layered sheet of material.
• Technical Questions: For the ’339 Patent, a key factual question is whether the operation of the accused "DynamIQ Shared Unit architecture" maps onto the specific claim limitations requiring an "interface block" that idles and resumes communication based on the stable locking of PLLs for different processor regions. The complaint does not specify how the commercial architecture performs this function.

V. Key Claim Terms for Construction

Term (’339 Patent): "interface block" (from claim 1)

• Context and Importance: This term defines the core component responsible for managing communication between independently clocked processor regions. The scope of this term is critical, as a narrow construction may not cover the accused DynamIQ architecture, while a broad one might raise validity questions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim itself provides a functional definition: "an interface block coupled to the first set... and... the second set..., wherein the interface block is configured to facilitate communication between the first set... and the second set" (’339 Patent, col. 8:1-5). This suggests any component performing that function could qualify.
  • Evidence for a Narrower Interpretation: The specification discloses specific embodiments of the interface block, including one comprising a "first level shifter" (’339 Patent, col. 8:6-14) and another comprising a "synchronizer" (’339 Patent, col. 8:21-28). A defendant may argue these embodiments limit the term's scope to these or structurally similar implementations.

Term (’925 Patent): "contiguous sections" (from claim 3)

• Context and Importance: This term defines the fundamental structure of the claimed thermal panel. Whether the accused graphite panels have this structure will be a primary infringement question. Practitioners may focus on this term because its construction will determine if a single, multi-layered, or flexible graphite sheet can be considered to have multiple "contiguous sections."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "contiguous" is sharing a common border or touching. A defendant might argue that different areas of a single sheet of material with different properties or orientations could be considered "contiguous sections." Claim 1 states a second section is contiguous with a first, which is a very general description (’925 Patent, col. 10:46-48).
  • Evidence for a Narrower Interpretation: The patent figures consistently depict the panel as being formed from multiple, distinct, and often angled planar sections (e.g., FIG. 1B, sections 118, 112, 122; FIG. 6, sections 606, 610, etc.). Plaintiff may argue that the term requires this type of piecewise, multi-faceted construction, not just different regions on a single flat sheet.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for the ’339 Patent. Inducement is based on allegations that Samsung provides user manuals and online materials that instruct customers on the use of the accused products, and that the infringing method is performed automatically "out of the box" (Compl. ¶10). Contributory infringement is based on allegations that the accused products are especially made to infringe and are not staple articles of commerce (Compl. ¶11). For the ’925 Patent, only contributory infringement is explicitly alleged on a similar basis (Compl. ¶18).

Willful Infringement

The complaint does not explicitly plead willfulness. It alleges knowledge for inducement of the ’339 Patent "Through at least the filing and service of this Complaint" (Compl. ¶10), which would only support a claim for post-filing enhancement of damages, not pre-suit willfulness.

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

The resolution of this case appears to hinge on two primary types of questions that the court will need to resolve:

1. A question of technical mapping: For the ’339 Patent, can discovery demonstrate that the commercial "DynamIQ Shared Unit architecture" in Samsung’s SoCs operates in a manner that is functionally and structurally equivalent to the claimed system, specifically regarding the "interface block" and its method of idling and resuming communications based on PLL stability?

2. A question of definitional scope and evidence: For the ’925 Patent, the case will likely turn on whether the accused "graphite thermal conduction transfer panels" meet the claim requirements. This raises two sub-issues: first, a legal question of claim construction regarding the meaning of "contiguous sections," and second, an evidentiary question of whether the accused panels can be shown to possess the claimed physical orientation and anisotropic thermal conductivity properties.