DCT
2:24-cv-00880
CM HK Ltd v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: CM HK Ltd (Hong Kong)
- Defendant: Samsung Electronics Co., Ltd. (South Korea) and 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., 11/01/2024
- Venue Allegations: Venue is alleged against Samsung Electronics America based on its regular and established place of business in Plano, Texas, and against Samsung Electronics Co., Ltd. as a foreign entity that conducts business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ Galaxy smartphones, which utilize custom sensor fusion software, infringe two patents related to methods for accurately determining device orientation.
- Technical Context: The technology at issue involves sensor fusion—the process of combining data from accelerometers, gyroscopes, and magnetometers—to correct for drift and interference, enabling precise motion tracking for applications like augmented reality and navigation.
- Key Procedural History: The complaint notes that Defendant Samsung filed a declaratory judgment action for non-infringement of the same patents in the Northern District of California on September 18, 2024, approximately six weeks before this complaint was filed. Plaintiff also alleges Samsung was aware of related patents from a prior lawsuit involving CyWee Group.
Case Timeline
| Date | Event |
|---|---|
| 2010-01-06 | Earliest Priority Date for ’846 and ’687 Patents |
| 2010-12-06 | Android 2.3 (Gingerbread) released with "Rotation Vector" sensor |
| 2013-10-31 | Android 4.4 (KitKat) released with "Game Rotation Vector" sensor |
| 2015-10-02 | Android Marshmallow released; Samsung allegedly replaced Android's sensor fusion library |
| 2020-12-01 | U.S. Patent No. 10,852,846 Issued |
| 2021-01-29 | Galaxy S21, S21+, S21 Ultra released |
| 2021-08-27 | Galaxy Z Flip3, Z Fold3 released |
| 2022-01-11 | Galaxy S21 FE released |
| 2022-02-25 | Galaxy S22, S22+, S22 Ultra released |
| 2022-08-26 | Galaxy Z Flip4, Z Fold4 released |
| 2023-02-17 | Galaxy S23, S23+, S23 Ultra released |
| 2023-07-11 | U.S. Patent No. 11,698,687 Issued |
| 2023-08-11 | Galaxy Z Flip5, Z Fold5 released |
| 2024-01-31 | Galaxy S24, S24+, S24 Ultra released |
| 2024-07-24 | Galaxy Z Flip6, Z Fold6 released |
| 2024-09-18 | Samsung files declaratory judgment action in N.D. Cal. |
| 2024-11-01 | Complaint Filed in E.D. Tex. |
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"
- Patent Identification: 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 the difficulty of accurately tracking the 3D orientation (yaw, pitch, and roll) of an electronic device using motion sensors. Prior art systems were susceptible to accumulated errors and could not reliably distinguish between gravitational forces and other accelerations, particularly in dynamic environments, leading to inaccurate motion tracking. (’846 Patent, col. 3:1-27).
- The Patented Solution: The invention proposes a method using a nine-axis motion sensor (combining a rotation sensor, accelerometer, and magnetometer) to improve accuracy. The core of the solution is a predict-and-compare model that uses quaternions to represent the device's orientation. The system first predicts the device's axial accelerations based on its previous state and measured angular velocity, and then compares this prediction to the currently measured axial accelerations to calculate a more accurate, updated orientation that filters out errors from drift and external interference. (’846 Patent, Abstract; col. 4:29-59; Fig. 7).
- Technical Importance: This method claims to provide a more "absolute" and drift-free orientation tracking, which is critical for the functionality of applications that rely on knowing a device's precise position and movement in 3D space, such as navigation and augmented reality. (’846 Patent, col. 4:4-9).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 7, and 8 (Compl. ¶91).
- Independent Claim 1 recites an electronic device with a motion sensor and a processor 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, notably "without using the measured axial accelerations corresponding to time T."
- Comparing the predicted axial accelerations with the measured axial accelerations to obtain a first comparison result.
- Obtaining an updated quaternion based on the current quaternion and the comparison result.
- Using the updated quaternion as the next previous quaternion for a subsequent calculation.
- Translating the resulting orientation angles into a real-time movement pattern on a display.
U.S. Patent No. 11,698,687 - "Electronic device for use in motion detection and method for obtaining resultant deviation thereof"
- Patent Identification: 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 application that led to the ’846 Patent, this patent addresses the same fundamental problem of inaccurate orientation tracking in electronic devices due to sensor drift and external interference. (’687 Patent, col. 3:1-27).
- The Patented Solution: The ’687 Patent discloses a similar predict-and-compare method using quaternions. A key distinction in its independent claim is the specific instruction to convert variables of the current quaternion into predicted axial accelerations that are "associated with the pitch and roll angles of the electronic device and without being associated with the yaw angle." This suggests a method that isolates the correction of pitch and roll from yaw calculations, potentially to handle magnetic interference (which primarily affects yaw) separately. (’687 Patent, col. 14:48-52; Claim 1).
- Technical Importance: This refined approach aims to further improve the accuracy of orientation tracking by isolating different sources of error, a crucial step for robust performance in real-world conditions where both physical and magnetic interference are present. (’687 Patent, col. 4:4-9).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 3, 9, 14, 15, 16, and 22 (Compl. ¶98).
- Independent Claim 1 recites an electronic device with a motion sensor and processor configured to calculate a resulting deviation by:
- Providing a previous quaternion at time T-1.
- Converting measured angular velocities at time T into a current quaternion.
- Converting variables of the current quaternion into predicted axial accelerations "associated with the pitch and roll angles... and without being associated with the yaw angle."
- Comparing the predicted axial accelerations with measured axial accelerations.
- Obtaining an updated quaternion based on this comparison.
- Using the updated quaternion for the next cycle.
- Providing content based on the resulting deviation.
III. The Accused Instrumentality
Product Identification
- The complaint accuses a range of Samsung smartphones, collectively referred to as the "Galaxy Phones," released since December 1, 2020, including models from the Galaxy S, Galaxy Z Flip, and Galaxy Z Fold series (Compl. ¶44). The Samsung SmartTag is also mentioned as an example of a product utilizing the accused technology (Compl. ¶79).
Functionality and Market Context
- The complaint alleges that the accused Galaxy Phones contain the necessary hardware for the patented methods, including an accelerometer, gyroscope, and magnetometer, as well as a dedicated low-power processor (Qualcomm Sensing Hub) for handling sensor data (Compl. ¶¶47-52).
- The core of the infringement allegation centers on Samsung’s proprietary software. The complaint alleges that beginning with the Marshmallow version of Android, Samsung replaced Google's standard sensor fusion library with its own custom code (Compl. ¶34). This custom code allegedly performs the patented methods of calculating quaternions to determine device orientation, which is then made available to applications like Google Maps and Samsung's SmartThings app (Compl. ¶¶36, 62, 83-84).
- The complaint provides a diagram, sourced from Android developer documentation, illustrating the two coordinate systems used by orientation sensors: a "global coordinate system" fixed to the Earth and a "device coordinate system" that rotates with the phone (Compl. p. 6, FIGURE 5-4). Plaintiff alleges these correspond to the "spatial reference frame" and "display reference frame" recited in the patents (Compl. ¶32).
- The complaint asserts that the accused Galaxy Phones have captured a significant share of the U.S. market, between 28% and 35% (Compl. ¶46).
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 motion sensor module comprising a rotation sensor and an accelerometer | Every accused Galaxy Phone has an accelerometer, gyroscope, and magnetometer. | ¶47 | col. 5:26-44 |
| a computing processor... configured to calculate a resulting deviation | The accused Galaxy Phones contain one or more computer processors and a Qualcomm Sensing Hub that processes sensor data using Samsung's custom sensor fusion code. | ¶¶34, 48-49, 56 | col. 6:49-62 |
| providing a previous quaternion corresponding to time T-1 | Samsung's sensor fusion code allegedly calculates quaternions using sensor data to track orientation over time, necessarily relying on a previous state for the next calculation. | ¶¶39, 43 | col. 7:1-6 |
| converting the measured angular velocities... into a current quaternion and predicted axial accelerations without using the measured axial accelerations | The complaint alleges Samsung's devices calculate quaternions using measured angular velocity and axial acceleration, but it specifically quotes Samsung's own denial of "predicting axial accelerations." | ¶¶39, 103 | col. 7:7-14 |
| comparing the predicted axial accelerations... with the measured axial accelerations... to obtain a first comparison result | The complaint alleges Samsung's sensor fusion involves "comparing angular velocities and axial accelerations" to ensure precise tracking. It also quotes Samsung's denial of this specific comparison step. | ¶¶40, 103 | col. 7:20-24 |
| obtaining an updated quaternion... based on the... first comparison result | The complaint alleges Samsung's process results in accurate, drift-free motion tracking, which implies a correction or update step. | ¶43 | col. 7:15-19 |
| translate the resultant angles of the resulting deviation... into a real-time movement pattern in the display reference frame | The complaint alleges that applications on the Galaxy Phones, such as Google Maps, provide a heading or direction that changes as the user's device changes direction. | ¶78 | col. 7:25-39 |
'687 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An electronic device... comprising: a motion sensor module... and a computing processor | As with the ’846 patent, the accused Galaxy Phones contain the necessary sensors and processors. | ¶¶47, 56 | col. 5:26-30 |
| converting variables of the current quaternion into predicted axial accelerations... without being associated with the yaw angle | The complaint makes general allegations of calculating quaternions but does not provide specific facts to show that Samsung's code predicts accelerations in a manner that is explicitly dissociated from yaw. | ¶¶39, 104 | col. 13:35-42 |
| comparing the predicted axial accelerations with the measured axial accelerations | The complaint alleges a general comparison of sensor data but also quotes Samsung's denial of performing this claimed comparison. | ¶¶40, 104 | col. 13:43-46 |
| providing content based on the resulting deviation in the spatial reference frame | The complaint alleges that applications on the Galaxy Phones provide visual content (e.g., a map heading) based on the calculated orientation. | ¶¶78, 83 | col. 13:51-54 |
- Identified Points of Contention:
- Technical Questions: The central factual dispute will be whether Samsung’s proprietary sensor fusion code actually performs the "predict-and-compare" steps recited in the claims. The complaint itself highlights this issue by quoting Samsung's denial from its declaratory judgment action, which states its devices "do not include or practice... obtaining a quaternion by predicting axial accelerations; [or] comparing predicted axial accelerations with measured axial accelerations" (Compl. ¶¶103, 104). The case will require expert analysis of Samsung's source code.
- Scope Questions: A key question for the ’687 Patent will be the meaning of the negative limitation "without being associated with the yaw angle." The parties will likely dispute what level of mathematical or functional separation is required to satisfy this element.
V. Key Claim Terms for Construction
The Term: "predicted axial accelerations"
Context and Importance: This term is the technological core of the asserted claims and the primary point of dispute, as evidenced by Samsung's denial in its DJ complaint (Compl. ¶¶103, 104). The definition will determine whether Samsung's method of error correction, whatever it may be, falls within the claim scope. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may argue that any algorithm that corrects for drift by modeling expected sensor behavior based on a prior state is generating "predicted" accelerations, even if not explicitly labeled as such in the code. The patent specification states the goal is to eliminate "undesirable external interferences," suggesting a functional rather than a strictly algorithmic definition (’846 Patent, col. 4:40-46).
- Evidence for a Narrower Interpretation: A defendant may argue the term requires the specific mathematical conversions shown in the specification (e.g., converting a quaternion into predicted accelerations using equations 2, 3, and 4) (’846 Patent, col. 17:1-21). Samsung's alleged use of "measured angular velocity and acceleration" (Compl. ¶103) could be argued to be a different, non-infringing method that does not involve this specific type of prediction.
The Term: "spatial reference frame"
Context and Importance: This term defines the coordinate system in which the patented orientation is calculated. The complaint alleges this term reads on Android's "global coordinate system" (Compl. ¶32), which is fixed relative to the Earth. The accuracy of this mapping will be important for infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this frame as being associated with the pointing device itself, defined by axes Xp, Yp, and Zp (’846 Patent, col. 2:49-53). This could be read broadly to cover any device-centric coordinate system.
- Evidence for a Narrower Interpretation: The patent consistently contrasts the "spatial pointer reference frame" with the "display frame" (’846 Patent, col. 2:45-58; Fig. 1). A defendant might argue that the term must be interpreted in the context of a 3D pointing device interacting with a separate 2D screen, and that this context limits its applicability to the internal workings of an integrated smartphone.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Samsung induces infringement by its customers. The basis for this allegation is that Samsung provides the Galaxy Phones and includes instructions (e.g., for using Google Maps) that direct users to operate the devices in an infringing manner (Compl. ¶¶60, 92, 99).
- Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. Plaintiff alleges Samsung has known of the patents since at least September 18, 2024, the date Samsung filed its own declaratory judgment action (Compl. ¶102). The complaint further alleges knowledge based on a prior lawsuit from a third party, CyWee Group, involving "related patents" (Compl. ¶108). Continued sales after these events are alleged to be willful and egregious (Compl. ¶¶105, 110-111).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of technical operation: Does Samsung’s proprietary sensor fusion code, which the complaint alleges replaced Google’s default library, actually perform the specific "predict-and-compare" methodology recited in the asserted claims? The outcome will depend on a factual analysis of Samsung's source code to resolve the conflict between Plaintiff's allegations and Samsung's quoted denials.
- The case will also turn on a key issue of claim construction: Can the term "predicted axial accelerations" be interpreted broadly to cover any predictive error-correction algorithm, or is it limited to the specific quaternion-based mathematical formulas disclosed in the patent's specification?
- Finally, a significant legal question will address willfulness: Does Samsung's act of filing a pre-emptive declaratory judgment action serve as undeniable proof of knowledge for a willfulness claim, or does it demonstrate a good-faith belief of non-infringement sufficient to defeat such a claim?