Firstface Co Ltd v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Firstface Co., Ltd. (Republic of Korea)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Nelson Bumgardner Conroy P.C.
• Case Identification: Firstface Co., Ltd. v. Samsung Electronics Co., Ltd., et al., 2:24-cv-00610, E.D. Tex., 07/31/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains a permanent office and employs personnel in Plano, Texas, and because Defendants conduct substantial business, including sales of the accused products, within the district. Venue over the foreign parent, Samsung Electronics Co., Ltd., is alleged to be proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s smartphone and tablet products infringe five patents related to methods for activating specific device functions, such as camera launch or user authentication, with a single user input while the device display is off.
• Technical Context: The technology at issue involves streamlining user interactions on mobile devices by combining the actions of waking the device and launching a specific application or function into a single gesture.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patents-in-suit and the alleged infringement via a letter dated May 9, 2024.

Case Timeline

Date	Event
2012-08-21	Earliest Priority Date for all Patents-in-Suit
2015-11-03	’298 Patent Issued
2018-05-01	’555 Patent Issued
2018-05-22	’082 Patent Issued
2021-01-19	’442 Patent Issued
2023-01-10	’263 Patent Issued
2024-05-09	Plaintiff’s Notice Letter Sent to Defendant
2024-07-31	Complaint Filed

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

U.S. Patent No. 9,179,298 - Method, mobile communication terminal and computer-readable recording medium for performing specific function when mobile communication terminal is activated

• Patent Identification: U.S. Patent No. 9,179,298, issued November 3, 2015 (Compl. ¶28).

The Invention Explained

• Problem Addressed: The patent describes the inefficiency of requiring users to perform multiple operations to access a function on a mobile device, such as first turning on the display and then separately launching an application (’298 Patent, col. 1:35-47).
• The Patented Solution: The invention is a mobile terminal and method where a single "activating input" on a button, received while the terminal is in an "inactive state" (display off but communicable), simultaneously causes the terminal to enter an "active state" (display on) and perform a predetermined function, such as activating the camera (’298 Patent, Abstract; col. 2:56-68). The function performed can be configured to differ based on the number of presses or the duration of the press (’298 Patent, col. 3:56-col. 4:13).
• Technical Importance: This approach reduces the number of steps required for a user to access frequently used functions from a locked or sleeping device.

Key Claims at a Glance

• The complaint asserts independent claims 1 and 10 (Compl. ¶73).
• Essential elements of independent claim 1 (a mobile communication terminal) include:
  • A display unit, memory, camera, and communication unit.
  • An "activation sensing unit" that detects an "activating input" to change the terminal from an "inactive state" to an "active state."
  • Performing a "predetermined operation simultaneously with the change" from inactive to active.
  • The predetermined operation includes "activating the camera and displaying a scene currently being photographed."
• The complaint reserves the right to assert dependent claims 2, 4, 11, and 12 (Compl. ¶73).

U.S. Patent No. 9,959,555 - Activating display and performing additional function in mobile terminal with one-time user input

• Patent Identification: U.S. Patent No. 9,959,555, issued May 1, 2018 (Compl. ¶34).

The Invention Explained

• Problem Addressed: The patent addresses the same general problem as the ’298 Patent: the multi-step process required to wake a device and then perform a subsequent action (’555 Patent, col. 1:19-42).
• The Patented Solution: The invention provides a method where a single user input on a button, while the display is off, both turns on the display to show a lock screen and performs user authentication (e.g., fingerprint or iris scan) "with no additional user input." If the user is authenticated, a "lock state" is released; otherwise, the lock state is maintained (’555 Patent, Abstract; col. 2:50-68).
• Technical Importance: This invention combines the distinct user actions of waking a device and authenticating to unlock it into a single, seamless gesture.

Key Claims at a Glance

• The complaint asserts independent claims 1, 12, 22, and 31 (Compl. ¶82).
• Essential elements of independent claim 1 (a method) include:
  • Receiving a user input on a button while the display is off.
  • In response, turning on the display and displaying a lock screen.
  • Also in response, "authenticating said user in addition to turning on the display with no additional user input."
  • Upon completion, "releasing a lock state...if said user is authenticated."
• The complaint also asserts numerous dependent claims (Compl. ¶82).

U.S. Patent No. 9,978,082 - Activating display and performing additional function in mobile terminal with one-time user input

• Patent Identification: U.S. Patent No. 9,978,082, issued May 22, 2018 (Compl. ¶39).
• Technology Synopsis: This patent claims a mobile terminal and method where a first press of a button from an inactive state initiates a user authentication process and turns on the display (’082 Patent, Claim 1). The patent further claims that consecutive re-pressing of the button within a threshold time performs a separate function, such as activating the camera, distinct from the authentication process (’082 Patent, Claim 1).
• Asserted Claims: Claims 1–6, 9–17, and 20 are asserted, including independent claims 1 and 11 (Compl. ¶91).
• Accused Features: The complaint accuses Samsung devices of infringement based on their ability to perform biometric authentication from a screen-off state via a button press, and to launch other applications like the camera via subsequent presses of the same button (Compl. ¶91).

U.S. Patent No. 10,896,442 - Activating display and performing additional function in mobile terminal with one-time user input

• Patent Identification: U.S. Patent No. 10,896,442, issued January 19, 2021 (Compl. ¶44).
• Technology Synopsis: This patent claims a mobile terminal configured to switch from an inactive state to an active state upon receiving a user input on a button (’442 Patent, Claim 1). This single input also triggers a user authentication process (e.g., iris, face, fingerprint), and the terminal is configured to display a lock screen regardless of the authentication result, releasing the lock only if authentication is successful (’442 Patent, Abstract; col. 13:5-15).
• Asserted Claims: Claims 1–3 and 6–11 are asserted, including independent claim 1 (Compl. ¶100).
• Accused Features: The complaint targets the biometric unlock functionalities of Samsung devices, where a single press of a button from a screen-off state wakes the device, displays a lock screen, and concurrently attempts user authentication (Compl. ¶100).

U.S. Patent No. 11,551,263 - Activating display and performing additional function in mobile terminal with one-time user input

• Patent Identification: U.S. Patent No. 11,551,263, issued January 10, 2023 (Compl. ¶49).
• Technology Synopsis: This patent claims a terminal where different functions are performed from an inactive state based on the type of button press received. A button press longer than a first threshold time performs a hands-free function, while a second press within a second threshold time activates the camera (’263 Patent, Abstract; Claim 1). This allows for multiple, distinct functions to be launched from a single button without first waking the device.
• Asserted Claims: Claims 1–4 are asserted, including independent claim 1 (Compl. ¶109).
• Accused Features: The complaint targets features on Samsung devices that allow users to launch the camera or other functions via single, double, or long presses of a physical button (e.g., the side key) while the screen is off (Compl. ¶109).

III. The Accused Instrumentality

• Product Identification: A broad range of Samsung mobile devices, including flagship and other models such as the Galaxy S24, S24+, S24 Ultra, S23 series, Z Fold6, Z Flip6, Z Fold5, Z Flip5, and various Galaxy Tab models (Compl. ¶56).
• Functionality and Market Context: The complaint targets the functionality in the Accused Products that allows users to access features directly from a screen-off state. Specific accused functionalities appear to include: (1) waking the device and simultaneously performing biometric authentication (e.g., fingerprint, face, or iris scan) with a single button press; and (2) launching the camera application with a double-press or long-press of a physical button while the screen is off (Compl. ¶¶56, 78, 87). The Accused Products are described as central to Samsung's mobile device business in the United States (Compl. ¶¶14, 19).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits 7-11, which were not filed with the public complaint. The infringement theories are summarized below in prose based on the complaint's narrative allegations.

• ’298 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe claims of the ’298 Patent when a user, for example, double-presses the side key while the screen is off (Compl. ¶73; Exhibit 7 (not provided)). This action is alleged to be a single "activating input" that simultaneously changes the device from an "inactive state" (screen off) to an "active state" (screen on) while also performing the "predetermined operation" of activating the camera and displaying the camera's view, as recited in the claims (Compl. ¶¶73-75).
• ’555 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe claims of the ’555 Patent through their biometric unlock features (Compl. ¶82; Exhibit 8 (not provided)). The alleged infringement occurs when a user presses a button (such as a power button with an integrated fingerprint sensor) while the screen is off. This single input is alleged to meet the claim limitations by turning on the display, showing a lock screen, and simultaneously authenticating the user without requiring additional input. If authentication is successful, the device's lock state is released, completing the claimed method (Compl. ¶¶82-84).
• Identified Points of Contention:
  • Scope Questions: A central question may be the construction of temporal terms like "simultaneously with" (’298 Patent) and "in addition to" (’555 Patent). A dispute could arise over whether the accused device's software performs these actions as a single, unified operation as claimed, or as a rapid but technically sequential series of operations that may not meet the claim limitations.
  • Technical Questions: The analysis may turn on whether a multi-press input, such as a "double press" to launch the camera, constitutes a single "activating input" as required by claims like those in the ’298 Patent, or if it is a sequence of distinct inputs. Evidence regarding how the device's operating system processes these hardware inputs will be relevant.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "inactive state" (asserted in claims of multiple patents)

• Context and Importance: The entire inventive concept begins from the device being in an "inactive state." The definition of this term is foundational; if the accused devices are not in this state (for example, if an always-on display is active), infringement may be avoided.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification defines the inactive state as one where "the display unit being turned off while the mobile communication terminal being communicable" (’442 Patent, col. 2:62-64). This could be interpreted broadly to cover any conventional screen-off or sleep mode where the phone can still receive calls and notifications.
  • Evidence for a Narrower Interpretation: The specification explicitly excludes a state where the terminal is "completely turned off" (’442 Patent, col. 3:20-22). A defendant might argue that certain modern low-power modes or states with minimal "always-on" display elements do not fit the specific context of the "inactive state" as described and enabled in the patent's detailed description.

• The Term: "activating input" (asserted in claims of multiple patents)

• Context and Importance: This term defines the user's action that triggers the claimed method. Its construction will be critical in determining whether the single-press, double-press, and long-press functionalities of the accused products fall within the scope of the claims.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the input as the user pressing the "activation button 120 when the mobile communication terminal 100 is in the inactive state" (’442 Patent, col. 3:51-53). A plaintiff may argue that any user-initiated button press from the inactive state that results in activation qualifies.
  • Evidence for a Narrower Interpretation: The specification and claims differentiate between inputs based on duration and number of presses (e.g., ’263 Patent, Claim 1). A defendant may argue that "activating input" should be construed narrowly to mean only the specific type of press that simply wakes the device (a single, short press), and that other inputs like a double-press are distinct types of inputs not covered by claims directed to a single "activating input."

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Samsung induces infringement by providing customers with product manuals, websites, and customer support that instruct and encourage users to configure and use the accused features, such as setting the side key to launch the camera (Compl. ¶¶58, 78, 87).
• Willful Infringement: The willfulness allegation is based on Samsung's alleged knowledge of the patents-in-suit and its infringement since at least the receipt of a notice letter dated May 9, 2024. The complaint alleges that Samsung continued its infringing conduct without responding substantively or formulating a good faith belief of non-infringement (Compl. ¶¶59-60, 65).

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

• A core issue will be one of definitional scope: How will the term "inactive state" be construed in the context of modern smartphones that may utilize "always-on" displays or various low-power sleep modes? The outcome of this construction could determine whether the accused functionality is even capable of infringing.
• A key evidentiary question will be one of input mapping: Does a "double-press" or "long-press" of a button on an accused device constitute a single "activating input" that performs a predetermined function, as claimed in some patents, or does the device's operating system treat these as a sequence of inputs that may fall outside the claim language?
• A central legal and factual question will be the temporal relationship between actions. The case may turn on whether the accused devices' performance of waking the screen and executing a function (like authentication or camera launch) is sufficiently "simultaneous" or "in addition to" the activation, as claimed, or if discovery reveals a technically sequential operation that a court could find to be distinct from the patented method.