DCT

2:23-cv-00495

Pictiva Displays Intl Ltd v. Samsung Electronics Co Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00495, E.D. Tex., 12/17/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. has a regular and established place of business in the district, including facilities, employees, and authorized sales and service centers. Venue over the foreign parent, Samsung Electronics Co., Ltd., is alleged on the basis of its subjection to personal jurisdiction in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s consumer electronic products incorporating Organic Light-Emitting Diode (OLED) displays infringe six patents related to OLED device structure, materials, and manufacturing processes.
  • Technical Context: OLED displays are a dominant technology in the consumer electronics market, valued for superior image quality, power efficiency, and physical flexibility in devices such as smartphones, televisions, and tablets.
  • Key Procedural History: The complaint alleges a history of licensing negotiations between the parties beginning around September 2020. During these discussions, Plaintiff allegedly provided Defendant with claim charts mapping the ’389 Patent to Samsung's products and identified other patents it believed were infringed. The complaint also alleges Defendant had actual knowledge of the ’547 Patent as early as September 2016, based on its subsidiary citing the patent in an Information Disclosure Statement during the prosecution of its own patent application.

Case Timeline

Date Event
2002-05-02 U.S. Patent No. 6,949,389 Priority Date
2005-09-27 U.S. Patent No. 6,949,389 Issue Date
2007-09-19 U.S. Patent No. 8,314,547 Priority Date
2008-01-01 Samsung allegedly began incorporating OLED displays in its devices
2008-05-30 U.S. Patent No. 8,723,164 Priority Date
2008-09-26 U.S. Patent No. 8,558,223 Priority Date
2008-12-11 U.S. Patent No. 11,828,425 Priority Date
2012-09-27 U.S. Patent No. 9,257,492 Priority Date
2012-11-20 U.S. Patent No. 8,314,547 Issue Date
2013-10-15 U.S. Patent No. 8,558,223 Issue Date
2014-05-13 U.S. Patent No. 8,723,164 Issue Date
2016-02-09 U.S. Patent No. 9,257,492 Issue Date
2016-09-21 Alleged date of Samsung's actual knowledge of the ’547 Patent
2020-09-25 Pictiva allegedly notified Samsung of infringement
2020-10-07 Pictiva and Samsung Display Co. allegedly entered into an NDA
2020-12-16 Pictiva allegedly sent a claim chart for the ’389 Patent to Samsung
2021-06-01 Alleged date of Samsung's actual knowledge of the ’389, ’223, and ’164 Patents
2021-08-17 Pictiva allegedly reiterated license requirement to Samsung
2023-11-28 U.S. Patent No. 11,828,425 Issue Date
2024-12-17 Second Amended Complaint Filing Date

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

U.S. Patent No. 6,949,389 - "Encapsulation for Organic Light Emitting Diodes Devices"

  • Patent Identification: U.S. Patent No. 6949389, "Encapsulation for Organic Light Emitting Diodes Devices," issued September 27, 2005. (Compl. ¶35).
  • The Invention Explained:
    • Problem Addressed: The patent addresses the challenge of protecting sensitive OLED devices from environmental damage, primarily from oxygen and moisture. (Compl. ¶11; ’389 Patent, col. 1:8-9). Prior art thin-film encapsulation methods involved blanket-coating an entire substrate containing multiple OLED devices, which problematically covered electrical contact pads and required extra processing steps to clear them. (’389 Patent, col. 1:56-2:24).
    • The Patented Solution: The invention proposes a more targeted encapsulation method. It involves depositing a planarization layer over the devices, hardening it in a specific pattern to cover only the active OLED areas, removing the unhardened material, and then depositing a protective barrier layer only over the hardened planarization layer. (’389 Patent, col. 2:46-54). This approach avoids covering necessary electrical contacts and simplifies manufacturing. (Compl. ¶11).
    • Technical Importance: This selective encapsulation method was intended to provide cost reduction, improve reliability, and enable thinner, lighter, and more mechanically flexible OLED packages compared to prior art. (Compl. ¶11; ’389 Patent, col. 1:48-52).
  • Key Claims at a Glance:
    • The complaint asserts independent method claim 34. (Compl. ¶39).
    • The essential steps of claim 34 are:
      • fabricating a plurality of devices on a substrate;
      • selectively depositing at least one planarization layer upon said devices; and
      • selectively depositing at least one barrier layer over said planarization layer.

U.S. Patent No. 8,314,547 - "Opto-Electronic Component"

  • Patent Identification: U.S. Patent No. 8314547, "Opto-Electronic Component," issued November 20, 2012. (Compl. ¶44).
  • The Invention Explained:
    • Problem Addressed: The patent describes a device structure that can emit electromagnetic radiation during operation and also achieve a desired color impression in the switched-off state. (’547 Patent, col. 1:12-16).
    • The Patented Solution: The patent discloses an optoelectronic component where a "structured layer" is placed in the light path of an organic light-emitting source (e.g., a blue OLED). This structured layer is composed of two types of regions arranged laterally (side-by-side). "First regions" contain a wavelength conversion layer (e.g., quantum dots) that converts the source light into a second color (e.g., blue to red or green). "Second regions" contain a filter layer that is transparent to the source light (e.g., blue) but is opaque to at least part of the converted light (e.g., red or green). (Compl. ¶12; ’547 Patent, Abstract).
    • Technical Importance: This architecture provides a technical foundation for creating full-color displays from a single-color light source, a technique employed in modern display technologies to enhance color purity and efficiency. (Compl. ¶48).
  • Key Claims at a Glance:
    • The complaint asserts independent device claim 1. (Compl. ¶48).
    • The essential elements of claim 1 are:
      • An optoelectronic device, comprising:
      • an organic layer sequence emitting a first wavelength spectrum;
      • a structured layer downstream of the organic layer sequence with laterally arranged first and second regions;
      • the first regions including a wavelength conversion layer to convert the first spectrum to a second spectrum; and
      • the second regions including a filter layer that is opaque to a third spectrum (corresponding to part of the second spectrum) but is transparent to the first spectrum.

U.S. Patent No. 8,558,223 - "Organic Electronic Component and Method for the Production Thereof"

  • Patent Identification: U.S. Patent No. 8558223, "Organic Electronic Component and Method for the Production Thereof," issued October 15, 2013. (Compl. ¶54).
  • Technology Synopsis: The patent addresses the need for high electron conductivity in organic electronic components to improve efficiency and service life. The disclosed solution is an electron-conducting layer formed by the "joint vaporization" of a metal complex with a specific organic compound, which is alleged to increase the number of "free" electrons available for transport and improve conductivity. (Compl. ¶13).
  • Asserted Claims: Claim 1 (device claim) and unspecified method claims are asserted. (Compl. ¶¶58, 59).
  • Accused Features: The electron transport layer within Samsung’s OLED displays, which is alleged to be formed by the simultaneous vaporization of a lithium metal complex with an organic compound containing a heteroaromatic compound conjugated via a C-C bond. (Compl. ¶¶58, 59, 21-22).

U.S. Patent No. 8,723,164 - "Electronic Device"

  • Patent Identification: U.S. Patent No. 8723164, "Electronic Device," issued May 13, 2014. (Compl. ¶65).
  • Technology Synopsis: The patent is directed to improving charge carrier balance and efficiency in electronic devices. The solution comprises an organic functional layer containing at least three distinct matrix materials, each having specific, interrelated energy levels (LUMO and HOMO) and charge carrier mobilities to optimize the transport of electrons and holes. (Compl. ¶14).
  • Asserted Claims: Claim 16. (Compl. ¶69).
  • Accused Features: The organic functional layers in Samsung’s smartphone display panels (e.g., Galaxy S23 Ultra) are alleged to contain three matrix materials with the claimed energetic and mobility relationships. (Compl. ¶69).

U.S. Patent No. 9,257,492 - "Method for Producing a Passive Electronic Component, Method for Producing an Optoelectronic Assembly and Passive Electronic Component"

  • Patent Identification: U.S. Patent No. 9257492, "Method for Producing a Passive Electronic Component, Method for Producing an Optoelectronic Assembly and Passive Electronic Component," issued February 9, 2016. (Compl. ¶75).
  • Technology Synopsis: The patent describes a structure for an electronic component and a method for making it. The structure involves first and second electrically conductive layers separated by a trench, with a dielectric applied in a "structured fashion" to insulate the contact regions before a final electrode layer is applied over the dielectric. (Compl. ¶15).
  • Asserted Claims: Claim 16 (component claim) and unspecified method claims are asserted. (Compl. ¶¶79, 80).
  • Accused Features: The structure of Samsung's OLED display panels, which allegedly use ITO layers for the conductive layers, a pixel define layer (PDL) as the structured dielectric, and a cathode as the final electrode layer. (Compl. ¶79).

U.S. Patent No. 11,828,425 - "Organic-Light Emitting Diode"

  • Patent Identification: U.S. Patent No. 11828425, "Organic-Light Emitting Diode," issued November 28, 2023. (Compl. ¶86).
  • Technology Synopsis: The patent relates to the overall device structure of an OLED. The claimed device comprises an organic layer sequence, a radiation exit area, an encapsulation, and a carrier, where the organic layer sequence includes at least one radiation-emitting region and an electron transport layer that may be n-doped. (Compl. ¶16).
  • Asserted Claims: Claim 1. (Compl. ¶90).
  • Accused Features: The overall assembly of Samsung's smartphone display panels (e.g., Galaxy S23 Ultra), including their organic layer sequence, transparent cathode (radiation exit area), thin-film encapsulation, and carrier substrate. (Compl. ¶90).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are a broad category of Samsung consumer electronics that incorporate OLED displays. (Compl. ¶17). Specific examples cited in the complaint include Samsung Galaxy smartphones (such as the Galaxy S8, S9, S20, and S23 Ultra), Galaxy Book Pro laptops, tablets, personal wear products, and televisions (such as the S95B TV). (Compl. ¶¶17, 22, 39, 48, 69, 90).

Functionality and Market Context

  • The accused products utilize OLED, AMOLED (active-matrix organic light-emitting diode), and Super AMOLED display technologies. (Compl. ¶19). The complaint highlights Samsung's marketing of these displays for their superior image quality, thinness, power efficiency, and fast response speeds. (Compl. ¶19). One specific technology identified is QD-OLED, used in televisions, which employs a blue OLED light source with a quantum dot layer for color conversion. (Compl. ¶¶18, 48). The complaint alleges that Samsung is the global leader in the OLED market. (Compl. ¶18). A diagram in the complaint illustrates the layered structure of an accused QD-OLED display, showing a blue light source, a quantum dot light emitting layer, and a glass substrate. (Compl. p. 17).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,949,389 Infringement Allegations

Claim Element (from Independent Claim 34) Alleged Infringing Functionality Complaint Citation Patent Citation
A method of encapsulating a plurality of devices fabricated upon a substrate... comprising: fabricating a plurality of devices on a substrate; Samsung's manufacturing process for its OLED displays, which involves fabricating multiple OLED devices on an AMOLED substrate. A complaint visual depicts a plurality of OLED devices on a substrate. (Compl. p. 14). ¶39 col. 2:46-48
selectively depositing at least one planarization layer upon said devices; The manufacturing process allegedly includes selectively depositing at least one planarization layer upon the fabricated OLED devices. A complaint visual shows this layer being deposited over the OLED devices but not the surrounding substrate. (Compl. p. 14). ¶39 col. 3:2-4
and selectively depositing at least one barrier layer over said planarization layer. The process allegedly includes selectively depositing at least one barrier layer (identified as "Encapsulation layer 2" and "3" in a visual) over the previously deposited planarization layer. Another complaint visual illustrates that these layers are deposited so as to avoid covering the edge, data driver, or camera hole. (Compl. p. 15). ¶39 col. 3:4-5

Identified Points of Contention

  • Scope Questions: The infringement analysis for this method claim may focus on the term "selectively depositing". A central question is whether this term requires a deposition technique that is inherently directional and targeted (e.g., via a nozzle or shadow mask), or if it can be construed more broadly to cover a sequence of blanket deposition, patterned hardening, and subsequent removal of unhardened material—a process described elsewhere in the patent's specification but not explicitly recited in claim 34.
  • Technical Questions: A potential point of dispute is whether the layers in Samsung's process map to the claimed layers. For example, what evidence does the complaint provide that a layer identified as "Encapsulation layer 1" functions as a "planarization layer" distinct from the subsequent "barrier layer", as opposed to being the first of a multi-layer barrier stack?

U.S. Patent No. 8,314,547 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An optoelectronic device, comprising: an organic layer sequence which emits an electromagnetic radiation having a first wavelength spectrum during operation; Samsung's S95B TV, which allegedly contains an OLED panel with an organic layer sequence that emits blue light. ¶48 col. 8:25-29
a structured layer disposed downstream...including first and second regions which are arranged laterally... A layer in the accused TV that is allegedly structured into laterally arranged green/red subpixel regions ("first regions") and blue subpixel regions ("second regions"). The complaint provides a "QD-OLED structure diagram" to illustrate this arrangement. (Compl. p. 17). ¶48 col. 8:29-34
the first regions each including a wavelength conversion layer configured to convert...radiation having a first wavelength spectrum into...radiation having a second wavelength spectrum; The green and red subpixel regions allegedly contain a quantum dot ("QD") light emitting layer that functions as a wavelength conversion layer, converting the blue light into green and red light, respectively. ¶48 col. 8:35-40
and the second regions each including a filter layer which is at least partially opaque to...radiation having a third wavelength spectrum...and wherein the filter layer is transparent to the electromagnetic radiation having the first wavelength spectrum. The blue subpixel regions allegedly include a filter layer that allows the source blue light to pass through but is opaque to red and green light. ¶48 col. 8:41-49

Identified Points of Contention

  • Scope Questions: A primary dispute may arise over the term "filter layer". The infringement theory requires the blue subpixel regions of the accused QD-OLED displays to possess this structure. The question is whether the term requires a distinct, separately manufactured filtering component, or if it can be construed to cover a region that is merely a passive passthrough for the source light, potentially lacking any added material that performs an active filtering function.
  • Technical Questions: What evidence does the complaint provide that the blue subpixels in Samsung's QD-OLED displays physically contain a "filter layer" that is opaque to red and green light? The defense may argue that the blue subpixel is characterized by the absence of a quantum dot conversion layer, not the presence of a distinct filter layer as required by the claim.

V. Key Claim Terms for Construction

For the ’389 Patent (Claim 34)

  • The Term: "selectively depositing"
  • Context and Importance: This term is central to distinguishing the claimed method from prior art techniques that involved non-selective, blanket deposition of layers. The viability of the infringement allegation depends on whether Samsung's manufacturing process falls within the scope of this term. Practitioners may focus on this term because the patent specification describes multiple ways this could be achieved, from targeted application (e.g., with a nozzle) to a broader process of patterned curing and removal.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes an embodiment where a liquid organic layer is deposited over the entire device, followed by selective curing with a UV mask, and subsequent removal of the uncured liquid. (’389 Patent, col. 3:51-62). If "selectively depositing" is interpreted as the final state of the layer after this multi-step process, it could support a broader meaning.
    • Evidence for a Narrower Interpretation: Claim 34 recites "selectively depositing" without mentioning any curing or removal steps, unlike claim 1 which explicitly recites "hardening" and "removing." This textual difference suggests "selectively depositing" in claim 34 refers to the initial application of the material itself. The specification also discloses a gas nozzle system for directed material deposition, which represents a narrower, more targeted method of application. (’389 Patent, col. 7:32-46).

For the ’547 Patent (Claim 1)

  • The Term: "filter layer"
  • Context and Importance: The infringement case for the ’547 patent hinges on the presence of a "filter layer" in the blue subpixels of Samsung's QD-OLED displays. If this term is construed to require a specific, additive material component whose function is to filter light, the infringement allegation could be challenged if the accused blue subpixels are simply areas where the blue source light passes through without an added filter.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires the second regions to "includ[e] a filter layer" that performs a specific function (transparent to first spectrum, opaque to third). An interpretation focused on this function could allow any structure that achieves this result to qualify, regardless of how it is manufactured.
    • Evidence for a Narrower Interpretation: The claim describes a "structured layer" with two distinct region types: one with a "wavelength conversion layer" and the other with a "filter layer." This parallel construction suggests the "filter layer" is a physical component analogous to the "wavelength conversion layer," not merely an absence of it. The abstract similarly contrasts the two, stating the first regions "have a wavelength conversion layer" and the second regions "have a filter layer." (’547 Patent, Abstract).

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement for all six patents-in-suit. The allegations are based on Samsung intentionally aiding and encouraging third parties, such as vendors, customers, and partners, to make, use, sell, or import the accused products. (Compl. ¶¶ 40, 49, 60, 70, 81, 91). The complaint also alleges inducement through the distribution of products, provision of technical assistance, and literature featuring the infringing OLED displays. (Compl. ¶29).

Willful Infringement

  • Willfulness is alleged for all six patents-in-suit. The allegations are based on both pre-suit and post-suit knowledge.
    • Pre-suit Knowledge: The complaint alleges Samsung had actual knowledge of the ’547 patent since at least September 2016 from an Information Disclosure Statement filed by its subsidiary, Samsung Display Co. (Compl. ¶¶ 21, 51). Knowledge of the ’389, ’223, and ’164 patents is alleged based on licensing discussions that began in September 2020 and included the provision of claim charts and patent lists through August 2021. (Compl. ¶¶ 22-24, 42, 63, 73).
    • Post-suit Knowledge: The complaint alleges Samsung had actual knowledge of the ’223, ’164, ’492, and ’425 patents since at least the service of the First Amended Complaint in the action. (Compl. ¶¶ 26, 84, 94).

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

  • A core issue will be one of process scope: for the ’389 patent, can the method step of "selectively depositing" be construed to cover a multi-stage process of blanket application, patterned curing, and removal, or is it limited to a single-step, targeted application of material?
  • A key factual question will be one of structural presence: for the ’547 patent, do Samsung’s QD-OLED blue subpixels contain a distinct "filter layer" as claimed, or are they technically characterized by the absence of a quantum-dot conversion layer, potentially placing them outside the literal scope of the claim?
  • A determinative issue for damages will be one of scienter: given the detailed allegations of pre-suit notice through licensing negotiations and a patent office citation, the court will need to evaluate whether Defendant’s continued alleged infringement, if proven, was sufficiently egregious to meet the standard for willfulness.