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) and Samsung Electronics Co., Ltd. (Republic of Korea)
  • Plaintiff’s Counsel: Kramer Alberti Lim & Tonkovich LLP; The Dacus Firm, P.C.
• Case Identification: 2:24-cv-00464, E.D. Tex., 08/01/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung maintains regular and established places of business within the district, including corporate offices and innovation centers in Plano and Richardson, employs personnel in the district, has committed acts of infringement in the district, and has not contested venue in other recent patent infringement actions filed there.
• Core Dispute: Plaintiff alleges that Defendant’s mobile phone and tablet devices infringe three patents related to mobile device physical design and user interface functionality, including methods for touch-based input.
• Technical Context: The technology at issue concerns the design and operation of user interfaces for mobile devices, a critical area for usability and functionality in the ubiquitous smartphone and tablet market.
• Key Procedural History: The complaint alleges that Defendant was aware of the asserted patent families prior to the lawsuit, citing instances where Defendant referenced members of these families during the prosecution of its own patent applications. These allegations may form a basis for Plaintiff's claims of willful infringement.

Case Timeline

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, "Systems to enhance data entry in mobile and fixed environment," issued November 15, 2022.

The Invention Explained

• Problem Addressed: The patent's background describes the inefficiency and difficulty of using standard QWERTY keyboards or multi-press telephone keypads on small mobile devices, which can be slow and cumbersome for users Compl. ¶¶5, 26
• The Patented Solution: The invention claims a specific physical design for a mobile phone that moves away from physical keys toward a large, touch-sensitive display that covers nearly the entire front surface of the device Compl. ¶28 This design facilitates input via virtual keys and sweeping gestures on the screen, which the patent describes as a "very quick and accurate system" (’144 Patent, col. 89:19-20; Compl. ¶26). At the time of the invention, this was presented as a novel form factor for a mobile phone Compl. ¶28
• Technical Importance: The claimed design concept represented a shift in mobile device ergonomics, prioritizing screen real estate over physical buttons to improve user interaction with applications and content Compl. ¶28

Key Claims at a Glance

The complaint asserts independent claims 1 and 9 Compl. ¶47

• Independent Claim 1: A mobile phone device comprising:
  • A "practically rectangular-shaped housing" with dimensions where the length "approximately corresponds to the distance between the ear and the mouth of a user" and the width is "substantially shorter than the length"
  • A "thin thickness"
  • A "display unit integrated within the front surface" that "practically covers the entire front surface"
  • The absence of any "physical key on the front surface"
  • Components integrated such that "none...is noticeable extended out from said housing"
• Independent Claim 9: A mobile phone comprising:
  • A body with a "practically rectangular shape" and similar dimensional and thickness constraints as claim 1
  • A "touch sensitive display unit"
  • A "virtual keyboard to enter text"
  • A "microphone and a speaker"
  • The display unit "practically occupying the entire front surface" and integrated within the phone
  • The front surface does not have a "physical button" and the phone does not have a "physical keyboard"
  • The display is adapted to show text entered via the virtual keyboard in both "landscape direction and in portrait direction"

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, "System for capturing event provided from edge of touch screen," issued April 5, 2016.

The Invention Explained

• Problem Addressed: The patent identifies prior art data input methods for mobile devices as problematic, citing techniques like multi-tap schemes or gesture systems that are "complicated, slow, inconvenient, error-prone, and/or require extensive memorization" (’602 Patent, col. 2:41-55; Compl. ¶33).
• The Patented Solution: The patent proposes a system where a "thin window is defined along one or more edges of the touch screen" that is handled by the operating system '602 Patent, col. 8:3-9 Sweep or gliding gestures that originate from the edge of the screen are directed to this window to trigger specific actions, and these gestures are interpreted differently from those starting within the main display area '602 Patent, col. 7:60-66 This creates a new, non-intrusive input channel that functions independently of the application currently displayed Compl. ¶35
• Technical Importance: This approach provided a method for adding functionality to a device with a limited-size touchscreen without cluttering the main application interface, allegedly allowing for "faster and more accurate user input" Compl. ¶35

Key Claims at a Glance

The complaint asserts independent claim 1 Compl. ¶82

• Independent Claim 1: A system for capturing an event from an edge of a touch screen, comprising:
  • A device with a touch screen
  • "at least one window located in the touch screen on an edge of the touch screen," which "functions independently of an interface of an application in use"
  • A processor
  • Wherein a "gliding action provided from outside of the touch screen towards inside" interacts with the window and is processed to "cause an action assigned to said window"

U.S. Patent No. 10,976,922 - "Data entry systems,"

• Patent Identification: U.S. Patent No. 10,976,922, "Data entry systems," issued April 13, 2021.
• Technology Synopsis: The patent addresses the problem of on-screen keyboards occupying excessive screen real estate, which hinders the ability to view application content and multitask (’922 Patent, col. 1:35-38; Compl. ¶39). The invention describes a system where a touchscreen is divided into zones for a first application and a keyboard; based on a condition from the keyboard, a second application is activated and its interface is displayed simultaneously with the first application and a "reduced interface" of the keyboard Compl. ¶¶41, 109
• Asserted Claims: At least independent claim 1 Compl. ¶108
• Accused Features: The complaint accuses Samsung's functionality where a user, while in the Samsung Messages app (first application), can tap a microphone icon on the Samsung Keyboard to activate the Samsung Voice Input app (second application), causing the voice input interface to appear in the keyboard zone alongside a reduced keyboard interface Compl. ¶¶111, 114

III. The Accused Instrumentality

Product Identification

• Product Identification: The complaint names "cellular phones and tablet devices" manufactured and sold by Samsung as the "Accused Instrumentalities," using the Samsung Galaxy S23 ("S23") as a representative example for its infringement allegations Compl. ¶¶46, 50

Functionality and Market Context

• Functionality and Market Context:
  • The accused products are described as having a physical design featuring a large, touch-sensitive display that covers nearly the entire front face, with no physical buttons or keyboard on that surface Compl. ¶¶55, 67 A screenshot from Samsung's website presents the S23 with specifications showing a height of 146.3 mm, width of 70.9 mm, and depth of 7.6 mm Compl. ¶51 Compl. p. 19
  • The devices run an operating system that provides user interface features such as a top-edge notification bar and side "Edge panels," which provide access to applications and notifications via swipe gestures originating from the screen's periphery Compl. ¶¶87, 89, 92-93
  • The software includes an on-screen keyboard that can be used for text entry into applications like Samsung Messages. This keyboard includes icons, such as a microphone, which upon activation can launch a secondary application interface (e.g., Samsung Voice Input) within the keyboard's screen zone Compl. ¶¶113-114 A screenshot provided in the complaint shows the user interface divided into a zone for the Samsung Messages app and a lower zone for the keyboard Compl. ¶113 Compl. p. 48

IV. Analysis of Infringement Allegations

11,503,144 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the construction of relative and non-standard terms. Questions may include whether the S23's rounded corners fall within the scope of "practically rectangular-shaped" and how a court will interpret the anthropometric limitation "approximately corresponds to the distance between the ear and the mouth." Further, the meaning of "practically covers the entire front surface" will be critical, given the presence of bezels and a camera cutout on the accused device.
  • Technical Questions: The allegation that no components are "noticeably extended" from the housing may be contested, with a potential focus on the definition of "noticeable" and a factual analysis of the device's physical profile, including any camera bump. The complaint's image of the recessed rear camera lenses on the S23 Ultra is presented as evidence for this element Compl. p. 23

9,304,602 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The case may turn on whether standard operating system UI elements, such as the Android notification bar or Samsung's "Edge panels," meet the claim definition of a "window... that functions independently." A defendant could argue these are integrated parts of the OS experience, not independent windows as contemplated by the patent. The complaint provides screenshots showing the consistent appearance of the notification bar across four different applications to support the "independent" functionality Compl. p. 37
  • Technical Questions: A potential point of dispute is whether a user's gesture truly originates "from outside of the touch screen." It raises the evidentiary question of how to distinguish a gesture starting off-screen from one starting at the absolute periphery of the screen's active area.

V. Key Claim Terms for Construction

• Patent: ’144 Patent
• The Term: "practically covers the entire front surface" (from Claim 1)
• Context and Importance: This term is critical because nearly all modern smartphones, including the accused S23, have some form of bezel and a camera cutout ("hole-punch") on their front face. The infringement analysis will depend on whether these features prevent the display from "practically" covering the "entire" surface.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's objective is to overcome the limitations of physical keys by maximizing screen space for a virtual interface Compl. ¶28 Practitioners may argue this purpose supports an interpretation where minor, necessary interruptions like a small camera hole do not negate the "practical" coverage of the surface.
  • Evidence for a Narrower Interpretation: The plain meaning of "entire" could be argued to allow for no interruptions. Furthermore, many figures in the patent depict a solid, uninterrupted display area below a speaker/earpiece area, which could be used to argue that the invention did not contemplate cutouts within the main display portion itself.
• Patent: ’602 Patent
• The Term: "window... functions independently of an interface of an application in use" (from Claim 1)
• Context and Importance: The plaintiff’s theory relies on mapping this term to system-level UI elements like the notification bar and Edge panels. The viability of the infringement claim hinges on whether these elements are considered "independent" from the underlying application.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification distinguishes between events handled by a "general process" for the application and those handled by a "process associated with the thin window" directed by the operating system '602 Patent, col. 8:6-9 This may support a construction where any OS-level overlay that intercepts edge gestures is an "independent" window.
  • Evidence for a Narrower Interpretation: The patent describes the window as potentially "extremely thin," "barely viewable," or "not viewable at all" '602 Patent, col. 8:3-13 A defendant may argue this language points to a specific, invisible active zone, not to prominent, content-filled UI elements like a notification bar, which displays information sourced directly from the running applications.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Samsung induces infringement by providing customers with user guides, instructions, demonstrations, and advertising that instruct and encourage the use of the accused features (e.g., Edge panels) in a manner that allegedly infringes the patents Compl. ¶¶69, 95, 120 Contributory infringement is also alleged on the basis that accused components are not staple articles of commerce and are known by Samsung to be specially adapted for use in an infringing manner Compl. ¶¶73, 99, 124
• Willful Infringement: Plaintiff alleges willfulness based on Samsung's actual notice from the filing of the complaint and, more significantly, on alleged pre-suit knowledge Compl. ¶¶70-72 Compl. ¶¶96-98 Compl. ¶¶121-123 The pre-suit knowledge allegations are based on specific instances where Samsung allegedly cited patents from the asserted families during the prosecution of its own patent applications, with the earliest cited knowledge date for the ’602 patent family being November 15, 2021 Compl. ¶97 and for the ’144 patent family being November 15, 2022 Compl. ¶71

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

• A core issue will be one of definitional scope: can claim terms describing the physical form of a mobile phone from an early-2000s priority patent (the ’144 patent), such as "practically covers the entire front surface," be construed to read on the design of a modern smartphone with bezels and camera cutouts?
• A second key question will be one of functional interpretation: do common, system-level operating system features like a notification bar and a slide-out app launcher (the ’602 patent's "Edge panels") constitute a "window" that "functions independently" of an application, as required by the claims, or are they integrated OS functionalities outside the patent's scope?
• A critical question for damages will be one of scienter: will the evidence that Samsung cited members of the asserted patent families during its own patent prosecution be sufficient to establish pre-suit knowledge and willful infringement, or will Defendant successfully argue that such citations do not constitute notice of the specific patents-in-suit or their alleged infringement?