DCT

2:23-cv-00587

Collision Communications Inc v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00587, E.D. Tex., 01/02/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains a regular and established place of business in Plano, Texas, which includes a Networks Innovation Center and R&D facilities. The foreign parent, Samsung Electronics Co., Ltd., is alleged to be subject to suit in any district where personal jurisdiction exists.
  • Core Dispute: Plaintiff alleges that Defendant’s broad range of 4G, 5G, and Wi-Fi enabled consumer electronics, smart appliances, and telecommunications infrastructure infringes six patents related to advanced methods for reducing signal interference in wireless networks.
  • Technical Context: The patents address multi-user detection (MUD) and parameter estimation techniques designed to enable reliable, real-time communication in overloaded or interference-heavy wireless environments.
  • Key Procedural History: This filing is a First Amended Complaint. The complaint alleges that the parties engaged in discussions regarding Plaintiff’s patented technology beginning around 2011. It further alleges that Plaintiff's patents have been cited during the prosecution of Defendant's own patent applications, which may be used to support allegations of pre-suit knowledge.

Case Timeline

Date Event
2000-09-20 U.S. Patent No. 6,947,505 Priority Date
2002-11-19 U.S. Patent No. 8,089,946 Priority Date
2003-04-14 U.S. Patent No. 7,463,703 Priority Date
2003-07-24 U.S. Patent No. 7,593,492 Priority Date
2003-11-25 U.S. Patent No. 7,920,651 Priority Date
2005-09-20 U.S. Patent No. 6,947,505 Issues
2008-09-26 U.S. Patent No. 9,814,071 Priority Date
2008-12-09 U.S. Patent No. 7,463,703 Issues
2009-09-22 U.S. Patent No. 7,593,492 Issues
~2011 Plaintiff and Defendant allegedly begin discussions regarding patented technology
2011-04-05 U.S. Patent No. 7,920,651 Issues
2012-01-03 U.S. Patent No. 8,089,946 Issues
2017-11-07 U.S. Patent No. 9,814,071 Issues
2025-01-02 First Amended Complaint Filing Date

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

U.S. Patent No. 7,463,703 - "Joint Symbol, Amplitude, and Rate Estimator"

  • Patent Identification: U.S. Patent No. 7,463,703, "Joint Symbol, Amplitude, and Rate Estimator," issued December 9, 2008.

The Invention Explained

  • Problem Addressed: As wireless networks become more crowded, multiple users transmit on the same channel, creating co-channel interference that can degrade or prevent reception of a specific user's signal (’703 Patent, col. 1:49-61). The patent notes that prior art multi-user detection (MUD) systems capable of handling such interference were often too computationally intensive for real-time operation, particularly in "overloaded" conditions where users exceed channel capacity (’703 Patent, col. 6:45-49, col. 5:50-53).
  • The Patented Solution: The invention is an apparatus that processes data streams from multiple users through a series of specialized estimators. The core of the solution is an iterative feedback loop: a bank of decoders generates initial symbol likelihood estimates, and these estimates are "iteratively fed back" to a symbol estimator and a joint amplitude estimator to refine their calculations in subsequent passes (’703 Patent, col. 8:27-33; Fig. 2). This iterative refinement process is intended to dramatically reduce the number of computations required to achieve reliable real-time signal separation (’703 Patent, col. 25:42-54).
  • Technical Importance: The invention proposed a computationally efficient architecture to make high-quality, real-time signal processing feasible in overloaded multi-user communication systems (Compl. ¶25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶56).
  • Claim 1 recites an apparatus comprising four main components:
    • An initial amplitude estimation unit for producing initial amplitude estimates.
    • A joint amplitude estimator for producing updated amplitude estimates.
    • A symbol estimator for producing symbol estimates for each user.
    • A bank of decoders that produces symbol likelihood estimates, which are then "iteratively fed back" to the symbol and joint amplitude estimators until a final condition is met.
  • The complaint reserves the right to assert other claims (Compl. ¶56).

U.S. Patent No. 7,920,651 - "Joint Symbol, Amplitude, and Rate Estimator"

  • Patent Identification: U.S. Patent No. 7,920,651, "Joint Symbol, Amplitude, and Rate Estimator," issued April 5, 2011.

The Invention Explained

  • Problem Addressed: The patent addresses the same technical challenge as the ’703 Patent: the difficulty of separating interfering user signals in real-time within crowded, or "supersaturated," communication channels (Compl. ¶26; ’651 Patent, col. 7:46-52).
  • The Patented Solution: This patent claims a joint amplitude estimator that divides an incoming data stream into multiple "observation intervals." For each interval, a processing module "computes a filter" and applies it to the data to produce individual amplitude estimates. A central amplitude estimation unit then processes these individual estimates to calculate new, updated amplitude estimates, which are then "iteratively passed back" to the processing modules to refine the filter for subsequent processing loops (’651 Patent, claim 1; col. 10:1-12).
  • Technical Importance: This patent describes an alternative iterative method, centered on computing and refining a filter, to achieve efficient joint estimation of signal parameters in multi-user systems (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶64).
  • Claim 1 recites a joint amplitude estimator comprising:
    • A data stream divided into a plurality of "observation intervals."
    • Processing modules that "compute a filter" for each interval and use it to generate individual amplitude estimates.
    • An amplitude estimation unit that calculates "new amplitude estimates" from the individual ones.
    • An iterative loop where the "new amplitude estimates are iteratively passed back to said processing modules."
  • The complaint also mentions an analogous method is claimed, suggesting claim 6 may also be at issue (Compl. ¶26), and reserves the right to assert other claims (Compl. ¶64).

Multi-Patent Capsules

  • U.S. Patent No. 8,089,946: "Bandwidth Efficient Wireless Network Modem," issued January 3, 2012.
    • Technology Synopsis: The patent addresses deficiencies in prior art multiuser receivers, which could distort or lose the signal of interest in interference environments (’946 Patent, col. 3:48-3:3). The solution is a modem designed to "exploit the channel densities possible with multiuser receivers," thereby providing more efficient use of wireless network bandwidth (Compl. ¶27; ’946 Patent, col. 3:4-9).
    • Asserted Claims: At least independent claim 1 (Compl. ¶72).
    • Accused Features: Samsung products equipped with "hot spot functionality and interference cancellation technology" (Compl. ¶72).
  • U.S. Patent No. 7,593,492: "Combinational Hybrid Turbo-MUD," issued September 22, 2009.
    • Technology Synopsis: The patent addresses the trade-off in Multi-User Detection (MUD) systems between high-complexity MUDs (slow but accurate) and low-complexity MUDs (fast but poor quality) (’492 Patent, col. 4:48-5:4). The invention proposes a system with a "decision unit" that adaptively selects the most appropriate MUD for a given situation based on a set of criteria, optimizing performance and complexity (Compl. ¶28; ’492 Patent, Abstract).
    • Asserted Claims: At least independent claim 1 (Compl. ¶80).
    • Accused Features: Samsung devices with "interference cancellation technology" (Compl. ¶80).
  • U.S. Patent No. 9,814,071: "Media Access Control Protocol for Multiuser Detection Enabled Ad-Hoc Wireless Communications," issued November 7, 2017.
    • Technology Synopsis: The patent addresses the problem of "collisions" in shared ad-hoc networks, where only one node can transmit at a time (’071 Patent, col. 1:37-48, 3:4-13). The invention proposes a method using MUD technology that allows a "plurality of nodes transmit simultaneously over a shared communication channel" by separating parameter-detecting signals into separate channels while data signals remain on shared channels, thereby increasing network capacity (’071 Patent, col. 3:18-23; claim 1).
    • Asserted Claims: At least independent claim 1 (Compl. ¶90).
    • Accused Features: "Accused Base Station Products" (Compl. ¶90).
  • U.S. Patent No. 6,947,505: "System For Parameter Estimation and Tracking of Interfering Digitally Modulated Signals," issued September 20, 2005.
    • Technology Synopsis: The patent tackles the difficulty of accurately estimating signal parameters (power, phase, etc.) in a dynamic multiuser environment where signals vary from burst to burst (’505 Patent, col. 1:32-41). The solution is a system that isolates a "newcomer" signal by recreating the training sequences of all known signals on a channel and subtracting them from the total received signal, providing an interference-free signal from which to estimate the newcomer's parameters (’505 Patent, col. 2:24-34).
    • Asserted Claims: At least independent claim 1 (Compl. ¶99).
    • Accused Features: Samsung 4G and 5G devices with "interference cancellation technology" (Compl. ¶99).

III. The Accused Instrumentality

Product Identification

The complaint names a vast array of Samsung products with 4G, 5G, and/or Wi-Fi capabilities as the "Accused Products" (Compl. ¶31). This includes flagship smartphone lines (Galaxy S, Z Fold/Flip), tablets (Galaxy Tab), and wearables (Galaxy Watch), as well as Wi-Fi enabled smart appliances such as refrigerators, ranges, and televisions (Compl. ¶¶32-35). The allegations also extend to network infrastructure, specifically "Accused Base Station Products" that support MU-MIMO (Multi-User, Multiple-Input, Multiple-Output) functionality (Compl. ¶37).

Functionality and Market Context

The relevant functionality is the products' alleged use of "interference cancellation technology" to operate on modern wireless standards like 4G LTE, 5G, and Wi-Fi (Compl. ¶¶56, 64). The complaint provides a screenshot from Samsung's website promoting the "HyperFast 5G" capabilities of its Galaxy S22 phones, which deliver "incredible download and upload speeds" (Compl. ¶46, p. 29). Another screenshot highlights the "2x faster, consistent connection" enabled by Wi-Fi 6E (Compl. ¶46, p. 30). These marketing materials are presented as evidence of Samsung encouraging users to engage in the infringing use of these advanced wireless features.

IV. Analysis of Infringement Allegations

The complaint references external exhibits for detailed claim charts, which were not available for this analysis. The following tables summarize the infringement theory based on the narrative allegations in the complaint and the language of the asserted patents.

’703 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an initial amplitude estimation unit processing said data stream and producing initial amplitude estimates... The accused devices’ receivers perform an initial estimation of signal strength for incoming data streams from multiple users. ¶56 col. 8:12-16
a symbol estimator... produc[ing] a plurality of symbols estimates for each user The devices’ processors estimate the transmitted data symbols (bits) for each user signal present in the data stream. ¶56 col. 8:19-22
a bank of decoders... producing a plurality of symbol likelihood estimates for each user Chipsets within the devices contain decoders that process the estimated symbols and calculate confidence or likelihood values for those symbols. ¶56 col. 8:22-26
wherein said symbol likelihood estimates are iteratively fed back to said symbol estimator and said joint amplitude estimator... The accused devices are alleged to use the output from the decoders to refine and improve subsequent symbol and amplitude calculations in a feedback loop. ¶56 col. 8:27-33

’651 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a data stream from said multiple users divided into a plurality of observation intervals The accused devices process incoming wireless data by segmenting it into discrete blocks or intervals for analysis. ¶64 col. 10:1-2
a plurality of processing modules... computes a filter for each of said observation intervals The devices' processors are alleged to compute a processing filter (e.g., an MMSE filter) for each data segment to help separate user signals. ¶64 col. 10:2-4
an amplitude estimation unit which processes said individual amplitude estimates and calculates new amplitude estimates... Based on the filtered data, the devices calculate updated estimates of the signal strength for each user. ¶64 col. 10:4-8
wherein said new amplitude estimates are iteratively passed back to said processing modules... These updated amplitude estimates are allegedly fed back to the filtering stage to improve interference cancellation in the next processing cycle. ¶64 col. 10:8-12
  • Identified Points of Contention:
    • Technical Questions: A primary technical question for both the ’703 and ’651 patents will be whether the accused products, which operate according to public standards like 4G/5G, actually implement the specific proprietary iterative feedback architectures described in the claims. The complaint alleges the use of "interference cancellation technology," but the central issue for the court may be whether this technology functions in the particular iterative manner claimed by the patents or through a different, non-infringing (e.g., standard-compliant, single-pass) method.
    • Scope Questions: For the ’651 Patent, a scope question may arise regarding the term "observation intervals." The analysis may question whether this term should be construed broadly to cover any form of data windowing performed by the accused devices, or more narrowly to mean specific, structured intervals tied to the patent's embodiments.

V. Key Claim Terms for Construction

  • The Term: "iteratively fed back" (’703 Patent, claim 1) / "iteratively passed back" (’651 Patent, claim 1)
  • Context and Importance: These phrases are the central mechanism of the claimed inventions. The entire infringement case for these patents likely depends on whether the accused devices' signal processing involves a feedback loop where the outputs of a later processing stage (e.g., decoding or amplitude estimation) are used as inputs to refine the calculations of an earlier stage (e.g., symbol estimation or filtering). Practitioners may focus on this concept because it distinguishes the claimed invention from simpler, linear, or single-pass processing architectures.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specifications describe the overall goal of using iterative processing to reduce computational complexity and achieve real-time operation (’703 Patent, col. 25:42-54; ’651 Patent, col. 8:1-4). A party might argue that any system that uses outputs to refine inputs in successive cycles, regardless of the specific architecture, meets this definition.
    • Evidence for a Narrower Interpretation: The patents illustrate specific feedback paths. In the ’703 Patent, Figure 2 shows a direct loop from the "Bank of Soft-Decoders" (130) back to the "MMSE-based Symbol Estimator" (105) and "MMSE-based Joint Amplitude Estimator" (120). A party could argue that the term is limited by this disclosed embodiment to a loop between these specific, claimed functional blocks. Similarly, for the ’651 patent, the claim requires passing estimates back to the "processing modules" that compute the filter (’651 Patent, claim 1).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Samsung's advertising, sales materials, and user manuals encourage customers to use the 4G, 5G, and Wi-Fi features of the Accused Products in an infringing manner (Compl. ¶¶45-46). The complaint includes screenshots of Samsung's marketing for "HyperFast 5G" and "faster" Wi-Fi as evidence of this encouragement (Compl. ¶46, pp. 29-30). Contributory infringement is also pleaded for the ’071 patent, alleging the Accused Base Station Products are not staple articles of commerce and are especially made or adapted for infringing use (Compl. ¶49).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It claims Samsung was aware of the patents and infringement as early as 2011 from direct "communications with Collision" (Compl. ¶¶55, 63). It also asserts that Samsung had knowledge because Collision's patents were cited during the prosecution of Samsung's own patent applications (Compl. ¶23).

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

  1. Technical Implementation: A central evidentiary question will be one of functional operation: do the accused Samsung products, which operate under public 4G/5G/Wi-Fi standards, actually perform the specific, proprietary iterative feedback loops for interference cancellation as claimed in the asserted patents, or do they employ distinct, standard-compliant signal processing techniques?
  2. Claim Scope and Architecture: A key legal question will be one of structural correspondence: can the functional blocks recited in the claims (e.g., "joint amplitude estimator," "symbol estimator," "bank of decoders") be mapped onto the components of the highly integrated chipsets in Samsung's products, or is there a fundamental mismatch between the claimed architecture and the accused hardware and software?
  3. Pre-Suit Knowledge: A critical factual question for willfulness and potential damages enhancement will be the substance of prior notice: what evidence can Plaintiff produce regarding the alleged 2011 discussions, and does that evidence establish that Samsung had actual knowledge of the asserted patents and their alleged infringement?