DCT

2:24-cv-00203

Apex Beam Tech LLC v. Samsung Electronics Co Ltd

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00203, E.D. Tex., 03/20/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants are subject to personal jurisdiction, have committed acts of infringement in the district, and maintain a regular and established place of business there. It is also alleged that Samsung Electronics Co., Ltd., as a foreign corporation, may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s 5G-enabled mobile handsets, tablets, and notebooks infringe thirteen patents related to transmission schemes in wireless communication systems.
  • Technical Context: The technologies at issue concern methods for managing complex data transmission, antenna configurations, and resource allocation in advanced wireless networks, such as 5G, to enhance efficiency and reliability.
  • Key Procedural History: The complaint alleges that Defendants had actual knowledge of several of the patents-in-suit from "related prior litigations." For certain patents, the complaint specifically references a prior complaint dated November 30, 2021, which may be relevant to allegations of willful infringement.

Case Timeline

Date Event
2016-11-01 U.S. Patent No. 11,063,727 Priority Date
2016-12-03 U.S. Patent No. 11,546,110 Priority Date
2017-01-22 U.S. Patent No. 11,374,721 Priority Date
2017-04-19 U.S. Patent No. 11,457,426 Priority Date
2017-04-19 U.S. Patent No. 11,917,581 Priority Date
2017-07-25 U.S. Patent No. 11,626,904 Priority Date
2019-11-05 U.S. Patent No. 10,965,434 Priority Date
2019-11-05 U.S. Patent No. 11,139,944 Priority Date
2019-11-07 U.S. Patent No. 10,986,695 Priority Date
2019-11-20 U.S. Patent No. 11,108,639 Priority Date
2019-12-07 U.S. Patent No. 10,979,128 Priority Date
2019-12-07 U.S. Patent No. 11,637,615 Priority Date
2021-03-30 U.S. Patent No. 10,965,434 Issued
2021-04-13 U.S. Patent No. 10,979,128 Issued
2021-04-20 U.S. Patent No. 10,986,695 Issued
2021-07-13 U.S. Patent No. 11,063,727 Issued
2021-08-31 U.S. Patent No. 11,108,639 Issued
2021-10-05 U.S. Patent No. 11,139,944 Issued
2021-11-30 Date of prior complaint mentioned for willfulness allegations
2022-06-28 U.S. Patent No. 11,374,721 Issued
2022-09-27 U.S. Patent No. 11,457,426 Issued
2023-01-03 U.S. Patent No. 11,546,110 Issued
2023-04-11 U.S. Patent No. 11,626,904 Issued
2023-04-25 U.S. Patent No. 11,637,615 Issued
2024-02-27 U.S. Patent No. 11,917,581 Issued
2024-03-20 Complaint Filing Date

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

U.S. Patent No. 11,063,727 - Method and Device in UE and Base Station for Multi-Antenna System

The Invention Explained

  • Problem Addressed: The patent background describes the context of multi-antenna systems, implying a need to efficiently manage increasingly complex antenna configurations and associated signaling at the base station side (Compl. ¶22; ’727 Patent, col. 1:15-28).
  • The Patented Solution: The invention provides a method for a user equipment (UE) to report channel information by using distinct signaling and reference signals for different subsets of antenna ports. The UE receives a "first signaling" to determine a set of L1 antenna ports and a "second signaling" to determine a set of Q2 antenna ports, then uses corresponding reference signals to generate channel information for a combined set of Q antenna ports, where Q is the sum of Q1 and Q2 subsets (’727 Patent, Abstract; col. 3:1-15).
  • Technical Importance: This approach provides a flexible scheme for channel state information (CSI) reporting in advanced multi-antenna systems, which is a foundational element for enabling high-performance 5G communications (Compl. ¶22).

Key Claims at a Glance

  • The complaint asserts at least independent claim 11 (Compl. ¶38).
  • Claim 11 recites a User Equipment (UE) for multi-antenna transmission, comprising:
    • a first receiver for receiving a first signaling, a second signaling, a first reference signal and a second reference signal;
    • a first transmitter for transmitting first channel information;
    • wherein the first reference signal comprises Q1 reference signal port(s) transmitted by Q1 antenna port(s), and the second reference signal comprises Q2 reference signal port(s) transmitted by Q2 antenna port(s);
    • wherein the first signaling is used to determine L1 antenna port(s), with the Q1 antenna port(s) being a subset of the L1 antenna ports, and the second signaling is used to determine the Q2 antenna port(s);
    • wherein the first channel information corresponds to a total of Q antenna ports, consisting of the Q1 and Q2 antenna ports;
    • wherein the first reference signal is transmitted in a first time resources pool and the second reference signal is in a second time resources pool, with the first reference signal occurring multiple times in its pool and the second occurring once in its pool.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,374,721 - Method and Device for Wireless Communication

The Invention Explained

  • Problem Addressed: The patent addresses the need for an efficient method of uplink transmission in a wireless system, particularly the coordination between an initial access signal and a subsequent data transmission (’721 Patent, col. 1:19-21; Compl. ¶23).
  • The Patented Solution: The invention describes a UE that transmits a first wireless signal (e.g., a Random Access Channel preamble) and a second wireless signal (e.g., on a Physical Uplink Shared Channel). A key aspect is that the time interval between the transmission of these two signals is used to determine the specific wireless resource for the second signal out of a set of candidate resources (’721 Patent, Abstract; col. 3:20-40).
  • Technical Importance: This method provides a structured way to link an initial resource request to a subsequent data transmission, which is a fundamental procedure for devices connecting to a cellular network and sending data.

Key Claims at a Glance

  • The complaint asserts at least independent claim 11 (Compl. ¶54).
  • Claim 11 recites a user equipment for wireless communication, comprising:
    • a first processor transmitting a first wireless signal;
    • a first transmitter transmitting a second wireless signal;
    • wherein the first wireless signal is generated by a first sequence and is used to determine a first time interval between a first time instant (start of the first signal) and a second time instant (start of the second signal);
    • wherein the second wireless signal occupies a first wireless resource, which is one of J candidate wireless resources;
    • wherein the first time interval is used to determine the first wireless resource out of the J candidate resources;
    • wherein the first sequence is a Zadoff-Chu (ZC) sequence, the first signal's transport channel is a Random Access Channel (RACH), and the second signal's physical channel is a Physical Uplink Shared Channel (PUSCH);
    • wherein the first wireless signal is used to determine whether the second wireless signal is transmitted or not.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,457,426 - Method and Device in User Equipment (UE) and Base Station Used for Paging

  • Technology Synopsis: This patent relates to a method for receiving paging messages in a system with multiple numerologies (different signal configurations). The invention describes a UE monitoring a first signaling (e.g., on a PDCCH) in specific time intervals to find scheduling information for a first radio signal (e.g., on a PDSCH) that carries the paging message. (Compl. ¶24, ¶74).
  • Asserted Claims: At least independent claim 11 is asserted (Compl. ¶75).
  • Accused Features: The accused features are the paging functionalities of Samsung's 5G devices that allegedly monitor control channels for paging information according to 5G standards (Compl. ¶76-77).

U.S. Patent No. 11,546,110 - Method and Device for Multi-Antenna Transmission in User Equipment (UE) and Base Station

  • Technology Synopsis: The patent describes a multi-antenna transmission method where a UE receives a radio signal transmitted by K antenna port groups. A downlink signaling is used to determine a "time resource pool," and an "antenna virtualization vector" available to the UE within that pool is associated with one of the antenna port groups. (Compl. ¶25, ¶95).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶96).
  • Accused Features: The accused features involve the reception of signals like Channel State Information Reference Signals (CSI-RS) or Synchronization Signal/Physical Broadcast Channel (SS/PBCH) blocks from multiple antenna port groups and the processing of associated downlink control information (Compl. ¶98-100).

U.S. Patent No. 11,626,904 - Method and Device for Multi-Antenna Transmission in User Equipment (UE) and Base Station

  • Technology Synopsis: This patent relates to a scheme for reporting channel quality in a multi-antenna system. A UE receives a wireless signal from K antenna port groups and uses RRC signaling to determine a target threshold. The UE reports channel state information based on a comparison of channel quality values (e.g., RSRPs) for a subset of K1 antenna port groups against this threshold. (Compl. ¶26, ¶113).
  • Asserted Claims: At least independent claim 11 is asserted (Compl. ¶114).
  • Accused Features: The accused features relate to the 5G-compliant method of reporting channel state information (CSI), which allegedly involves measuring reference signals from multiple antenna ports, comparing quality metrics, and transmitting a CSI report via PUCCH or PUSCH (Compl. ¶116-118).

U.S. Patent No. 11,917,581 - Method and Device in UE and Base Station Used for Paging

  • Technology Synopsis: This patent is directed to a method for receiving paging messages in a communication system. A UE monitors signaling in X time intervals to get scheduling information (time-frequency resource, MCS, subcarrier spacing) for a radio signal that carries a paging message. A key aspect is that the location of a frequency subband used for the signaling helps determine the X time intervals. (Compl. ¶27, ¶129).
  • Asserted Claims: At least independent claim 13 is asserted (Compl. ¶130).
  • Accused Features: This patent is asserted against the paging functionalities of the accused 5G devices, similar to the '’426 Patent, but with a focus on how the location of frequency resources for control signaling determines the monitoring intervals (Compl. ¶131-132, ¶137).

U.S. Patent No. 10,965,434 - Scheduling Activation and Release

  • Technology Synopsis: This patent describes a method for validating Downlink Control Information (DCI) used to activate or deactivate configured uplink grants. The validation logic changes depending on whether bits in the DCI's HARQ process number field indicate a specific configuration index, comparing either just the redundancy version field or both fields against pre-configured sequences. (Compl. ¶28, ¶147).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶148).
  • Accused Features: The accused features are the alleged implementations of 5G NR configured grant activation and deactivation procedures, where DCI validation for uplink resources is performed (Compl. ¶149, ¶155-156).

U.S. Patent No. 11,139,944 - Validation of Downlink Control Information

  • Technology Synopsis: This patent concerns a method for validating DCI in a wireless device. The validation logic depends on whether the DCI has a "first format" or a "second format" and whether bits in the HARQ field indicate a configuration index. Validation is based on the redundancy version bits and, in some cases, the HARQ bits, but not in others, to activate or deactivate resources. (Compl. ¶29, ¶166).
  • Asserted Claims: At least independent claim 11 is asserted (Compl. ¶167).
  • Accused Features: The accused features are the alleged implementations of DCI validation logic in 5G devices, particularly for handling different DCI formats and configurations for resource activation/deactivation (Compl. ¶168-172).

U.S. Patent No. 11,108,639 - Wireless Device Feedback for Semi-Persistent Scheduling Release

  • Technology Synopsis: This patent describes a method for deactivating multiple semi-persistent scheduling (SPS) configurations. A device receives RRC messages defining two SPS configurations with the same HARQ codebook identifier. It then receives a DCI where a value in the HARQ process number field indicates a state mapped to both SPS configurations, triggering their deactivation and the transmission of an acknowledgment. (Compl. ¶30, ¶183).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶184).
  • Accused Features: The accused features relate to the alleged implementation of 5G procedures for deactivating multiple SPS configurations via a single DCI command (Compl. ¶185-191).

U.S. Patent No. 10,986,695 - Uplink Cancellation Indication Signaling

  • Technology Synopsis: This patent relates to a method for cancelling a scheduled uplink transmission. A device receives configuration parameters defining starting positions for cancellation indications within a DCI for a normal uplink carrier and a supplementary uplink carrier. Upon receiving a DCI with a cancellation RNTI, it determines the relevant cancellation indication based on these positions and cancels the transmission. (Compl. ¶31, ¶201).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶202).
  • Accused Features: The accused features are the alleged 5G implementations of uplink cancellation, where a DCI can instruct a device to abort a scheduled transmission on either a normal or supplementary uplink carrier (Compl. ¶203-210).

U.S. Patent No. 10,979,128 - Beam Failure and Consistent Listen Before Talk Failure Recovery

  • Technology Synopsis: This patent describes a recovery method for wireless devices. The device is configured for both beam failure recovery and listen-before-talk (LBT) failure recovery. Upon detecting a consistent LBT failure, it stops any ongoing beam failure recovery process, switches to a different bandwidth part (BWP), and initiates a new random access process for LBT failure recovery. (Compl. ¶32, ¶219).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶220).
  • Accused Features: The accused features relate to the alleged implementation of recovery mechanisms in 5G devices operating in unlicensed spectrum, where both beam failures and LBT failures must be managed (Compl. ¶221-227).

U.S. Patent No. 11,637,615 - Random Access and Consistent LBT Failure Recovery

  • Technology Synopsis: This patent describes a multi-stage recovery process. A device initiates a first random access process for beam failure recovery. If a consistent LBT failure is triggered, it stops the first process, switches BWPs, and initiates a second random access process for LBT recovery. After the LBT recovery process completes, it initiates a third random access process for beam failure recovery. (Compl. ¶33, ¶236).
  • Asserted Claims: At least independent claim 9 is asserted (Compl. ¶237).
  • Accused Features: This patent is asserted against the alleged implementation of complex, multi-stage recovery procedures in 5G devices that must handle both beam and LBT failures in sequence (Compl. ¶238-244).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses a wide range of Samsung's 5G-capable products, including but not limited to the Galaxy A, S, Note, Fold, and Z series smartphones, as well as Galaxy Tab tablets and Galaxy Book notebooks (Compl. ¶34).

Functionality and Market Context

  • The accused products are alleged to be User Equipments (UEs) that implement 3GPP 5G standards (Compl. ¶34). The complaint provides a screenshot of the Samsung Galaxy S24 lineup, highlighting its 5G capabilities including support for sub6 and mmWave frequencies (Compl. p. 12). Another visual shows a physical layer model for uplink shared channel transmission from a 3GPP technical specification, which the complaint alleges is implemented by the accused products (Compl. p. 14, fig. 5.1.1-1). The accused functionalities are core to 5G operation, including multi-antenna transmission, channel state reporting, paging, random access procedures, and various resource allocation and failure recovery mechanisms (Compl. ¶39, ¶55, ¶76). The products are positioned as mainstream consumer and enterprise mobile devices.

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,063,727 Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
a User Equipment (UE) for multi-antenna transmission, comprising: a first receiver: receiving a first signaling, a second signaling, a first reference signal and a second reference signal; and a first transmitter: transmitting first channel information The accused products are UEs with transceivers that receive configuration signaling and reference signals (CSI-RS) and transmit channel state information reports. ¶39, ¶41 col. 7:6-12
wherein the first reference signal comprises Q1 reference signal port(s), the Q1 reference signal port(s) is(are) transmitted by Q1 antenna port(s) respectively; the second reference signal comprises Q2 reference signal port(s), the Q2 reference signal port(s) is(are) transmitted by Q2 antenna port(s) respectively The accused products receive a first reference signal (Periodic/Semi-persistent CSI-RS) with Q1 ports and a second reference signal (aperiodic CSI-RS) with Q2 ports. ¶43 col. 7:13-19
the first signaling is used to determine L1 antenna port(s), the Q1 antenna port(s) is(are) a subset of the L1 antenna port(s); the second signaling is used to determine the Q2 antenna port(s) The first signaling (e.g., RRC configuration) is used to determine mapped antenna ports from which periodic/semi-persistent CSI-RS are transmitted (L1). The second signaling (e.g., DCI format 0_1) is used to determine mapped antenna ports for aperiodic CSI-RS (Q2). ¶43 col. 7:20-24
wherein... the first channel information corresponds to Q antenna ports; the Q antenna ports consist of the Q1 antenna port(s) and the Q2 antenna port(s), the Q is equal to a sum of the Q1 and the Q2 The transmitted channel state information report allegedly corresponds to the combined set of Q1 antenna ports (from the first reference signal) and Q2 antenna ports (from the second reference signal). ¶44 col. 7:28-32
the first reference signal is transmitted in a first time resources pool, and the second reference signal is transmitted in a second time resources pool... The first reference signal (Periodic/Semi-persistent CSI-RS) is received in a first set of resources, and the second reference signal (aperiodic CSI-RS) is received in a second set of resources. ¶45 col. 7:33-36
the first reference signal occurs multiple times in the first time resources pool... the second reference signal occurs once in the second time resources pool The periodic/semi-persistent CSI-RS allegedly occurs multiple times, while the aperiodic CSI-RS is triggered instantly by a DCI and thus allegedly occurs once. ¶45 col. 7:36-41
  • Identified Points of Contention:
    • Scope Questions: A potential issue is whether the 3GPP concepts of "Periodic/Semi-persistent" and "Aperiodic" CSI reporting (Compl. ¶45) map directly onto the patent's claim terms "first time resources pool" and "second time resources pool." A court may need to determine if these standard industry practices fall within the specific scope defined by the patent's specification.
    • Technical Questions: The complaint alleges that an aperiodic CSI-RS "occurs once in the second time resources pool" because it is "instantly triggered by DCI format 0_1" (Compl. ¶45). A question for the court could be whether this "on-demand" triggering satisfies the claim limitation of occurring "once," especially if the same triggering mechanism could be used multiple times.

U.S. Patent No. 11,374,721 Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
a user equipment for wireless communication, comprising: a first processor transmitting a first wireless signal; and a first transmitter transmitting a second wireless signal The accused products are UEs with processors and transmitters that transmit a first signal (Random Access Preamble on PRACH) and a second signal (data on PUSCH). ¶56, ¶57 col. 5:63-66
wherein the first wireless signal is generated by a first sequence... the first sequence is a Zadoff-Chu (ZC) sequence The accused products allegedly generate the Random Access Preamble using a Zadoff-Chu sequence, as specified by 5G standards. ¶58, ¶64 col. 6:23-25
a transport channel corresponding to the first wireless signal is a Random Access Channel (RACH), a physical channel corresponding to the second wireless signal is a Physical Uplink Shared Channel (PUSCH) The complaint alleges the first signal (preamble) corresponds to the RACH and the second signal (data) corresponds to the PUSCH, per 5G standards. ¶65 col. 6:25-29
the first wireless signal is used to determine a first time interval... the first time interval is used to determine the first wireless resource out of the J candidate wireless resources The time between the preamble (Msg1) and the subsequent data transmission (Msg3 on PUSCH) is allegedly used to determine the PUSCH resource, as the actual time separation depends on system parameters like subcarrier spacing. ¶59, ¶63 col. 6:4-14
the first wireless signal is used to determine whether the second wireless signal is transmitted or not The successful transmission and response to the first signal (preamble) is a prerequisite for the UE to proceed with the second signal (PUSCH transmission), thus determining if it is transmitted. ¶66 col. 6:29-31
  • Identified Points of Contention:
    • Scope Questions: The central dispute may turn on the construction of "the first time interval is used to determine the first wireless resource." The complaint alleges an indirect relationship where the time gap "depends on the subcarrier spacing (SCS) configuration" (Compl. ¶61), which in turn relates to the resource. This raises the question of whether such an indirect dependency meets the claim's requirement that the interval itself is "used to determine" the resource.
    • Technical Questions: Does the accused product's logic actually use the measured or calculated time interval as an input to a function or lookup table that outputs the PUSCH resource, or is the timing merely a consequence of other system scheduling decisions? The evidence presented will be critical to resolving this functional claim limitation.

V. Key Claim Terms for Construction

Patent: U.S. Patent No. 11,063,727

  • The Term: "time resources pool"
  • Context and Importance: The infringement theory hinges on mapping the 3GPP concept of "Periodic/Semi-persistent CSI RS resources" to a "first time resources pool" and "aperiodic CSI RS resources" to a "second time resources pool" (Compl. ¶45). The definition of this term is therefore critical to determining if the accused 5G standard-compliant behavior falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification states that the time resources pool can be "a positive integer of time unit(s)" and the time unit can be a subframe, which could support a broad reading on any grouping of time-based resources (’727 Patent, col. 3:46-51).
    • Evidence for a Narrower Interpretation: Figure 2 of the patent depicts the "first time resources pool" and "second time resources pool" as distinct, non-overlapping sets of resources (’727 Patent, Fig. 2). A defendant may argue this graphical depiction limits the term to physically separate resource sets, potentially creating a distinction from how periodic and aperiodic resources are managed in the 5G standard.

Patent: U.S. Patent No. 11,374,721

  • The Term: "the first time interval is used to determine the first wireless resource"
  • Context and Importance: The core of the infringement allegation for this patent is that the time gap between a RACH preamble and a PUSCH data transmission is "used to determine" the resource for that PUSCH transmission (Compl. ¶63). Practitioners may focus on this term because the complaint's theory relies on a functional relationship where the timing "depends on" system parameters rather than being a direct input to a selection algorithm.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstract states the "first time interval is used to determine the first wireless resource out of the J candidate wireless resources," suggesting a functional selection process where the timing is an input that selects from a set of possibilities, which could support the complaint's theory.
    • Evidence for a Narrower Interpretation: The detailed description may provide specific embodiments where the time interval is an explicit input into a formula or a direct index into a lookup table. If the specification only discloses such direct computational uses, a defendant may argue that the term should be construed narrowly to require more than the indirect dependency alleged in the complaint.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on Defendant’s affirmative acts of manufacturing and selling the accused products while providing instructions, technical support, and marketing materials that encourage infringing use (e.g., Compl. ¶46, ¶67). Contributory infringement is alleged on the basis that the accused components are not staple articles of commerce and are especially made for use in an infringing manner (e.g., Compl. ¶47, ¶68).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The complaint claims Defendants had actual knowledge of the patents from "related prior litigations" against Samsung or its direct competitors involving similar 5G functionalities (e.g., Compl. ¶50, ¶71). This alleged pre-suit knowledge forms the primary basis for willfulness.

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

  • A core issue will be one of standards-to-claim mapping: will the complex and multifaceted procedures defined in the 3GPP 5G standards be found to practice the specific, ordered steps recited in the patents-in-suit? For many of the patents, the infringement theory relies on mapping industry-standard terms and processes (e.g., "aperiodic CSI-RS," "configured grant activation") onto the patent's specific claim language (e.g., "second time resources pool," "validating the DCI"), a mapping which will likely be a central point of dispute.
  • A key legal question will be the scope of functional language: how broadly will claim terms like "used to determine" be construed by the court? The case may turn on whether an indirect, consequential relationship between two technical features (like the time gap and resource allocation in the ’721 patent) is sufficient to meet the claim language, or if a more direct, computational link is required by the patent's specification.
  • A crucial factual question will concern willfulness and damages: what evidence will be presented regarding the "related prior litigations" mentioned in the complaint, and will it be sufficient to establish pre-suit knowledge of the asserted patents? The answer will significantly influence the potential for enhanced damages.