DCT
2:24-cv-00464
Keyless Licensing LLC v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Keyless Licensing LLC (Texas)
- Defendant: Samsung Electronics America, Inc. (New York); Samsung Electronics Co., Ltd. (Republic of Korea)
- Plaintiff’s Counsel: The Dacus Firm, P.C.; Kramer Alberti Lim & Tonkovich LLP
- Case Identification: 2:24-cv-00464, E.D. Tex., 06/20/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung maintains regular and established places of business in the district, including corporate offices and R&D facilities in Plano and Richardson, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones and tablets infringe three patents related to mobile device physical design, user interface controls for edge-of-screen interactions, and systems for managing multiple applications with an on-screen keyboard.
- Technical Context: The patents address foundational aspects of modern smartphone design and usability, including the move to full-face touchscreens and the development of software-based user interface solutions for input and multitasking.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent families, citing numerous instances where Samsung cited patents from these families during the prosecution of its own patent applications.
Case Timeline
| Date | Event |
|---|---|
| 2003-04-18 | Earliest Priority Date for ’144 Patent |
| 2009-12-30 | Earliest Priority Date for ’602 Patent |
| 2013-05-09 | Earliest Priority Date for ’922 Patent |
| 2016-04-05 | ’602 Patent Issued |
| 2021-04-13 | ’922 Patent Issued |
| 2022-11-15 | ’144 Patent Issued |
| 2024-06-20 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,503,144 - "Systems to enhance data entry in mobile and fixed environment"
- Patent Identification: U.S. Patent No. 11,503,144, titled “Systems to enhance data entry in mobile and fixed environment,” issued November 15, 2022 (Compl. ¶25).
The Invention Explained
- Problem Addressed: The patent’s background section describes the drawbacks of prior art data entry methods on mobile devices, noting the difficulty of using standard QWERTY keyboards on small screens and the inefficiency of multi-press systems on telephone-style keypads (’144 Patent, col. 1:33-47). The complaint frames the problem as a need to maximize display area, eliminate physical buttons, and improve user input efficiency (Compl. ¶26).
- The Patented Solution: The invention claims a mobile phone with a specific physical form factor: a "practically rectangular-shaped housing" with a thin profile where a display unit "practically covers the entire front surface" and which has no physical keys on that surface (’144 Patent, Abstract; Compl. ¶49). This design is combined with user interface solutions, such as using a "sweeping procedure" over virtual keys instead of discrete presses, to create what the complaint describes as a "novel, sleek, and seamless mobile phone" (’144 Patent, col. 81:30-41; Compl. ¶26).
- Technical Importance: With an earliest priority date of 2003, the claimed design represented a significant departure from the then-dominant mobile phone paradigm of physical keypads and smaller screens, anticipating the hardware design language of modern smartphones (Compl. ¶28).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 9 (Compl. ¶47).
- Claim 1 recites a mobile phone device with elements including:
- A practically rectangular-shaped housing with a specific length-to-width ratio and a thin thickness.
- The length approximately corresponding to the distance between a user's ear and mouth.
- A display unit that is integrated within and practically covers the entire front surface.
- The absence of any physical key on the front surface.
- Components integrated within the housing such that none are "noticeable extended out."
- Claim 9 recites a mobile phone with elements including:
- A body with similar rectangular shape and dimensional properties as Claim 1.
- A touch sensitive display unit, a virtual keyboard, a microphone, and a speaker.
- The display unit "practically occupying the entire front surface" and the front surface lacking a physical button or physical keyboard.
- The display unit being adapted to show text in both landscape and portrait orientations.
U.S. Patent No. 9,304,602 - "System for capturing event provided from edge of touch screen"
- Patent Identification: U.S. Patent No. 9,304,602, titled “System for capturing event provided from edge of touch screen,” issued April 5, 2016 (Compl. ¶31).
The Invention Explained
- Problem Addressed: The patent identifies prior art data input methods on mobile devices as "problematic for users because the approaches are complicated, slow, inconvenient, error-prone, and/or require extensive memorization" (’602 Patent, col. 2:41-43, 2:53-55; Compl. ¶33). Specifically, it critiques methods requiring users to remember specific stroke patterns or multi-tap schemes.
- The Patented Solution: The invention proposes a system that uses "at least one window" located on an edge of the touchscreen that functions independently of any application running in the main display area (’602 Patent, col. 103:4-8; Compl. ¶83). A processor detects a "gliding action" that starts from outside the touchscreen and interacts with this edge window to trigger a specific, assigned action (’602 Patent, col. 103:9-14). The patent specification notes this window may be extremely thin or even invisible, serving as a dedicated, non-intrusive input zone (’602 Patent, col. 8:3-13).
- Technical Importance: The claimed system provides a method for adding functionality to a mobile device without consuming valuable screen real estate, creating a distinct input mechanism at the screen's periphery that is separate from the primary application interface (Compl. ¶35).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶82).
- Claim 1 recites a system for capturing an event from a screen edge, with elements including:
- A device with a touch screen.
- At least one "window" located on an edge of the touch screen.
- The window functions "independently of an interface of an application in use on the touch screen."
- A processor.
- A "gliding action" from outside to inside the screen interacts with the window.
- The processor processes the gliding action to cause an action assigned to the window.
- The window is located on the screen before the gliding action begins.
U.S. Patent No. 10,976,922 - "Data entry systems"
- Patent Identification: U.S. Patent No. 10,976,922, titled “Data entry systems,” issued April 13, 2021 (Compl. ¶38).
- Technology Synopsis: The patent addresses the problem of displaying a full on-screen keyboard on a mobile device, which can obscure application content and features keys that are too small for easy use (’922 Patent, col. 1:31-38; Compl. ¶39). The patented solution is a system that divides the touchscreen into zones, allowing for the simultaneous display of a first application, a second application, and a reduced keyboard interface, where the second application is activated via a control on the keyboard itself to improve multitasking capabilities (Compl. ¶41, ¶109). A screenshot in the complaint shows the Samsung Messages interface, a reduced keyboard, and a voice input interface displayed simultaneously (Compl. ¶55).
- Asserted Claims: At least independent claim 1 (Compl. ¶108).
- Accused Features: The accused functionality involves the interaction between the Samsung Messages application, the Samsung Keyboard, and the Samsung Voice Input application, which are alleged to operate as a system for using multiple applications simultaneously on the device's screen (Compl. ¶111, ¶113-114).
III. The Accused Instrumentality
Product Identification
- The accused products are Samsung's mobile devices, including cellular phones and tablets, referred to as the "Accused Instrumentalities" (Compl. ¶46). The complaint uses the Samsung Galaxy S23 as a primary and representative example for its infringement allegations (Compl. ¶50).
Functionality and Market Context
- The complaint focuses on three key areas of functionality in the Samsung Galaxy S23:
- Physical Form Factor: The complaint alleges the S23's physical design—a thin, rectangular housing with a display covering nearly the entire front surface and no physical front-facing buttons—embodies the invention of the ’144 patent (Compl. ¶51-56). An image from Samsung's website provides the specific height, width, and depth of the Galaxy S23 housing (Compl. ¶51).
- Edge-Based UI Controls: The complaint identifies two software features as the infringing "windows" of the ’602 patent: the "notification bar" at the top edge of the display and the "Edge panels" feature accessible via a "handle" on the side of the display (Compl. ¶87, ¶89). The accused infringing acts are swiping from the top edge to open the notification shade and swiping from the side edge to open the Edge panels, both of which are alleged to function independently of the main application on screen (Compl. ¶92-93).
- Keyboard and Application Integration: The complaint accuses the system where a user interacts with the Samsung Messages app, uses the Samsung Keyboard for text entry, and then taps a microphone icon on the keyboard to activate the Samsung Voice Input application (Compl. ¶111, ¶114). This sequence is alleged to result in the simultaneous display of the messaging interface, the voice input interface, and a reduced keyboard interface, infringing the ’922 patent (Compl. ¶120).
IV. Analysis of Infringement Allegations
Infringement Allegations: U.S. Patent No. 11,503,144
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a practically rectangular-shaped housing within which the components of a mobile phone are integrated | The Samsung Galaxy S23 has a rectangular-shaped housing with integrated components. | ¶51 | ’144 Patent, Abstract |
| said housing having a front surface, a back surface, and four side surfaces | The S23 is alleged to have a front, back, and four side surfaces. | ¶52 | ’144 Patent, Abstract |
| wherein the length of the front surface approximately corresponds to the distance between the ear and the mouth of a user | The S23's height of 146.3 mm is alleged to be a distance approximately corresponding to the distance between a user's ear and mouth. | ¶53 | ’144 Patent, Abstract |
| wherein the width of the front surface is substantially shorter than the length and wherein the housing has a thin thickness | The S23's width of 70.9 mm is alleged to be substantially shorter than its 146.3 mm length, and its 7.6 mm depth is alleged to be a thin thickness. | ¶54 | ’144 Patent, Abstract |
| a display unit integrated within the front surface of said housing wherein said display unit practically covers the entire front surface of said housing | The S23’s display unit is integrated within its front surface and is alleged to cover nearly the entire surface, except for a camera hole and black border. A diagram annotates these features on the S23's front surface (Compl. ¶55). | ¶55 | ’144 Patent, Abstract |
| wherein said mobile phone device does not include a physical key on the front surface | The S23 is alleged to have no physical keys on its front surface. | ¶55 | ’144 Patent, Abstract |
| wherein said components of the mobile phone are integrated within said housing such that none of said components is noticeable extended out from said housing | All S23 components, including the rear camera, are alleged to be integrated within the housing without noticeable extension. | ¶56 | ’144 Patent, Abstract |
- Identified Points of Contention:
- Scope Questions: The infringement analysis may turn on the construction of several qualitative terms, raising questions such as: Does the S23's camera cutout and bezel prevent its display from "practically" covering the "entire" front surface? Do the raised metal rings around the rear camera lenses constitute components that are "noticeably extended out from said housing"?
- Technical Questions: A key question may be whether the claim limitation that the device length "approximately corresponds to the distance between the ear and the mouth of a user" requires evidence of intentional ergonomic design or is simply a descriptive statement about a common phone dimension.
Infringement Allegations: U.S. Patent No. 9,304,602
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a device having a touch screen | The Samsung Galaxy S23 and other accused devices feature a touch screen display. | ¶85 | ’602 Patent, col. 7:60-62 |
| at least one window located in the touch screen on an edge of the touch screen, wherein said at least one window functions independently of an interface of an application in use on the touch screen | The S23 allegedly includes a "notification bar" at the top edge and "Edge panels" on the side edge, which are alleged to function as independent windows. Screenshots from the accused device show the 'Edge panels' settings (Compl. ¶89). | ¶87, ¶89, ¶88 | ’602 Patent, col. 8:3-10 |
| a processor | The S23 includes a Snapdragon Octa-Core processor. | ¶90 | ’602 Patent, col. 10:55-58 |
| wherein a gliding action provided from outside of the touch screen towards inside of the touch screen, said gliding action at first interacting with said at least one window on the touch screen, is processed by said processor to cause an action assigned to said window... | A user swiping down from the top edge to open the notification shade or swiping in from the side edge to open the Edge panels is the alleged gliding action processed by the processor. | ¶91, ¶92, ¶93 | ’602 Patent, col. 103:9-14 |
| and wherein said at least one window is located on the touch screen before said gliding action begins. | The notification bar and Edge panel handle are alleged to be present on the screen before the user initiates the swipe. | ¶91 | ’602 Patent, col. 8:3-7 |
- Identified Points of Contention:
- Scope Questions: The case may depend on whether the term "window" can be construed to read on a software construct like a status bar or a slide-out panel handle. Further, the requirement for the gliding action to be "provided from outside of the touch screen" raises a definitional question about the boundary of the screen's active area versus its physical bezel.
- Technical Questions: The complaint provides screen recordings showing the user's touch point as a circle. An evidentiary question will be whether this touch originates "outside" the screen or on its active periphery, and whether that factual distinction is material to the claim language.
V. Key Claim Terms for Construction
- Term: "practically covers the entire front surface" (’144 Patent, Claim 1)
- Context and Importance: This term is critical because the accused Galaxy S23 has both a "camera hole" and a "black border" on its front face (Compl. ¶55). The viability of the infringement claim will depend on whether "practically" is broad enough to encompass these non-display elements.
- Intrinsic Evidence for a Broader Interpretation: The use of the modifier "practically" in the claim itself suggests that 100% coverage is not required and that minor, functional interruptions to the display are permissible.
- Intrinsic Evidence for a Narrower Interpretation: The complaint describes the claimed invention as providing a "novel, sleek, and seamless mobile phone" (Compl. ¶26). This language could be used to argue for a construction that requires a more uninterrupted, truly "seamless" surface, potentially excluding designs with visible holes or borders.
- Term: "window" (’602 Patent, Claim 1)
- Context and Importance: Plaintiff's infringement theory maps this term to the S23's notification bar and Edge panels (Compl. ¶87, ¶89). The case hinges on whether these modern UI elements fall within the patent's definition of a "window."
- Intrinsic Evidence for a Broader Interpretation: The specification describes "a thin window...defined along one or more edges of the touch screen" which can have a width of "less than 10 or 5 pixels" and may be "barely viewable by the user or even not viewable at all" (’602 Patent, col. 8:3-13). This description may support reading the term on a thin Edge panel handle or a status bar.
- Intrinsic Evidence for a Narrower Interpretation: The term "window" is often understood in the art to mean a discrete, bounded graphical area for an application. Defendant may argue that a system-level status bar or a transient UI handle does not meet the conventional meaning of the term as used in the context of graphical user interfaces.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Samsung induces infringement by its customers and end-users by providing the Accused Instrumentalities and distributing "instructions, demonstrations, brochures, videos, and user guides that intentionally instruct and guide users" to operate the devices in an infringing manner (Compl. ¶69, ¶95, ¶121).
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. For each patent, it asserts that Samsung knew of the patent family because Samsung cited related patents and applications during the prosecution of its own patent portfolio, providing specific dates by which it alleges Samsung had knowledge (Compl. ¶71, ¶97, ¶123).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the patent's qualitative physical descriptors from an early-2000s priority date, such as "practically covers the entire front surface" and "noticeably extended out," be construed to read on the specific industrial design of a modern smartphone that incorporates features like camera punch-holes and integrated multi-lens camera arrays?
- A second key question will be one of functional mapping: Do modern, system-level software features like the Android notification bar and Samsung's "Edge panel" constitute a "window" as claimed in the ’602 patent, and does a user gesture starting at the screen's periphery meet the limitation of a "gliding action provided from outside of the touch screen"?
- A third central question will involve system boundaries: Does the accused interaction between separate software components—a messaging app, a keyboard app, and a voice input app—constitute a single, integrated "system" that operates as claimed in the ’922 patent, or is it a series of standard inter-application calls managed by the underlying operating system?