DCT

2:24-cv-00049

Mullen Industries LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00049, E.D. Tex., 12/03/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains regular and established places of business in the district, and because Defendant Samsung Electronics Co., Ltd. is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile phones, tablets, smart watches, and associated server systems infringe eight U.S. patents related to location-based services, security measures for mobile devices, and remote call notifications.
  • Technical Context: The patents address technologies for remotely locating mobile devices and managing user access rights, as well as providing notifications on companion devices, which are foundational features in the modern smartphone and wearable device ecosystem.
  • Key Procedural History: The complaint notes that Mullen Industries LLC previously filed a patent infringement suit against Apple Inc., a primary competitor of Samsung, asserting the same patents-in-suit, suggesting Plaintiff's infringement theories may be well-developed.

Case Timeline

Date Event
2002-03-25 Priority Date for ’575, ’283, ’039, ’218, ’418, ’117, ’024 Patents
2003-03-14 Priority Date for ’633 Patent
2013-02-12 U.S. Patent No. 8,374,575 Issued
2015-12-01 U.S. Patent No. 9,204,283 Issued
2021-08-17 U.S. Patent No. 11,096,039 Issued
2021-08-31 U.S. Patent No. 11,109,218 Issued
2021-09-14 U.S. Patent No. 11,122,418 Issued
2021-11-30 U.S. Patent No. 11,190,633 Issued
2022-01-25 U.S. Patent No. 11,234,117 Issued
2022-02-08 U.S. Patent No. 11,246,024 Issued
2024-12-03 Complaint Filing Date

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

U.S. Patent No. 11,234,117 - “Systems and Methods for Locating Cellular Phones and Security Measures for the Same”

  • Patent Identification: U.S. Patent No. 11,234,117, entitled “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued January 25, 2022 (Compl. ¶29).

The Invention Explained

  • Problem Addressed: The patent’s background section notes that while GPS has been integrated into cellular phones, the location information determined by these signals is "only minimally utilized" (ʼ117 Patent, col. 1:28-33).
  • The Patented Solution: The invention describes a system where a user of one device can locate another user's device based on access rights assigned by the requested user (’117 Patent, Abstract). These security measures and access rights are preferably stored and managed on a remote system (e.g., a server or database), creating an "information brokering scheme" that allows users to grant different levels of location access (e.g., exact location, city, or country) to different people (’117 Patent, col. 1:37-54; col. 2:15-21).
  • Technical Importance: This framework for permission-based, user-to-user location sharing managed by a remote system was a key technical step toward the development of modern social location services like "Find My Friends." (Compl. ¶¶4-7).

Key Claims at a Glance

  • The complaint asserts infringement of claim 15 (Compl. ¶44).
  • The essential elements of independent claim 15 include:
    • A wireless telephone comprising a processor, a positioning system for determining a location of the device, and memory storing programming.
    • The programming is capable of displaying a plurality of users, each associated with a different wireless telephone.
    • The programming is capable of receiving a first manual input in the form of a selection of one of said plurality of users.
    • The programming is capable of receiving an input of a login and a password.
    • The programming is capable of providing the login and password to a remote server for determining whether to allow access to location information for the selected user’s telephone.
    • The determination includes identifying the user via the login, determining the password is associated with the login, and determining whether the selected user has provided access rights.
    • The programming is capable of assigning location access rights to the selected user's telephone for obtaining its location.
    • The programming is capable of receiving said location information from a server and displaying said location information.
  • The complaint also asserts infringement of claims 1-92 (Compl. ¶43).

U.S. Patent No. 11,190,633 - “Systems and Methods for Providing Remote Incoming Call Notification for Cellular Phones”

  • Patent Identification: U.S. Patent No. 11,190,633, entitled “Systems and Methods for Providing Remote Incoming Call Notification for Cellular Phones,” issued November 30, 2021 (Compl. ¶30).

The Invention Explained

  • Problem Addressed: The patent’s background describes that users often miss notifications from their cellular phones when the phone is stored in a location like a purse, where audible rings are dampened and physical vibrations cannot be sensed (ʼ633 Patent, col. 1:20-35).
  • The Patented Solution: The invention discloses a remote notification device, such as a watch, that receives communication signals from a mobile phone corresponding to different events (e.g., incoming call, calendar event). The remote device then provides its own user-perceivable notifications (e.g., visual, haptic, audio) to alert the user, overcoming the physical barrier between the user and the phone (’633 Patent, Abstract; col. 2:1-14). The device also includes motion sensing.
  • Technical Importance: This technology establishes the core functionality of a companion device that acts as a remote notifier for a primary mobile device, a concept central to the smartwatch market. (Compl. ¶¶80-81, 88).

Key Claims at a Glance

  • The complaint asserts infringement of at least claim 1 (Compl. ¶81).
  • The essential elements of independent claim 1 include:
    • A watch for use with a mobile telephonic device that provides notification of an incoming call.
    • The watch comprises a watch band, a second watch band, and a buckle.
    • The watch includes a device operable to receive first and second wireless communication signals associated with a first event and a different second event from the mobile device.
    • The device includes a battery.
    • The device includes motion sensing operable to distinguish between a plurality of different types of motion.
    • The device is operable to provide a first user-perceivable notification signal dependent on the first communication signal, and a second user-perceivable notification signal dependent on the second communication signal.
  • The complaint reserves the right to assert other claims (Compl. ¶81).

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 11,122,418, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued September 14, 2021 (Compl. ¶31).

  • Technology Synopsis: The ’418 Patent is directed to a system where a first wireless device’s location can be provided to a remote system and requested by a second wireless device, outside of an active call, based on permissions stored on that remote system (’418 Patent, Abstract).

  • Asserted Claims: At least claims 1, 2, 6, 7, 10, 13, and 17 (Compl. ¶99).

  • Accused Features: Samsung phones and tablets are accused of infringing by using location-based services (e.g., SmartThings Find, Google Maps) where a user can request and receive another user's location from a remote server, with access controlled by permissions granted by the first user (Compl. ¶¶102, 104-105).

  • Patent Identification: U.S. Patent No. 11,109,218, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued August 31, 2021 (Compl. ¶32).

  • Technology Synopsis: The ’218 Patent is directed to a wireless telephonic device that, after requesting location access, displays a map including indicia representing the locations of multiple users, distance, compass directions, an address, and travel time (’218 Patent, Abstract; claim 11).

  • Asserted Claims: At least claims 11-15 (Compl. ¶121).

  • Accused Features: Samsung phones and tablets running Google Maps are accused of infringing by requesting location access and then displaying a map with navigational data, including the user's location, a destination, a travel route, distance, travel time, and a compass (Compl. ¶¶123, 126).

  • Patent Identification: U.S. Patent No. 11,096,039, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued August 17, 2021 (Compl. ¶33).

  • Technology Synopsis: The ’039 Patent is directed to a remote system that identifies users via login/password, records their location, and provides location-based event notifications (e.g., arrival at a location) based on manually pre-selected, region-based, and distance-based criteria (’039 Patent, Abstract; claim 1).

  • Asserted Claims: At least claims 1, 4, 7, 8, 9, and 13 (Compl. ¶139).

  • Accused Features: The Samsung server systems supporting SmartThings Find are accused of infringing by authenticating users, recording device locations, and providing location-based event notifications (e.g., when a device arrives at or leaves a user-defined area) (Compl. ¶¶145-148).

  • Patent Identification: U.S. Patent No. 9,204,283, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued December 1, 2015 (Compl. ¶34).

  • Technology Synopsis: The ’283 Patent describes methods for mobile-to-mobile locating where a user selects another user from a display, provides login credentials to a remote server, and the server determines access rights before transmitting location information back to the requesting device (’283 Patent, Abstract).

  • Asserted Claims: At least claims 1, 2, 6, 8, 9, 13, 15, 16, and 17 (Compl. ¶165).

  • Accused Features: Samsung’s performance of methods for providing location-based services through its phones, tablets, and servers is accused of infringing by enabling the display and selection of users, authentication via a remote server, determination of access rights, and transmission of location data for display (Compl. ¶¶170-175).

  • Patent Identification: U.S. Patent No. 8,374,575, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued February 12, 2013 (Compl. ¶35).

  • Technology Synopsis: The ’575 Patent describes methods for mobile-to-mobile locating where a device can direct a remote server to change the list of users who are permitted to access its location. The remote server then transmits the location to authorized users and can provide directional information (’575 Patent, Abstract).

  • Asserted Claims: At least claims 1, 2, 3, 6, 8, 13, 23, 24, 26, 28, 30, 31, 32, 35, 37, 38-40, 42, and 44 (Compl. ¶183).

  • Accused Features: Samsung’s performance of methods via its devices and servers is accused of infringing by allowing users to manage a list of other users on a remote server who can access their location and by providing directional information between users (Compl. ¶¶188, 192-193).

  • Patent Identification: U.S. Patent No. 11,246,024, “Systems and Methods for Locating Cellular Phones and Security Measures for the Same,” issued February 8, 2022 (Compl. ¶36).

  • Technology Synopsis: The ’024 Patent describes a remote server system that receives a location from a first phone, receives a selection of another user from that phone, uses login/password information to authenticate and determine access rights, and transmits the location information back to the first phone (’024 Patent, Abstract).

  • Asserted Claims: At least claims 1-14, 16-20, 22-35, 37-41, 43-50, 53-57, 59-69, 71-75, 77, and 78, including claim 24 (Compl. ¶200).

  • Accused Features: Samsung's remote server systems are accused of infringing by performing the steps of receiving device locations, user selections, and login information from phones, and then determining and enforcing access rights before transmitting location data back to the user's device (Compl. ¶¶205-213).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are broadly categorized as Samsung’s mobile phones (e.g., Galaxy S23, S22, A54), tablets (e.g., Galaxy Tab S9), smart watches, and the associated server systems that support their location-based and notification functionalities (Compl. ¶¶42, 80, 98, 120, 138, 164, 182, 199). The software features specifically named are Samsung SmartThings Find and Google Maps (Compl. ¶54).

Functionality and Market Context

  • The complaint alleges that the accused products incorporate location-based technologies (using GPS, Wi-Fi, and cellular signals) and motion-sensing technologies (using accelerometers and gyroscopes) (Compl. ¶¶50-51, 85-86). These technologies enable commercially significant features such as finding lost devices, sharing real-time location with contacts, receiving navigational directions, and getting notifications from a paired phone on a smartwatch (Compl. ¶¶54, 67, 83, 88). The complaint presents these features as central to the user experience of Samsung's mobile and wearable products. A screenshot from the complaint shows the SmartThings Find interface displaying multiple users on a map. (Compl. p. 19).

IV. Analysis of Infringement Allegations

11,234,117 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
a wireless telephone comprising a processor,...a positioning system...and memory storing programming Samsung phones and tablets include processors (e.g., Snapdragon), a positioning system (e.g., GPS), and memory storing an operating system and applications. ¶46-53 col. 9:25-31; Fig. 15
capable of displaying a plurality of users, wherein each one of said plurality of users is associated to a different one of a plurality of wireless telephones The SmartThings Find and Google Maps applications display multiple users (contacts, family members) on a map, each associated with their own device. ¶57-58 col. 8:42-51; Fig. 4
capable of receiving a first manual input in a form of a selection of one of said plurality of users The applications allow a user to manually tap on or select a specific user from the displayed list or map to view their location or get directions. ¶59-60 col. 6:53-57
capable of receiving an input in a form of a login and a second manual input in a form of a password The applications require the user to sign into a Samsung or Google account using a login and password to access location-sharing features. ¶61-62 col. 9:55-61; Fig. 13-14
capable of providing said login and said password to a remote server for use in determining whether to allow access of location information The device transmits the user's login credentials to a remote server, which authenticates the user and checks permissions before granting access to another user's location. ¶63 col. 5:15-25
capable of assigning location access rights to said one of said plurality of wireless telephones The applications provide an interface for a user to grant or revoke location access rights to other users. ¶64-65 col. 3:24-33; Fig. 9
capable of receiving said location information...from a server and displaying said location information After authentication and permission checks by the server, the device receives the selected user's location data and displays it on a map. ¶66-67 col. 5:21-25; Fig. 6
  • Identified Points of Contention:
    • Scope Questions: A potential issue may be whether Samsung’s distributed, cloud-based architecture for its services constitutes the "remote server" as contemplated by the patent, which has a 2002 priority date.
    • Technical Questions: The analysis may focus on whether the sequence of operations in the accused products—user selection, authentication, permission check, and data display—maps precisely onto the steps required by the claim, particularly the interplay between the local device programming and the remote server’s determination process.

11,190,633 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A watch for use with a mobile telephonic device that provides notification of an incoming call Samsung smartwatches are used with mobile phones and notify the user of incoming calls to the phone. A complaint screenshot shows this functionality. (Compl. p. 30). ¶81 col. 1:11-14
said watch comprising: a watch band; a second watch band; a buckle... Samsung watches are sold with and comprise these standard components. ¶82 col. 2:54-57
a device operable to receive first wireless communication signals associated with a first event and second wireless communication signals associated with a second event...wherein said first event and second event are different Samsung watches receive distinct wireless notifications for different events from a paired phone, such as an incoming call, a missed call, a text message, and a calendar reminder. ¶83 col. 2:1-5
said device includes a battery Samsung watches are battery-powered. ¶84 col. 2:58-60
said device includes motion sensing operable to distinguish between a plurality of different types of motion The watches include accelerometers and gyroscopes used for step detection, fall detection, and gesture controls, which allegedly distinguish between different types of motion. ¶85-87 col. 2:5-9
said device is operable to provide first user-perceivable notification signals...and...second user perceivable notification signals The watches provide distinct visual, audio, and haptic signals corresponding to the different types of received notification events. ¶88 col. 2:9-14
  • Identified Points of Contention:
    • Scope Questions: A central question may be the interpretation of "motion sensing operable to distinguish between a plurality of different types of motion." The dispute could turn on whether general fitness tracking or UI gesture recognition meets this functional requirement as understood in the patent’s context.
    • Technical Questions: An evidentiary question may arise regarding whether the different user alerts (e.g., a short vibration versus a long vibration) are sufficiently distinct to qualify as separate "first" and "second" user-perceivable notification signals tied to different "first" and "second" events as required by the claim structure.

V. Key Claim Terms for Construction

  • Term: "remote server" (from ’117 Patent and related family)

  • Context and Importance: This term is central to the infringement theory for the location-services patents. The definition is critical for determining whether Samsung's modern, distributed cloud infrastructure (alleged to run on platforms like AWS) meets the architectural limitations described in patents with a 2002 priority date. Practitioners may focus on this term because the technological landscape of server architecture has changed significantly since the patent's filing.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification uses broad language, referring to a "remote system, such a remote database, facility, distribution center, or any other system," which may support an interpretation that covers modern cloud architectures (’117 Patent, col. 5:11-14).
    • Evidence for a Narrower Interpretation: The patent's figures and descriptions of the "information brokering scheme" could be argued to imply a more centralized or monolithic server structure, potentially allowing Samsung to argue its distributed system is technically different (’117 Patent, col. 2:15-21).

  • Term: "motion sensing operable to distinguish between a plurality of different types of motion" (from ’633 Patent)

  • Context and Importance: This functional language is a key limitation in the claim asserted against Samsung’s smartwatches. The outcome of the case for this patent may hinge on whether the accused motion sensing features—used for fitness, health, and UI gestures—perform the claimed function.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language is broad and does not specify which types of motion must be distinguished. Plaintiff will argue that distinguishing between walking, falling, and a wrist gesture are sufficient to meet the limitation (Compl. ¶¶86-87).
    • Evidence for a Narrower Interpretation: The patent specification, if it provides specific examples or a particular context for the motion sensing, could be used to argue for a narrower construction that excludes the general-purpose fitness and UI functions of the accused watches.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Samsung induces infringement by providing customers with user manuals and instructions on how to use the accused features, such as sharing location via SmartThings Find and Google Maps (Compl. ¶¶69-71, 90). It also alleges contributory infringement on the basis that the accused location-based and motion-sensing technologies have no substantial non-infringing uses (Compl. ¶¶73, 91).
  • Willful Infringement: The complaint alleges that Samsung had pre-suit knowledge of the patents-in-suit and their infringement based on several grounds: (1) direct meetings between Samsung representatives and the inventor, Jeff Mullen; (2) Samsung’s alleged monitoring of litigation against its primary competitor, Apple, which involved the same patents; and (3) general industry monitoring (Compl. ¶¶9-14). Plaintiff alleges that Samsung’s infringement has been and continues to be willful, wanton, and flagrant (Compl. ¶18).

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

  • A core issue will be one of architectural equivalence: does Samsung’s modern, distributed cloud infrastructure for its location services technically and legally correspond to the "remote server" or "remote system" architecture disclosed in patents with a 2002 priority date? The court will have to determine if the differences are merely implementation details or fundamental distinctions that avoid infringement.
  • A key evidentiary question for the smartwatch patent (’633) will be one of functional scope: do the general-purpose motion sensors in Samsung watches, used for fitness and UI gestures, perform the specific claimed function of being "operable to distinguish between a plurality of different types of motion," or will Samsung successfully argue that this is a mischaracterization of their intended and actual operation?
  • The allegations of pre-suit knowledge will present a critical question of willfulness: what evidence can Plaintiff produce to substantiate its claims of meetings and litigation monitoring, and can that evidence establish that Samsung acted with the requisite knowledge and intent to justify a finding of willful infringement and potential enhanced damages?