DCT
2:24-cv-00901
GenghisComm Holdings LLC v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GenghisComm Holdings, LLC (Colorado)
- Defendant: Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Global IP Law Group, LLC
- Case Identification: 2:24-cv-00901, E.D. Tex., 11/05/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has committed acts of infringement and maintains a regular and established place of business in the district, specifically citing facilities in Plano, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s 5G cellular base station receivers infringe a patent related to methods for receiving and decoding pre-coded Orthogonal Frequency Division Multiplexing (OFDM) signals.
- Technical Context: The technology concerns advanced signal processing techniques for wireless communications, specifically methods for decoding complex uplink signals in cellular networks like 5G to improve efficiency and performance.
- Key Procedural History: The complaint notes the patent-in-suit descends from a family of applications with a priority date tracing back to 2004. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2004-08-02 | ’386 Patent Earliest Priority Date |
| 2022-08-30 | ’386 Patent Issue Date |
| 2024-11-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,431,386 - "Transmit Pre-Coding"
Issued August 30, 2022.
The Invention Explained
- Problem Addressed: The patent's background section describes inefficiencies in conventional wireless networks, such as base-station bottlenecks in cellular systems and performance degradation in peer-to-peer networks. It also notes the general impracticality of implementing complex antenna arrays on mobile terminals due to power, cost, and size constraints (’386 Patent, col. 2:7-39).
- The Patented Solution: The invention describes a receiving apparatus (such as a base station) that decodes an OFDM signal transmitted by a user device. The core of the solution lies in a specific decoding process that employs codes designed to be the "inverse to, complex-conjugate of, or complementary to" a set of codes used by the transmitter (’386 Patent, Abstract). This specialized coding at the transmitter shapes the signal into a "superposition of cyclic-shifted pulse waveforms," an approach that allows for sophisticated signal processing to be handled primarily at the receiver, potentially reducing the complexity required of the user device (’386 Patent, col. 74:6-14; Abstract).
- Technical Importance: This technical approach allows for the use of advanced uplink signal transmission techniques that can enhance data rates and reliability, while shifting the implementation complexity from resource-constrained mobile devices to more powerful network infrastructure like base stations (’386 Patent, col. 2:35-39; col. 49:25-30).
Key Claims at a Glance
- The complaint asserts independent claim 10.
- The essential elements of independent claim 10 are:
- An apparatus for receiving an OFDM signal from a user device, comprising a processor and memory.
- The memory includes instructions for:
- Determining the subcarrier frequencies allocated to the user device.
- Converting the received OFDM signal into frequency-domain values.
- Decoding these values to recover data symbols.
- The decoding process must employ a plurality of codes that are "inverse to, complex-conjugate of, or complementary to" a set of complex-valued codes that the user device employs to shape the signal into a "superposition of cyclic-shifted pulse waveforms."
- The complaint also asserts dependent claims 15 and 17 (Compl. ¶¶38, 45).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Accused Samsung 5G Receivers," with a specific example being the Samsung CDU50 Baseband Unit (Compl. ¶23).
Functionality and Market Context
The accused products are hardware components used in 5G cellular network base stations (e.g., gNodeB) for receiving and processing uplink radio signals from user equipment (Compl. ¶¶23, 26). The complaint alleges that the functionality of these products is dictated by their compliance with 5G cellular standards, particularly the 3GPP TS 38.211 specification (Compl. ¶26). The infringement theory is based on the allegation that these receivers are designed to process DFT-spread-OFDM (DFT-s-OFDM) signals in the uplink, and that the Samsung CDU50 baseband unit contains a Samsung S8600 system-on-a-chip (SoC) for this purpose (Compl. ¶¶28, 29).
IV. Analysis of Infringement Allegations
’386 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus for receiving an Orthogonal Frequency Division Multiplexing (OFDM) signal transmitted by a user device in a wireless network... | The Accused Samsung 5G Receivers are designed for 5G networks to receive uplink OFDM signals from user equipment. | ¶28 | col. 75:6-10 |
| at least one processor; and a non-transitory computer-readable memory... | The Accused Samsung 5G Receivers, such as the Samsung CDU50, include a processing system (e.g., Samsung S8600 SoC) and associated memory for storing and executing instructions. | ¶29 | col. 73:50-54 |
| determining a plurality of subcarrier frequencies allocated to the user device; | The Accused Samsung 5G Receivers must determine the subcarrier frequencies and spacings for each user device as defined in the 5G specification in order to process the received signal. | ¶30 | col. 73:55-57 |
| converting the OFDM signal to a plurality of frequency-domain values corresponding to the plurality of subcarrier frequencies; | To process the uplink signal, the Accused Samsung 5G Receivers must convert the time-domain signal into a frequency-domain signal, allegedly using an inverse of the N-point DFT used by the user equipment to generate the signal. | ¶31 | col. 73:58-60 |
| decoding the plurality of frequency-domain values to recover a plurality of data symbols encoded by the user device... | The Accused Samsung 5G Receivers must decode transform precoded data by using an inverse of the M-point DFT that the user equipment employed to encode the data symbols. | ¶32 | col. 73:61-64 |
| wherein decoding employs a plurality of codes that are inverse to, complex-conjugate of, or complementary to a set of complex-valued codes that the user device employs to shape the OFDM signal into a superposition of cyclic-shifted pulse waveforms... | The decoding process allegedly uses an inverse DFT that is the complex-conjugate of the DFT used for precoding. This precoding DFT includes an exponential term that imparts a cyclic shift, creating the claimed waveform structure. | ¶¶33, 34 | col. 73:65-74:14 |
The complaint provides an annotated diagram from the 3GPP 5G Specification highlighting the exponential term in the transform precoding formula, which it alleges corresponds to the claimed complex-valued codes (Compl. p. 11).
Identified Points of Contention
- Scope Questions: The case appears to hinge on a standards-based infringement theory. A primary question will be whether the phrase "superposition of cyclic-shifted pulse waveforms," rooted in the patent's description of Carrier Interferometry, can be construed to read on the signal structure created by the DFT-s-OFDM process as defined in the 3GPP 5G standard.
- Technical Questions: A key technical question is whether compliance with the cited 5G standard necessarily results in an apparatus that practices every limitation of Claim 10. The infringement allegation rests on the argument that the standard dictates the infringing functionality. The court may need to consider whether the standard allows for non-infringing implementation alternatives or if there is a technical distinction between the signal processing described in the patent and the operation specified by the 3GPP standard.
V. Key Claim Terms for Construction
Term for Construction: "a superposition of cyclic-shifted pulse waveforms"
- Context and Importance: This phrase from element F of claim 10 defines the specific structure of the signal created by the user device. The infringement case depends on demonstrating that the signal resulting from the 5G standard's DFT-s-OFDM precoding method falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification discusses a variety of signal processing techniques, and a party might argue the term is a general descriptor for any signal generated by applying phase shifts to a set of carriers to create time-domain offsets ('386 Patent, col. 42:25-30).
- Evidence for a Narrower Interpretation: The patent’s figures and detailed description of Carrier Interferometry (CI) embodiments depict distinct, discrete pulses created by specific phase relationships ('386 Patent, Figs. 17A, 22A, 29A). A party could argue the term is limited to these specific CI-based embodiments and does not cover the continuous signal structure produced by the 5G standard's transform precoding.
Term for Construction: "codes that are inverse to, complex-conjugate of, or complementary to"
- Context and Importance: This phrase, also from element F, defines the required mathematical relationship between the codes used by the transmitter and the codes used by the receiver for decoding. Plaintiff's infringement theory relies on the receiver's inverse DFT being a "complex-conjugate" of the transmitter's DFT (Compl. ¶33).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "or" to connect the three terms suggests they are alternatives covering a range of reciprocal mathematical operations used in digital signal processing. A party could argue it is meant to broadly capture any matched encoding/decoding scheme.
- Evidence for a Narrower Interpretation: A party may argue these terms have precise technical meanings defined by the patent's specific embodiments, particularly in the context of Carrier Interferometry. The argument would be that the general mathematical relationship in a standard DFT/IDFT pair does not necessarily meet the specific definition of "inverse," "complex-conjugate," or "complementary" as used and intended by the inventor in the context of the patent as a whole.
VI. Other Allegations
Willful Infringement
The complaint alleges that Samsung has known of its infringement and asks the court to declare the infringement willful (Compl. ¶36; Prayer for Relief ¶C). The complaint does not allege any pre-suit notice, suggesting the claim for willfulness is based on Defendant's continuation of allegedly infringing activities after the filing of the lawsuit.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the court’s determination of two central questions:
- A core issue will be one of standards-essential infringement: Does compliance with the cited 3GPP 5G standard for uplink communications (specifically, implementing DFT-s-OFDM) necessarily and without exception result in a base station receiver that practices every limitation of the asserted claims, or does the standard permit non-infringing design choices?
- A key evidentiary question will turn on claim construction: Can the patent's term "superposition of cyclic-shifted pulse waveforms," which arises from a specification focused on Carrier Interferometry (CI), be construed broadly enough to cover the signal structure created by the transform precoding process defined in the 5G standard, or is there a fundamental mismatch in the underlying technologies?