DCT
2:24-cv-00435
Mobile Data Tech LLC v. Samsung Electronics America Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Mobile Data Technologies LLC (Delaware)
- Defendant: Samsung Electronics America, Inc. (New York) and Samsung Electronics Co., Ltd. (Republic of Korea)
- Plaintiff’s Counsel: Spencer Fane LLP; Scheef & Stone LLP
- Case Identification: 2:24-cv-00435, E.D. Tex., 06/10/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains multiple regular and established places of business in the district, including a "Flagship North Texas Campus" in Plano and a "Samsung Experience Store" in Frisco.
- Core Dispute: Plaintiff alleges that Defendant’s Samsung Members social media application and associated Samsung Galaxy smartphones infringe four patents related to systems for managing and sharing information content over wireless networks.
- Technical Context: The technology at issue addresses methods for users to create, manage, and share personalized content with other users via mobile devices, a foundational concept in the mobile social media and community platform sector.
- 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
| Date | Event |
|---|---|
| 2002-06-18 | Priority Date for ’801, ’039, ’578, and ’348 Patents |
| 2014-09-02 | U.S. Patent No. 8,825,801 Issues |
| 2015-05-12 | U.S. Patent No. 9,032,039 Issues |
| 2017-04-11 | U.S. Patent No. 9,619,578 Issues |
| 2018-03-20 | U.S. Patent No. 9,922,348 Issues |
| 2024-06-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,825,801 - "METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS" (Issued Sep. 2, 2014)
The Invention Explained
- Problem Addressed: The patent’s background section identifies the difficulty of creating, publishing, and managing information content specifically for mobile devices, which have limited display space and navigational capabilities. It notes that conventional tools like website authoring software are not optimized for this purpose and lack integration with wireless networking functions like messaging and collaboration services (’801 Patent, col. 1:39-65).
- The Patented Solution: The invention proposes a network-based system that separates content creation from content consumption. It describes a "first web-based interface" (e.g., a content management website) where a primary user can create content and establish access rules. This content is then made available to other users through a "second web-based interface" (e.g., a mobile website) that is optimized for mobile devices. The first user controls access to the content on the second interface, thereby facilitating managed, interactive communication between the primary user and the additional users (’801 Patent, Abstract; col. 2:13-29).
- Technical Importance: The technology aimed to simplify the creation of mobile-friendly, shareable content for non-technical users while integrating it with interactive functionalities inherent to mobile networks, anticipating key features of modern social media platforms (’801 Patent, col. 1:55-65).
Key Claims at a Glance
- The complaint identifies independent claim 23 as an exemplary asserted claim (Compl. ¶50).
- The essential elements of claim 23 include:
- Providing a first web-based interface accessible to a first user.
- The first interface is configured to permit the user to activate a "mobile information channel" for sharing content with additional users.
- Generating a second web-based interface, different from the first.
- The second interface provides the additional users with access to the shared content via the mobile information channel.
- The mobile information channel supports messaging between the users over a wireless network.
- The channel is configured to permit the first user to send and receive messaging content with the other users.
- The complaint reserves the right to assert additional claims (Compl. ¶50).
U.S. Patent No. 9,032,039 - "METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS" (Issued May 12, 2015)
The Invention Explained
- Problem Addressed: The ’039 Patent addresses the same technical challenge as the ’801 Patent: the lack of optimized tools for creating and sharing content on mobile devices and the failure of existing solutions to integrate with wireless networking functions (’039 Patent, col. 1:44-2:4).
- The Patented Solution: The invention, as described in the ’039 Patent, is a method for managing content where a server receives content from a user's mobile device, receives information related to the device's wireless network functionality, and integrates the two for insertion into an "application-based information channel" for sharing (’039 Patent, Abstract). This architecture facilitates the sharing of content that is enriched with or enabled by mobile-specific functions.
- Technical Importance: This approach focuses on the server-side process of combining user-generated content with mobile network metadata, providing a technical framework for mobile-native content sharing platforms.
Key Claims at a Glance
- The complaint asserts at least independent claim 18 (Compl. ¶52).
- The essential elements of claim 18 include:
- Receiving, at a server from a mobile device, content for insertion into a specified application-based information channel.
- Receiving, at the server from the mobile device, information associated with at least one wireless network functionality of the device.
- Integrating the content and the information into the specified application-based information channel.
- The complaint reserves the right to assert additional claims (Compl. ¶69).
U.S. Patent No. 9,619,578 - "METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS" (Issued April 11, 2017)
- Technology Synopsis: This patent, part of the same family, describes a method for providing an interface that allows a first user to control the activation of a "mobile information channel" for sharing content with other users. The system involves inserting content from the first user, receiving additional content from other users via their mobile devices, and integrating information related to wireless network functionality into the channel.
- Asserted Claims: The complaint asserts at least independent claim 9 (Compl. ¶71).
- Accused Features: The accused features are the content creation, sharing, and community interaction functionalities of the Samsung Members application on Samsung smartphones (Compl. ¶¶26-28, 71).
U.S. Patent No. 9,922,348 - "METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS" (Issued March 20, 2018)
- Technology Synopsis: This patent describes a system comprising a processing element (e.g., a server) that receives device-captured data (e.g., photos, videos) from multiple mobile devices and integrates this data into a "web-based shared information channel." This channel is controllably accessible to the users of those mobile devices, allowing for shared, media-rich experiences.
- Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶90).
- Accused Features: The accused features are the functionalities of the Samsung Members application that allow users to create posts with media and share them within the application's community on Samsung smartphones (Compl. ¶¶26-28, 90).
III. The Accused Instrumentality
- Product Identification: The accused instrumentalities are collectively identified as the "Accused Products," which consist of the Samsung Members mobile application (formerly the Samsung+ app) and all Samsung smartphones capable of using the application, including the Galaxy S, Z, and A series lineups (Compl. ¶¶26-28).
- Functionality and Market Context: The complaint alleges that Samsung Members is a "social media application" that allows users to create and share content with other users over a network (Compl. ¶26). A provided screenshot from the Google Play store describes the app as a place to "Connect and share with others in the community" (Compl. p. 8, ¶26). The complaint further alleges that the application provides functionality for users to "like" and "comment" on posts, and includes screenshots showing user-generated posts containing text and images organized in feeds (Compl. ¶31; p. 9). The application is available through the Google Play store and is distributed on Samsung's widely sold Galaxy smartphones (Compl. ¶¶26-27).
IV. Analysis of Infringement Allegations
’801 Patent Infringement Allegations
| Claim Element (from Independent Claim 23) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a first web-based interface accessible to a first user, the first web-based interface being configured to permit the first user to activate a given mobile information channel for sharing content between the first user and one or more additional users | The Samsung Members application provides an interface for a user to create a post, which allegedly constitutes activating a "mobile information channel" for sharing content with other users in the community. | ¶¶26, 31 | col. 2:13-20 |
| and generating a second web-based interface different than the first web-based interface, wherein the second web-based interface provides each of the one or more additional users access to at least a portion of the shared content via the given mobile information channel | Other users in the Samsung Members community can view the first user's post through the application's content feeds, which allegedly constitutes the "second web-based interface." | ¶¶26, 31 | col. 2:20-29 |
| wherein the given mobile information channel supports messaging between the first user and the one or more additional users over a wireless network | The Samsung Members application allows users to "like" and "comment" on posts, which constitutes a form of messaging between users over a wireless network. | ¶31 | col. 6:23-28 |
| and wherein the mobile information channel is configured to permit the first user to send messaging content to the one or more additional users and to receive messaging content from the one or more additional users. | A user can post comments (sending content) and view comments from others (receiving content) on a given post within the Samsung Members community. | ¶31 | col. 6:23-28 |
- Identified Points of Contention:
- Scope Questions: The primary dispute may center on whether the architecture of the native Samsung Members application maps onto the patent's claim language of a "first web-based interface" and a "second web-based interface." A court will have to determine if a content creation screen within an app and a separate content viewing feed within the same app satisfy these two distinct limitations, which the patent describes in the context of "web sites" and "URLs" (’801 Patent, col. 10:35-50).
- Technical Questions: A question arises as to whether creating a post in a general social feed constitutes "activating a given mobile information channel." The defense may argue that the patent contemplates a more deliberate creation of a discrete, themed channel (e.g., a user-created mobile website with specific sections like "About," "Journal," etc., as shown in '801 Patent, Fig. 5), rather than a transient social media post.
’039 Patent Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, at a server from a mobile device, content for insertion into a specified application-based information channel | When a user creates a post in the Samsung Members app on their smartphone, that content is transmitted to and received by Samsung's servers for insertion into the app's community platform. | ¶26 | col. 2:38-42 |
| receiving, at the server from the mobile device, information associated with at least one wireless network functionality of the mobile device | The complaint alleges the Accused Products operate over wireless networks. The transmission of content from a user's mobile device to Samsung's servers necessarily includes associated data related to wireless functionality (e.g., device identity, network status, user authentication). | ¶26 | col. 2:43-46 |
| and integrating the content and the information associated with said at least one wireless network functionality of the mobile device into the specified application-based information channel. | Samsung's servers allegedly combine the user's post (content) with the associated user and device data (information) to process, format, and display the post correctly within the Samsung Members community feed. | ¶26 | col. 2:47-52 |
- Identified Points of Contention:
- Scope Questions: The construction of "application-based information channel" will be critical. The complaint suggests the entire Samsung Members community platform is this channel. A defendant might argue for a narrower construction requiring a more specific, user-defined channel, consistent with the '801 patent's disclosure.
- Technical Questions: The key technical question is what actions satisfy the "integrating" limitation. Does the routine server-side processing of a user's post along with its associated metadata (e.g., user ID, timestamp) meet the claimed step of "integrating... information associated with... wireless network functionality," or does the claim require a more specific combination of content with a mobile-network feature like location services or MMS?
V. Key Claim Terms for Construction
The Term: "web-based interface" (’801 patent)
- Context and Importance: This term's construction is central to the infringement analysis for the ’801 patent. Practitioners may focus on this term because the accused instrumentality is a mobile application, and the defense may argue this does not qualify as a "web-based interface," which it might contend is limited to a traditional website accessed via a browser.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent Abstract states the interfaces "may comprise respective content management and mobile web sites," suggesting that a "web site" is an example, not a required limitation (’801 Patent, Abstract). The core of the invention is a networked system for sharing content, a function an app can perform.
- Evidence for a Narrower Interpretation: The detailed description repeatedly uses language associated with traditional websites, such as "home page," "URL," and "web browser" (’801 Patent, col. 10:35-50). The patent figures depicting the user interface strongly resemble conventional website layouts from the early 2000s (e.g., '801 Patent, Fig. 6).
The Term: "integrating" (’039 patent)
- Context and Importance: The meaning of "integrating" is crucial for claim 18 of the ’039 patent. Practitioners may focus on this term because the dispute will likely turn on what level of combination is required between the user's "content" and the "information associated with... wireless network functionality."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes a system where various wireless functionalities (messaging, location-based services, etc.) are made to work with user content, suggesting "integrating" could mean making them functionally interoperable on a platform level (’039 Patent, col. 6:5-13).
- Evidence for a Narrower Interpretation: A defendant could argue "integrating" requires a more direct and substantive combination, such as embedding location data directly into the content of a post or transforming a post into an MMS message, rather than merely processing user metadata alongside the post on a server.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Samsung provides the Samsung Members application and instructs users on how to use its features (e.g., sharing, commenting), thereby encouraging them to perform the claimed methods (Compl. ¶¶35-37). Contributory infringement is based on allegations that Samsung supplies the application, which constitutes a material part of the invention, is not a staple article of commerce, and is known to be used for infringement (Compl. ¶¶38-39).
- Willful Infringement: The complaint alleges that Defendant's infringement is willful based on knowledge obtained "since at least the date of this Complaint" (Compl. ¶¶32, 48). This is a standard allegation of post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "web-based interface," which is described in the patent in the context of traditional websites and URLs, be construed to read on the user-facing screens of a native mobile application like Samsung Members? The outcome of this claim construction question may be dispositive for the ’801 patent and its relatives.
- A key evidentiary question will be one of functional operation: what specific "information associated with... wireless network functionality" is received and "integrated" with user content by Samsung's servers? The case for the '039 patent may depend on whether routine processing of user and device metadata meets this "integrating" limitation, or if the patent requires the combination of content with a more substantive mobile service like location-based tagging or MMS formatting.