DCT

2:24-cv-00532

Pictiva Displays Intl Ltd v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00532, E.D. Tex., 11/25/2024
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Defendant Samsung Electronics America, Inc. maintaining a regular and established place of business in the district, and Defendant Samsung Electronics Co., Ltd. being a foreign corporation subject to jurisdiction in any district.
  • Core Dispute: Plaintiffs allege that Defendant’s consumer electronic products incorporating Organic Light-Emitting Diode (OLED) displays infringe seven U.S. patents related to OLED manufacturing processes, device structures, and material compositions.
  • Technical Context: The dispute centers on OLED technology, a dominant display solution in the consumer electronics market valued for its high image quality, thin form factors, and power efficiency.
  • Key Procedural History: The complaint references a related pending action between the parties (Pictiva I, Case No. 2:23-cv-00495-JRG). It also details a history of pre-suit interactions beginning around June 2020, including patent acquisition notices, infringement allegations, a mutual non-disclosure agreement, and the provision of claim charts by Plaintiffs to Defendant’s subsidiary, Samsung Display Co., Ltd. These allegations form the basis for Plaintiffs’ claims of pre-suit knowledge and willful infringement.

Case Timeline

Date Event
2002-05-02 ’389 Patent Priority Date
2005-09-27 ’389 Patent Issue Date
2007-09-19 ’547 Patent Priority Date
2008-01-01 Samsung allegedly begins incorporating OLED displays (approx.)
2008-05-30 ’164 Patent Priority Date
2008-09-26 ’223 Patent Priority Date
2008-12-11 ’425 and ’250 Patents Priority Date
2012-09-27 ’492 Patent Priority Date
2012-11-20 ’547 Patent Issue Date
2013-10-15 ’223 Patent Issue Date
2014-05-13 ’164 Patent Issue Date
2016-02-09 ’492 Patent Issue Date
2016-09-21 Samsung allegedly gains knowledge of ’547 Patent via IDS
2020-06-01 Pictiva acquires certain OLED patents from OSRAM (approx.)
2020-09-25 Pictiva notifies Samsung of alleged infringement
2020-10-07 Pictiva and Samsung Display Co. enter into NDA
2020-12-16 Pictiva sends a claim chart for the ’389 Patent to Samsung Display Co.
2021-06-30 Samsung allegedly gains knowledge of ’389 Patent infringement (no later than)
2021-08-17 Pictiva reiterates license requirement to Samsung Electronics Co.
2021-08-31 Samsung allegedly gains knowledge of ’223 & ’164 Patent infringement (no later than)
2023-11-28 ’425 Patent Issue Date
2024-11-25 Complaint Filing Date
2024-12-03 ’250 Patent Issue Date

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

U.S. Patent No. 6,949,389 - Encapsulation for Organic Light Emitting Diodes Devices, issued September 27, 2005

The Invention Explained

  • Problem Addressed: The patent describes that a critical manufacturing step for OLEDs is encapsulation to protect the device from damaging environmental effects, primarily oxygen and moisture (’389 Patent, col. 1:7-9). Prior art methods of thin-film encapsulation were noted to have disadvantages related to cost and reliability (Compl. ¶12; ’389 Patent, col. 1:48-52).
  • The Patented Solution: The invention proposes a method for encapsulating multiple OLED devices on a substrate by first "selectively depositing at least one planarization layer" upon the devices, followed by "selectively depositing at least one barrier layer over said planarization layer" (’389 Patent, col. 11:1-5). This selective deposition process is intended to reduce costs, improve reliability, and enable thinner and more flexible device packages compared to prior art methods (Compl. ¶12; ’389 Patent, col. 1:48-52).
  • Technical Importance: This approach to encapsulation sought to improve the manufacturing viability and durability of OLED displays, which were key factors for their broader commercialization in consumer electronics (Compl. ¶12).

Key Claims at a Glance

  • The complaint asserts independent claim 34 (Compl. ¶42).
  • Essential elements of claim 34 include:
    • fabricating a plurality of devices on a substrate;
    • selectively depositing at least one planarization layer upon said devices; and
    • selectively depositing at least one barrier layer over said planarization layer.

U.S. Patent No. 8,314,547 - Opto-Electronic Component, issued November 20, 2012

The Invention Explained

  • Problem Addressed: While not explicitly stated in the complaint, the patented solution addresses the technical challenge of efficiently generating a full spectrum of colors in an OLED display, particularly when using a single-color light source as the foundation.
  • The Patented Solution: The patent describes an optoelectronic device having an organic layer that emits light in a "first wavelength spectrum" (e.g., blue) (’547 Patent, col. 14:56-58). Downstream from this light source is a "structured layer" with two types of regions arranged laterally side-by-side (’547 Patent, col. 14:59-65). The first regions contain a "wavelength conversion layer" that converts the blue light into a "second wavelength spectrum" (e.g., green or red), while the second regions contain a "filter layer" that is transparent to the original blue light (’547 Patent, col. 14:65-15:10). This structure allows a full-color pixel to be created from a single-color blue OLED emitter.
  • Technical Importance: This architecture enables the production of full-color displays using a single, highly stable and efficient blue OLED emitter, a design principle used in modern QD-OLED technology to enhance color performance and manufacturing consistency (Compl. ¶¶20, 51).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶51).
  • Essential elements of claim 1 include:
    • an organic layer sequence which emits an electromagnetic radiation having a first wavelength spectrum;
    • a structured layer disposed downstream of the organic layer sequence, including first and second regions arranged laterally;
    • the first regions including a wavelength conversion layer to convert the first spectrum to a second spectrum; and
    • the second regions including a filter layer that is transparent to the first spectrum but at least partially opaque to a third spectrum corresponding to part of the second spectrum.

U.S. Patent No. 8,558,223 - Organic Electronic Component and Method for the Production Thereof, issued October 15, 2013

  • Technology Synopsis: The ’223 Patent is directed to an organic electronic component containing an electron-conducting layer formed by the "joint vaporization" of a metal complex and a specific organic compound that comprises a heteroaromatic compound conjugated to an aromatic compound via a C-C bond (Compl. ¶14). This process is alleged to improve electron conductivity by increasing the number of "free" electrons, resulting in a layer that is amorphous with short-range order, which enhances reliability and homogeneity of emission (Compl. ¶14).
  • Asserted Claims: At least Claim 1 (Compl. ¶61).
  • Accused Features: The electron transport layers within Samsung’s OLED displays, such as those in the Galaxy S20, which are alleged to be formed by the claimed joint vaporization process using a lithium metal complex and a specific organic compound (Compl. ¶¶61-62).

U.S. Patent No. 8,723,164 - Electronic Device, issued May 13, 2014

  • Technology Synopsis: The ’164 Patent describes an electronic device with an organic functional layer containing at least three distinct matrix materials. The invention defines a specific energetic relationship between these materials: the third has the lowest LUMO (Lowest Unoccupied Molecular Orbital), the second has the highest HOMO (Highest Occupied Molecular Orbital), and the first has a lower charge carrier mobility than the other two (Compl. ¶15). This configuration is asserted to provide an improved charge carrier balance within the organic layers, leading to increased efficiency (Compl. ¶15).
  • Asserted Claims: At least Claim 16 (Compl. ¶72).
  • Accused Features: The display panels in Samsung smartphones, such as the Galaxy S23 Ultra, which are alleged to contain an organic functional layer with at least three matrix materials that meet the claimed relationships for LUMO, HOMO, and charge carrier mobility (Compl. ¶72).

U.S. Patent No. 9,257,492 - Method for Producing a Passive Electronic Component..., issued February 9, 2016

  • Technology Synopsis: The ’492 Patent claims an electronic component and its manufacturing method, focusing on pixel structure and insulation. The invention involves first and second electrically conductive layers on a substrate, a trench that separates contact regions, and a "dielectric" applied in a structured fashion to insulate the regions from each other before a final electrode layer is applied over the structure (Compl. ¶16).
  • Asserted Claims: At least Claim 16 (Compl. ¶82).
  • Accused Features: Samsung’s OLED display panels that allegedly use a pixel define layer (“PDL”) as the claimed dielectric, applied in a structured manner to insulate contact regions separated by a trench before the cathode is applied (Compl. ¶82).

U.S. Patent No. 11,828,425 - Organic-Light Emitting Diode, issued November 28, 2023

  • Technology Synopsis: The ’425 Patent is directed to a device comprising an OLED with a specific structure: an organic layer sequence, a radiation exit area, an encapsulation, and a carrier. The claimed organic layer sequence includes a radiation-emitting region that comprises an n-doped electron transport layer combined with an emission layer containing an iridium-based compound, which is characteristic of a phosphorescent emitter (Compl. ¶17).
  • Asserted Claims: At least Claim 1 (Compl. ¶93).
  • Accused Features: The display panels in Samsung smartphones, such as the Galaxy S23 Ultra, which are alleged to incorporate thin-film encapsulation, an organic layer sequence on a carrier, an n-doped electron transport layer, and an emission layer with iridium-containing compounds (Compl. ¶93).

U.S. Patent No. 12,158,250 - Organic-Light Emitting Diode, to be issued December 3, 2024

  • Technology Synopsis: The ’250 Patent is a continuation of the ’425 Patent and shares the same specification (Compl. ¶18). It describes a device with an OLED having an organic layer sequence, encapsulation, and a carrier. The specification details embodiments where the organic layer includes an electron transport layer comprising 8-hydroxyquinolinolato-lithium ("Liq") and an emission layer comprising an iridium-containing compound (Compl. ¶18).
  • Asserted Claims: At least Claim 1 (Compl. ¶103).
  • Accused Features: The display panels in Samsung smartphones, such as the Galaxy S23 Ultra, which are alleged to have the same features accused of infringing the ’425 Patent, including thin-film encapsulation and specific materials for the electron transport and emission layers (Compl. ¶103).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Accused Products" as a broad range of Samsung consumer electronics that incorporate OLED displays. Specific examples cited include Galaxy smartphones (e.g., S8, S9, S20, S23 Ultra), tablets, computers (e.g., Galaxy Book Pro), personal wear products, and televisions (e.g., S95B TV) (Compl. ¶¶19, 42, 51).

Functionality and Market Context

  • The accused products utilize various forms of OLED technology, including AMOLED (active-matrix organic light-emitting diode), Super AMOLED, and QD-OLED (Quantum Dot OLED) (Compl. ¶¶21, 51). The complaint alleges these technologies are central to the products' market appeal, providing features like high image quality, thinness, power efficiency, and bendable properties (Compl. ¶21). Samsung is positioned as a leader in the global OLED market, with an alleged 90% market share in smartphone OLED displays in 2020 (Compl. ¶20). The complaint uses a diagram to illustrate the alleged structure of Samsung's QD-OLED technology, showing a blue light source, a quantum dot light emitting layer, and a glass substrate (Compl. p. 19).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,949,389 Infringement Allegations

Claim Element (from Independent Claim 34) Alleged Infringing Functionality Complaint Citation Patent Citation
fabricating a plurality of devices on a substrate Samsung’s manufacturing process fabricates multiple OLED devices on an AMOLED substrate. A cross-sectional diagram in the complaint illustrates a "plurality of devices" on a substrate. ¶42; Compl. p. 15 col. 10:46-49
selectively depositing at least one planarization layer upon said devices A planarization layer is deposited over the OLED devices. A diagram in the complaint purports to show this deposition is selective, as the layer covers the active area but not the device edge, camera hole, or data driver. ¶42; Compl. p. 16 col. 11:1-2
selectively depositing at least one barrier layer over said planarization layer A barrier layer is deposited over the planarization layer. The complaint provides a diagram illustrating this barrier layer being selectively deposited over the previously deposited planarization layer. ¶42; Compl. p. 16 col. 11:3-5
  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over the meaning of "selectively depositing." The complaint's visuals suggest a process where material is applied only to desired areas. The question for the court will be whether this claim term can be construed to cover modern manufacturing techniques that might involve depositing a layer over a wider area and subsequently removing unwanted portions (e.g., via photolithography), or if its scope is limited to additive processes like printing or nozzle deposition described in the patent specification.

U.S. Patent No. 8,314,547 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an organic layer sequence which emits an electromagnetic radiation having a first wavelength spectrum during operation The accused S95B TV allegedly uses an OLED panel with a blue light emitting source, which constitutes the organic layer sequence emitting a first wavelength spectrum. The complaint includes a diagram showing a "Blue light emitting source" in its QD-OLED structure. ¶51; Compl. p. 19 col. 14:56-58
a structured layer disposed downstream...including first and second regions which are arranged laterally The display allegedly includes a layer with laterally arranged subpixels, where green and red subpixels correspond to the "first regions" and blue subpixels correspond to the "second regions." ¶51; Compl. p. 19 col. 14:59-65
wherein the first regions each include a wavelength conversion layer configured to convert...first wavelength spectrum into...a second wavelength spectrum The green and red subpixels allegedly use quantum dot (QD) layers to convert the blue light from the source into green and red light, respectively. ¶51; Compl. p. 19 col. 14:65-15:3
wherein the second regions each include a filter layer which...is transparent to the...first wavelength spectrum The blue subpixel regions allegedly include a filter layer that allows the blue light from the source to pass through. A diagram in the complaint illustrates this concept with a simplified pixel structure. ¶51; Compl. p. 20 col. 15:6-10
  • Identified Points of Contention:
    • Technical Questions: The analysis may focus on the precise function of the structure in the "second regions" (the blue subpixels) of the accused QD-OLED displays. The claim requires a "filter layer" that is not only transparent to the first wavelength (blue) but also "at least partially opaque" to a third wavelength related to the second (green/red). The evidentiary question will be whether the accused blue subpixel structure performs this specific filtering function or if it is merely a transmissive path for the blue source light.

V. Key Claim Terms for Construction

Patent: U.S. Patent No. 6,949,389

  • The Term: "selectively depositing"
  • Context and Importance: This term is at the core of the infringement allegation for the ’389 Patent. Its construction will determine whether Samsung’s manufacturing process, which may differ from the specific deposition methods described in the patent, falls within the claim scope. Practitioners may focus on this term because the patent specification describes methods like patterned curing followed by removal of unpatterned liquid, which could be contrasted with modern, high-volume photolithography techniques.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language of the claim does not specify the mechanism of selection. A party could argue that any process resulting in a patterned layer—including blanket deposition followed by selective removal—achieves a "selective deposit." The patent's abstract also uses the general phrase "selectively depositing."
    • Evidence for a Narrower Interpretation: The detailed description discusses specific methods like deposition through a mask or using a gas nozzle system to direct material flow, which imply additive deposition only in desired locations (’389 Patent, col. 6:8-12, col. 7:33-46). A party could argue that these examples limit the term to processes where the deposition step itself is patterned, not a subsequent removal step.

Patent: U.S. Patent No. 8,314,547

  • The Term: "filter layer"
  • Context and Importance: The definition of this term is critical for determining infringement by the blue subpixels in Samsung's QD-OLED displays. The claim requires this layer to have a dual optical property: transparency to the first wavelength (blue) and opacity to a third wavelength related to the converted colors (green/red). The infringement case depends on whether the accused structure performs this specific filtering function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that an object of the invention is to "reduce or avoid an undesired color impression in a switched-off state" (’547 Patent, col. 2:19-21). A party might argue that any layer in the blue subpixel that helps achieve this goal by managing light—such as a color filter that enhances blue purity by blocking ambient light—meets the functional requirement of a "filter layer."
    • Evidence for a Narrower Interpretation: The claim language is specific, requiring the filter to be "at least partially opaque to an electromagnetic radiation having a third wavelength spectrum which corresponds to at least one part of the second wavelength spectrum" (’547 Patent, col. 15:6-10). A party could argue this requires the filter to actively block specific wavelengths generated by the color-converting "first regions," a function that a simple blue-pass color filter might not perform.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all asserted patents. The allegations are based on Samsung intentionally encouraging and aiding third parties, including vendors, customers, and partners, to make, use, or sell the accused products. This encouragement is alleged to occur through activities such as advertising infringing features, distributing the products, and providing technical assistance and literature (Compl. ¶¶32, 43, 52).
  • Willful Infringement: Willfulness is alleged for all asserted patents based on both pre-suit and post-suit knowledge. The complaint alleges Samsung had pre-suit knowledge of the ’547 Patent since at least September 2016 from citing it in an Information Disclosure Statement, and of the ’389, ’223, and ’164 patents since no later than mid-2021 through direct licensing discussions and the provision of claim charts (Compl. ¶¶23, 26-27, 45, 54, 66, 76). For the remaining patents, knowledge is alleged from at least the service of complaints in a related or the current litigation (Compl. ¶¶29, 87, 97, 107).

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

  • A core issue will be one of process scope: For the ’389 patent, can the claim term "selectively depositing," which the patent specification links to methods like masked deposition and patterned curing, be construed to cover modern, high-volume OLED manufacturing processes that may rely on blanket deposition and photolithographic removal?
  • A key question will be one of functional correspondence: For the ’547 patent and the accused QD-OLED displays, does the structure within the blue subpixels perform the dual optical function of a "filter layer" as defined by the claim—specifically, being transparent to blue light while also being opaque to wavelengths associated with the converted red and green light?
  • A central theme of the case will be willfulness and intent: Given the extensive history of pre-suit communications, including licensing negotiations and claim chart exchanges alleged in the complaint, a key question for the fact-finder will be whether Samsung’s continued alleged infringement after receiving detailed notice was objectively reckless, potentially justifying an award of enhanced damages.