Lab Technology LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00324, E.D. Tex., 05/03/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant infringes five U.S. patents related to various telecommunications technologies, including audio announcements, emergency location services, voice message analysis, display refreshing, and voice call switching.
• Technical Context: The patents-in-suit address distinct functional challenges in modern telecommunications, reflecting the evolution of mobile devices from simple phones to multi-purpose communication hubs.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

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

U.S. Patent No. 8,498,388 - "Method and system for announcement," issued July 30, 2013

The Invention Explained

• Problem Addressed: The patent describes conventional methods for delivering audio announcements as inefficient, citing the need for users to repeatedly dial a number or navigate web pages to hear potentially outdated information (’388 Patent, col. 1:22-65).
• The Patented Solution: The invention proposes a method where a device, described as a "telephone," receives a structured "announcement package" containing audio items. The system is designed to receive updates that can modify this package by replacing, deleting, or adding content, ensuring the announcements are timely and delivered efficiently (’388 Patent, Abstract; col. 3:34-48). The architecture is illustrated in Figure 1, showing a server delivering an announcement package to an "announcer" device (’388 Patent, Fig. 1).
• Technical Importance: This approach aims to improve the effectiveness and timeliness of delivering dynamic audio information, ranging from news reports to personal alerts (’388 Patent, col. 2:1-3).

Key Claims at a Glance

The complaint incorporates by reference claim charts that were not filed with the public docket, and thus does not identify the specific claims asserted (Compl. ¶21, Ex. 6). For the purpose of analysis, independent claim 1 is used as a representative example.

• A method for receiving an announcement by a telephone, comprising:
  • receiving a first announcement item comprising a first item identity and first audio data;
  • receiving a second announcement item comprising a second item identity and second audio data;
  • determining if the second item identity matches the first item identity; and
  • if a match is determined, updating the first audio data with the second audio data.
    The complaint reserves the right to assert additional claims (Compl. ¶15).

U.S. Patent No. 8,503,973 - "Method and system for obtaining emergency caller location," issued August 6, 2013

The Invention Explained

• Problem Addressed: The patent identifies a critical problem with emergency services (e.g., 911) for mobile and VoIP telephones, which, unlike traditional landlines, are not tied to a fixed, known physical address, making it difficult to dispatch emergency responders accurately (’973 Patent, col. 2:23-39).
• The Patented Solution: The invention describes a method where a mobile phone, upon detecting that its connection point to the network (the "wireless base station") has changed, obtains a new "subscriber location" corresponding to the new base station and sends this updated location to a "phone system." This allows for dynamic location reporting critical for mobile users (’973 Patent, Abstract; col. 11:11-30).
• Technical Importance: The technology provides a solution to the public safety challenge of locating emergency callers using modern, non-stationary telephone services (’973 Patent, col. 2:57-60).

Key Claims at a Glance

The complaint incorporates by reference claim charts that were not filed with the public docket, and thus does not identify the specific claims asserted (Compl. ¶30, Ex. 7). For the purpose of analysis, independent claim 1 is used as a representative example.

• A method for obtaining a subscriber location for a mobile phone, comprising:
  • obtaining a current wireless base station identity;
  • obtaining a stored wireless base station identity;
  • determining that the current and stored identities do not match;
  • obtaining a subscriber location corresponding to the current identity; and
  • sending the subscriber location to the phone system.
    The complaint reserves the right to assert additional claims (Compl. ¶24).

U.S. Patent No. 8,515,032 - "System to record and analyze voice message usage information," issued August 20, 2013

• Technology Synopsis: The patent addresses the lack of tractable information in conventional voicemail systems for policy enforcement or evidence gathering (’032 Patent, col. 1:36-47). The invention describes a system that creates detailed "voice message records," logging actions such as "sent," "received," and "listened," along with sender/recipient identities and timestamps, to enable analysis and reporting on voicemail usage (’032 Patent, Abstract).
• Asserted Claims: The complaint does not specify asserted claims, referencing non-public charts (Compl. ¶39, Ex. 8).
• Accused Features: The complaint accuses unspecified "Exemplary Defendant Products" (Compl. ¶33).

U.S. Patent No. 9,219,982 - "Apparatus and method for automatically refreshing a display of a telephone," issued December 22, 2015

• Technology Synopsis: The patent seeks to solve the problem of users having to navigate complex menus to find frequently used services on a telephone (’982 Patent, col. 1:30-34). The solution is a telephone that automatically refreshes its display to present commonly used communication services based on a "function," which can be determined by factors like time, location, or user activity (’982 Patent, Abstract).
• Asserted Claims: The complaint does not specify asserted claims, referencing non-public charts (Compl. ¶47, Ex. 9).
• Accused Features: The complaint accuses unspecified "Exemplary Defendant Products" (Compl. ¶42).

U.S. Patent No. 9,578,570 - "Methods and systems for switching over a voice call," issued February 21, 2017

• Technology Synopsis: The patent addresses the problem of voice calls over IM-based networks (e.g., voice-over-WiFi) being dropped when a user moves out of the network's range (’570 Patent, col. 2:10-14). The invention provides a method and system to seamlessly switch an active IM-based voice call to a secondary network, such as a cellular network, to maintain the call without interruption (’570 Patent, Abstract).
• Asserted Claims: The complaint does not specify asserted claims, referencing non-public charts (Compl. ¶56, Ex. 10).
• Accused Features: The complaint accuses unspecified "Exemplary Defendant Products" (Compl. ¶51).

III. The Accused Instrumentality

• Product Identification: The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" detailed in confidential claim charts (Exs. 6-10) that were not filed on the public docket (Compl. ¶¶ 15, 24, 33, 42, 51). Therefore, the specific Samsung products, methods, or services cannot be identified from the provided documents.
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, as this information is contained within the non-publicly filed exhibits.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges infringement but incorporates by reference claim chart exhibits that were not filed on the public docket (Compl. ¶¶ 21, 30, 39, 47, 57). Therefore, a detailed claim chart summary cannot be constructed. The narrative infringement theory is summarized below in prose.

• '388 Patent Infringement Allegations

  • The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’388 Patent (Compl. ¶20). It asserts that these products satisfy all elements of the exemplary claims by receiving and updating audio announcements (Compl. ¶20). The specific operational details of how the products allegedly meet each claim element are contained in the non-public Exhibit 6 (Compl. ¶21).
  • Identified Points of Contention: A central question may be whether the accused products, likely multi-function smartphones, perform the specific claimed steps of comparing item identities and updating audio data locally, as required by claim 1. The functional capabilities of the accused device versus the claimed "telephone" could be a key area of dispute.

• '973 Patent Infringement Allegations

  • The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’973 Patent (Compl. ¶29). The core of the allegation is that these products perform a method of obtaining and updating a user's location for emergency services in a manner that satisfies all elements of the exemplary claims (Compl. ¶29). The specific evidence and mapping to claim elements are referenced in the non-public Exhibit 7 (Compl. ¶30).
  • Identified Points of Contention: An evidentiary question will be whether the accused products are shown to perform the specific sequence of obtaining a stored base station identity, comparing it to a current one, and then obtaining and sending a "subscriber location" to a "phone system." The technical implementation of location services in modern smartphones may not map directly to this claimed method.

V. Key Claim Terms for Construction

• Term: "telephone" (’388 Patent, claim 1)

  • Context and Importance: This term appears in the preamble and body of claim 1, defining the device that performs the claimed method. Its construction is critical because the patent's embodiments may imply a device with a more limited function than a modern smartphone, which acts as a general-purpose computer. Practitioners may focus on this term to dispute whether a complex smartphone, where individual applications manage their own data, performs the updating steps "by the telephone" as a whole.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is general. The specification describes delivering a wide variety of announcements, including news, alerts, and advertisements, which are common on modern devices (’388 Patent, col. 2:46-62).
    • Evidence for a Narrower Interpretation: The patent claims priority to 2006, and the specification focuses on a client device ("announcer") receiving structured "announcement packages" from a server (’388 Patent, Fig. 1). This could support an argument that "telephone" refers to a device acting as a simple client for this specific system, not a general computing device running disparate applications.

• Term: "subscriber location" (’973 Patent, claim 1)

  • Context and Importance: This term is the ultimate output of the claimed method, intended to solve the problem of locating mobile 911 callers. Its definition is crucial because modern devices can generate many types of location data (e.g., raw GPS, cell-tower triangulation, civic address). The infringement analysis will depend on whether the location data provided by the accused products qualifies as the claimed "subscriber location."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent mentions that the location can be "geophysical location coordinates" (’973 Patent, col. 4:35-37), suggesting the term is not limited to a street address.
    • Evidence for a Narrower Interpretation: The background section contrasts the invention with traditional systems that use an Automatic Location Identity (ALI) database, which contains street addresses for dispatch (’973 Patent, col. 1:52-54). This context may support an argument that "subscriber location" must be a dispatchable location, such as a civic address, rather than just raw coordinate data.

VI. Other Allegations

• Indirect Infringement: For all five patents-in-suit, the complaint alleges induced infringement. The allegations are based on Defendant distributing "product literature and website materials" that allegedly instruct and encourage end-users to use the accused products in a manner that infringes the patents (Compl. ¶¶ 18, 27, 36, 45, 54).
• Willful Infringement: The complaint alleges that Defendant has actual knowledge of the patents-in-suit at least upon service of the complaint and the corresponding claim charts (Compl. ¶¶ 17, 26, 35, 44, 53). The allegations of continued infringement after this notice form the basis for a claim of post-suit willful infringement.

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

• A primary issue will be one of evidence and specificity: As the complaint's technical infringement details are confined to non-public exhibits, a key question is whether Plaintiff can produce concrete evidence that Samsung’s highly integrated products perform the specific, sequential steps recited in the asserted method claims, or if there is a mismatch between the patent's prescribed processes and the actual operation of the accused technology.
• The case will likely involve a central dispute over definitional scope: Can claim terms rooted in the technological context of the mid-2000s, such as "telephone" performing a specific update function (’388 Patent) or a "subscriber location" obtained via base station comparison (’973 Patent), be construed to read on the complex, multi-modal operations of current-generation smartphones?
• A third key question relates to the viability of a multi-patent suit: With five distinct technologies asserted, the case raises the strategic question of whether the asserted patents share a sufficient nexus of technology and accused functionality to be tried together, or if the disparate nature of the inventions—from call hand-offs to display refreshing—will lead to motions to sever or create significant case management challenges.