DCT
2:24-cv-00880
CM HK Ltd v. Samsung Electronics Co Ltd
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: CM HK Ltd (Hong Kong)
- Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: The Shore Firm LLP; Offor Evans PLLC
- Case Identification: 2:24-cv-00880, E.D. Tex., 01/28/2025
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics America, Inc. because it maintains a regular and established place of business in the district. Venue is alleged to be proper for the foreign parent, Samsung Electronics Co., Ltd., on the basis that it is a foreign entity that may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s Galaxy smartphone line infringes patents related to methods for correcting and improving the accuracy of motion sensor data to determine a device's orientation.
- Technical Context: The technology concerns sensor fusion—the process of combining data from accelerometers, gyroscopes, and magnetometers—to provide precise, drift-free orientation and motion tracking for electronic devices.
- Key Procedural History: The complaint alleges that Samsung has had knowledge of the patents-in-suit since at least September 18, 2024, when Samsung itself filed a declaratory judgment action of non-infringement in the Northern District of California. This prior action is cited as a primary basis for Plaintiff's willful infringement claim. The complaint also references a prior lawsuit by CyWee Group against Samsung involving related patents as a basis for knowledge.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-06 | Android Gingerbread (API 9) released with "Rotation Vector" sensor |
| 2011-03-28 | Earliest Priority Date for ’846 and ’687 Patents |
| 2013-10-31 | Android KitKat (API 19) released with "Game Rotation Vector" sensor |
| 2015-10-02 | Samsung allegedly begins using its own sensor fusion library |
| 2020-12-01 | U.S. Patent No. 10,852,846 issues |
| 2021-01-29 | Release of Samsung Galaxy S21, the first-listed accused product |
| 2023-07-11 | U.S. Patent No. 11,698,687 issues |
| 2024-09-18 | Samsung files Declaratory Judgment action against CM HK |
| 2025-01-28 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,852,846 - “Electronic device for use in motion detection and method for obtaining resultant deviation thereof,” issued December 1, 2020
The Invention Explained
- Problem Addressed: The patent describes that prior art motion-sensing devices, particularly those with 5-axis sensors, could not accurately calculate a device's true orientation (yaw, pitch, and roll) in a 3D spatial frame, especially when subject to dynamic movements and external forces beyond gravity (Compl. ¶111; ’846 Patent, col. 3:1-28). Such systems could only provide a "relative" movement pattern, leading to inaccuracies and drift over time (’846 Patent, col. 3:29-40).
- The Patented Solution: The invention claims to solve this problem by using a nine-axis sensor module (rotation sensor, accelerometer, magnetometer) and a specific comparison method. The method involves using angular velocity data (from the rotation sensor) to calculate a "current state" and then derive "predicted axial accelerations." These predicted accelerations are then compared with the "measured axial accelerations" (from the accelerometer) to obtain a corrected, or "updated," orientation state represented by a quaternion (’846 Patent, FIG. 7, steps 715-735). This comparison model is designed to decouple gravitational forces from other external accelerations, thereby yielding a more accurate and "absolute" orientation (’846 Patent, col. 17:36-44, col. 19:26-40).
- Technical Importance: This improved method for calculating orientation enables more precise and reliable motion tracking in smartphones and other devices, which is a critical foundation for features like augmented reality, advanced gaming, and stable user interfaces (’846 Patent, col. 4:6-14).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 3, 7, and 9 (Compl. ¶99).
- Essential elements of independent claim 1 include:
- An electronic device comprising a display, a motion sensor (rotation sensor and accelerometer), and a computing processor.
- The processor is configured to calculate a resulting deviation by:
- providing a previous quaternion corresponding to time T-1.
- converting measured angular velocities at time T into a current quaternion and predicted axial accelerations, without using the measured axial accelerations.
- comparing the predicted axial accelerations with the measured axial accelerations to obtain a first comparison result.
- obtaining an updated quaternion based on the comparison result.
- using the updated quaternion as the next occurrence of the previous quaternion.
- providing the resulting deviation based on the updated quaternion.
- The complaint reserves the right to assert other claims (Compl. ¶99).
U.S. Patent No. 11,698,687 - “Electronic device for use in motion detection and method for obtaining resultant deviation thereof,” issued July 11, 2023
The Invention Explained
- Problem Addressed: As a continuation of the '846 Patent, the '687 Patent addresses the same technical problem: the inability of prior art systems to accurately calculate a device's absolute 3D orientation in dynamic environments due to sensor drift and the difficulty of distinguishing gravity from other accelerations (’687 Patent, col. 3:1-28).
- The Patented Solution: The '687 Patent discloses the same core technical solution as its parent: a comparison method that uses angular velocity data to predict what axial accelerations should be, and then compares that prediction to what the accelerometer actually measures to correct for errors and produce an updated, more accurate orientation (’687 Patent, FIG. 7, steps 715-735). The claims are framed as a method rather than a device, but the underlying technical process is the same.
- Technical Importance: The method provides the same technical benefit of enabling accurate, drift-free motion tracking for modern electronic device applications (’687 Patent, col. 4:6-14).
Key Claims at a Glance
- The complaint asserts independent claims 1, 14, and 25, along with multiple dependent claims (Compl. ¶106).
- Essential elements of independent claim 1 (a method claim) include:
- Generating measured angular velocities and measured axial accelerations with a motion sensor.
- Calculating a resulting deviation by:
- providing a previous quaternion corresponding to time T-1.
- converting measured angular velocities at time T into a current quaternion and predicted axial accelerations, without using the measured axial accelerations.
- comparing the predicted axial accelerations with the measured axial accelerations to obtain a first comparison result.
- obtaining an updated quaternion based on the comparison result.
- using the updated quaternion as a next occurrence.
- providing the resulting deviation based on the updated quaternion.
- Providing content based on the resulting deviation.
- The complaint reserves the right to assert other claims (Compl. ¶106).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Samsung’s Galaxy Phones released since December 1, 2020, including the Galaxy S, Z Flip, and Z Fold series smartphones (Compl. ¶47).
Functionality and Market Context
- The complaint alleges that the accused Galaxy Phones incorporate a Qualcomm Snapdragon Sensor Core and Sensing Hub, which are always-on, low-power processors that collect and process data from an accelerometer, gyroscope, and magnetometer (Compl. ¶¶50-54, 57).
- It is alleged that Samsung uses its own custom sensor fusion library, which replaced the standard Android library and runs on this hardware (Compl. ¶¶34, 36). This system allegedly provides device orientation data for features like screen rotation, motion gestures, and applications such as Google Maps and the SmartThings App (Compl. ¶¶55, 82, 92).
- The complaint includes a diagram from Android's developer documentation to illustrate the two coordinate systems—a device-fixed frame and a global reference frame—that are central to orientation tracking (Compl. ¶¶32, Figure 5-4, p. 6). This visual from an Android source document, which Samsung's system is alleged to be based on, illustrates the foundational concepts of orientation sensing at issue in the case (Compl. ¶¶22, 40).
- Plaintiff alleges that Samsung’s Galaxy Phones have captured between 28% and 35% of the U.S. market since December 1, 2020, positioning them as a major commercial product line (Compl. ¶49).
IV. Analysis of Infringement Allegations
’846 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An electronic device... comprising: a display... a motion sensor module comprising a rotation sensor and an accelerometer... and a computing processor... | The accused Galaxy Phones contain a display, a motion sensor module with an accelerometer and gyroscope (rotation sensor), and one or more computer processors (e.g., Qualcomm Snapdragon Sensor Core). | ¶¶50-52, 62-64 | col. 9:6-32 |
| converting measured angular velocities corresponding to time T... into a current quaternion and predicted axial accelerations without using the measured axial accelerations... | Samsung’s sensor fusion code allegedly uses a "predict()" function that updates the phone's orientation based on measured angular accelerations (velocities), which corresponds to calculating predicted axial accelerations. | ¶38 | col. 14:48-54 |
| comparing the predicted axial accelerations... with the measured axial accelerations corresponding to time T to obtain a first comparison result; | Samsung’s sensor fusion code then allegedly uses an "update()" function that uses the phone's accelerometer data (measured axial accelerations) to further refine the orientation, which corresponds to the comparison step. | ¶39 | col. 13:51-55 |
| obtaining an updated quaternion associated with time T based on the current quaternion and the first comparison result... | The combination of the "predict()" and "update()" functions is alleged to result in an updated quaternion that represents the phone's refined orientation. | ¶¶38-39, 42 | col. 14:55-58 |
’687 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| generating, with a motion sensor module... measured angular velocities and measured axial accelerations; | The accused Galaxy Phones contain a motion sensor module (Qualcomm Sensing Hub) with a gyroscope and accelerometer that generate angular velocity and axial acceleration data. | ¶¶50-53, 57 | col. 5:6-10 |
| converting measured angular velocities... into a current quaternion and predicted axial accelerations without using the measured axial accelerations... | As with the '846 Patent, Samsung’s sensor fusion code is alleged to use a "predict()" function based on measured angular velocities to calculate a predicted orientation state. | ¶38 | col. 14:48-54 |
| comparing the predicted axial accelerations with the measured axial accelerations... to obtain a first comparison result; | As with the '846 Patent, Samsung’s sensor fusion code is alleged to use an "update()" function with accelerometer data to compare against the predicted state. | ¶39 | col. 13:51-55 |
| providing content based on the resulting deviation in the spatial reference frame. | The calculated orientation is used to enable features like screen rotation and provide heading/direction in applications like Google Maps, which constitutes providing content based on the deviation. | ¶¶55, 86 | col. 19:15-24 |
- Identified Points of Contention:
- Technical Question: The central dispute appears to be a factual and technical one over how Samsung's sensor fusion algorithm actually works. The complaint alleges a "predict-then-update" sequence that maps to the claims' "predict-then-compare" limitation. However, the complaint also quotes Samsung’s own filing in a prior action, which states its devices "do not include or practice... obtaining a quaternion by predicting axial accelerations" and instead "utilize measured angular velocity and acceleration" directly (Compl. ¶111). This raises the question of what evidence will show whether Samsung's process includes the specific predictive step required by the claims.
- Scope Questions: What is the scope of "predicted axial accelerations"? Does the term require the specific mathematical conversion shown in the patent's equations (e.g., ’846 Patent, col. 17:20-25), or can it be construed more broadly to cover any algorithm that uses angular velocity data to form a predictive model that is then corrected by measured accelerometer data?
V. Key Claim Terms for Construction
- The Term: "predicted axial accelerations" (appears in independent claim 1 of both patents)
- Context and Importance: This term is the core technical limitation at the heart of the dispute. Practitioners may focus on this term because Samsung, in its own declaratory judgment complaint, has already signaled its non-infringement position by denying that its devices calculate "predicted axial accelerations" (Compl. ¶111). The outcome of the case could hinge on whether Samsung's accused method is found to meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the overall goal as an "enhanced comparison method and/or model to eliminate the accumulated errors" by comparing signals from different sensors (’846 Patent, col. 4:46-66). A party could argue that any process that uses gyroscope data to predict an orientation and then uses accelerometer data to correct that prediction falls within the spirit of the invention, regardless of the precise mathematical steps.
- Evidence for a Narrower Interpretation: The specification provides specific, detailed equations for calculating "predicted axial accelerations (Ax', Ay', Az')" from a quaternion, which is itself derived from angular velocities (’846 Patent, col. 17, eq. (2)-(4)). A party could argue that the term should be limited to this disclosed embodiment, and that any method not performing this specific calculation does not infringe.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for both patents, asserting that Samsung had knowledge of the patents and their infringement while making and selling the accused Galaxy Phones (Compl. ¶¶100, 107). The factual basis includes Samsung providing devices with the accused functionality and instructions for using applications like Google Maps that rely on it (Compl. ¶¶68, 82-83).
- Willful Infringement: The complaint pleads willfulness based on Samsung’s alleged knowledge of the patents since at least September 18, 2024, the date Samsung filed a declaratory judgment action against CM HK concerning the same patents (Compl. ¶110). This is presented as direct, pre-suit knowledge. The complaint further alleges knowledge based on a prior lawsuit from a related entity (CyWee Group against Samsung) and Samsung's continued sales after becoming aware of the patents, allegedly without obtaining an opinion of counsel (Compl. ¶¶116, 119, 122).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the answers to two primary questions:
- A central evidentiary and technical question: Does the accused Samsung sensor fusion algorithm, in its actual operation, perform the specific step of creating "predicted axial accelerations" from angular velocity data for the purpose of comparison with measured accelerometer data, as claimed in the patents? Or does it employ a fundamentally different, non-infringing method of sensor data integration, as Samsung’s prior court filings suggest?
- A critical claim construction question: What is the proper scope of the term "predicted axial accelerations"? Will the court define it narrowly, limiting it to the specific mathematical formulas disclosed in the patent's specification, or will it adopt a broader functional definition that could encompass a wider range of predictive error-correction algorithms?
- A significant damages question: If infringement is found, will Samsung's decision to continue selling the accused products after filing its own declaratory judgment action on the patents-in-suit be considered "objectively reckless" conduct sufficient to support a finding of willful infringement and potential enhanced damages?