DCT

2:24-cv-00910

Transparence LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00910, E.D. Tex., 11/11/2024
  • Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. based on its maintenance of established places of business and commission of infringing acts within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy phone and tablet products, featuring centralized application and notification management systems like Samsung Pass and Dex mode, infringe three patents related to cursor-based, persistent graphical user interfaces for managing multiple applications.
  • Technical Context: The technology at issue involves methods for centralizing the management of disparate computer applications, including their authentication and notifications, through a single, persistent graphical user interface that is accessible regardless of the user's immediate computing context.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent family because Defendant’s own patent applications and an issued patent cited publications from the asserted family during prosecution before the U.S. Patent and Trademark Office. These allegations form the basis for the claim of willful infringement.

Case Timeline

Date Event
2009-09-01 Earliest Priority Date for ’079, ’329, and ’580 Patents
2013-04-09 U.S. Patent No. 8,418,079 Issues
2016-01-12 U.S. Patent No. 9,235,329 Issues
2018-01-01 Approximate Start of Alleged Infringement Period (at least 2018)
2018-04-01 Alleged Notice: PTO cites Transparence application against Samsung
2018-09-01 Alleged Notice: Transparence patents/apps cited in Samsung prosecution
2020-04-01 Alleged Notice: Samsung's issued U.S. Patent No. 10,628,006 cites Transparence application
2024-04-16 U.S. Patent No. 11,960,580 Issues
2024-11-11 Complaint Filed

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

U.S. Patent No. 9,235,329 - "System and Method for Cursor-Based Application Management"

Issued January 12, 2016

The Invention Explained

  • Problem Addressed: The patent describes the management of multiple applications and their notifications as "arduous, problematic, and without centralization and convenience," requiring users to access each application individually to perform tasks like logging in or receiving updates (’329 Patent, col. 1:64-2:11).
  • The Patented Solution: The invention proposes a "single, unified, persistent user interface" that centralizes application management (’329 Patent, col. 1:66-2:1). This interface allows a multiplicity of applications to be "brought to the cursor' regardless of context or environment (i.e., in a browser, in an application, on a desktop, etc.)," providing a single point of control for authentication and notifications across different applications (’329 Patent, col. 3:13-17).
  • Technical Importance: The technology aimed to solve the growing problem of application fragmentation by providing a persistent, non-intrusive management layer accessible from the cursor, thereby reducing the steps needed for a user to manage their computing environment (Compl. ¶18).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶40).
  • Claim 1 is a computer-implemented method comprising the essential elements of:
    • Receiving an authentication requirement for multiple applications that provide messages.
    • Associating these authentication requirements with a single login credential.
    • Displaying a menu of the applications after receiving the single login credential.
    • Receiving a user input in the menu to specify which applications the user wants to receive notifications from.
    • Receiving a message from one of the specified applications.
    • Displaying a notification about the received message "regardless of a computer environment context."
  • The complaint reserves the right to assert additional claims (Compl. ¶41, n.1).

U.S. Patent No. 8,418,079 - "System and Method for Cursor-Based Application Management"

Issued April 9, 2013

The Invention Explained

  • Problem Addressed: The patent specification notes that conventional graphical user interfaces, such as right-click menus, are "context specific" and thus "not well suited for managing the computing environment as a whole" (’079 Patent, col. 1:41-2:2).
  • The Patented Solution: The invention discloses a cursor-based GUI that includes a "persistent application manager item" (’079 Patent, col. 2:45-47). This persistent item, unlike conventional contextual menu items, provides access to an application menu that remains constant regardless of the user's computing environment, allowing for centralized management, dynamic updates, and notifications for multiple applications (’079 Patent, col. 2:33-47, 2:58-61). The complaint includes a visual aid comparing a conventional context-specific menu with the invention's centralized, persistent GUI (Compl. ¶27, Fig. 1).
  • Technical Importance: This approach sought to transform the cursor environment from a set of disparate, context-sensitive tools into a centralized and persistent hub for managing a user's entire suite of applications (Compl. ¶16).

Key Claims at a Glance

  • The complaint asserts at least independent claim 11 (Compl. ¶60).
  • Claim 11 is a computer-implemented method comprising the essential elements of:
    • Receiving a user input.
    • Generating a GUI adjacent to a cursor in response to the input.
    • The GUI comprising one or more "persistent application management items that remain constant...regardless of the user's computer environment."
    • The items being configured to launch associated applications.
    • "Dynamically updating" the application items.
    • "Providing a notification to the user" when an item has been updated.
  • The complaint reserves the right to assert additional claims (Compl. ¶61, n.3).

U.S. Patent No. 11,960,580 - "System and Method for Cursor-Based Application Management"

Issued April 16, 2024

  • Technology Synopsis: The ’580 Patent discloses a system for a wireless device with a touch screen that manages authentication for multiple applications (’580 Patent, col. 13:26-30). It describes receiving different authentication requirements for a first and second application, associating them with a single "touch-based single manager login credential," and displaying an application menu that includes items for both applications along with a "new message indicator" adjacent to an application item (’580 Patent, col. 13:31-14:2).
  • Asserted Claims: Independent claim 1 (Compl. ¶77).
  • Accused Features: The complaint accuses Samsung Galaxy phones and tablets, which use Samsung Pass to manage credentials via biometrics or a PIN for various applications, of infringing by associating multiple authentication requirements with a single credential and displaying new message notifications in a centralized manner (Compl. ¶80, ¶87-91).

III. The Accused Instrumentality

Product Identification

The complaint names "all of Samsung's Galaxy phones and tablets" sold since at least 2018, with specific reference to the Galaxy S24 and devices operating in "Dex mode" (Compl. ¶28, ¶41, ¶53).

Functionality and Market Context

  • The complaint alleges that the Accused Products contain functionality for centrally managing applications and notifications. This includes the "Samsung Pass" feature, which allegedly uses a single credential (e.g., a fingerprint) to manage authentication for multiple applications like Facebook and Gmail (Compl. ¶44).
  • For the infringement allegations against the ’079 Patent, the complaint focuses on Samsung's "Dex mode." This feature is described as mirroring a smartphone's display on an external monitor to create a desktop-like environment, allegedly providing a persistent GUI that is generated adjacent to the cursor and operates independently of the active application (Compl. ¶53, ¶64-65).
  • The complaint notes that Samsung has promoted Dex mode for public safety and in-vehicle computing use cases, which it alleges trace back to the Plaintiff's original vision for the patented technology (Compl. ¶55-57).

IV. Analysis of Infringement Allegations

'329 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving an authentication requirement for a plurality of applications that provide messages The Accused Products receive authentication requirements for applications such as Facebook and Gmail. ¶43 col. 11:1-12
associating the authentication requirements for the plurality of applications...with a single login credential The Accused Products use Samsung Pass to associate these requirements with a single credential, such as the user's fingerprint. ¶44 col. 7:6-11
after receiving the single login credential, displaying a menu listing each of the plurality of applications... After receiving the fingerprint authentication, the Accused Products display a menu of the applications that provide messages. ¶45 col. 6:40-49
receiving, in the menu, an input from a user specifying one or more applications...the user wants to receive notifications... Through the application menu, a user can specify applications from which to receive notifications, such as Facebook or Gmail. ¶46 col. 9:50-59
receiving a message from an application specified in the menu The Accused Products receive messages from applications specified in the menu, such as Gmail and Facebook Messenger. ¶47 col. 8:1-21
displaying, regardless of a computer environment context, a notification indicating a message was received... The Accused Products display a notification indicating a message was received, regardless of how the user is using the device. ¶48 col. 3:13-17

Identified Points of Contention:

  • Scope Questions: A potential dispute may arise over the claim term "regardless of a computer environment context." A court may need to determine if a centralized notification system on a modern mobile operating system, which itself could be considered a single "environment," meets this limitation as described in the patent, which provides examples like a browser, desktop, or application.
  • Technical Questions: The complaint alleges that a user "can provide an input specifying" which applications send notifications. The case may require evidence on whether this user configuration process in the accused devices maps onto the specific "receiving, in the menu, an input" step as required by the claim.

'079 Patent Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving an input from a user In Dex Mode, the Accused Products receive a user input, such as a double-click. ¶63 col. 4:50-54
generating a graphical user interface adjacent to a cursor in response to the input received In Dex Mode, a GUI is generated adjacent to the computer cursor in response to the user's input. ¶64 col. 2:38-42
wherein the graphical user interface comprises one or more persistent application management items that remain constant...regardless of the user's computer environment The GUI in Dex Mode allegedly contains application management items that remain constant and can be accessed regardless of the currently used application. ¶65 col. 2:65-3:2
wherein the application management items are configured for launching one or more applications... The items are configured to launch various Google, Microsoft, and Samsung applications. ¶66 col. 6:1-15
dynamically updating the one or more application items The Accused Products allegedly have a setting available for automatically updating the applications displayed on the persistent GUI. ¶68 col. 2:58-61
providing a notification to the user when the one or more application items have been updated In Dex Mode, the Accused Products allegedly notify the user when an application displayed on the GUI has been updated. ¶69 col. 14:3-6

Identified Points of Contention:

  • Scope Questions: The interpretation of "persistent application management items" will be critical. The complaint's visual evidence illustrates a dedicated "MANAGER" item (Compl. ¶27, Fig. 1), and a court may have to decide if the accused collection of application icons in Dex mode meets that definition.
  • Technical Questions: The complaint alleges a "setting available for automatically updating" the applications. A key question for the court will be whether the availability of a setting satisfies the active method step of "dynamically updating" an item, or if this allegation points more toward indirect infringement.

V. Key Claim Terms for Construction

  • Term: "regardless of a computer environment context" ('329 Patent, Claim 1)

    • Context and Importance: This term is central to the patent's promise of a "persistent" and "unified" interface. Its construction will determine whether the invention applies broadly to any system that provides notifications outside of the source application, or if it is limited to the specific desktop, browser, and application environments discussed in the specification.
    • Intrinsic Evidence for a Broader Interpretation: The specification states that applications can be "'brought to the cursor' regardless of context or environment (i.e., in a browser, in an application, on a desktop, etc.)" ('329 Patent, col. 3:13-17). This parenthetical list may support an interpretation that "context" refers to the foreground application, which would favor the plaintiff's theory.
    • Intrinsic Evidence for a Narrower Interpretation: A defendant may argue that the patent’s examples are all rooted in a traditional personal computer paradigm. This could support an argument that the term does not readily apply to the integrated nature of a mobile operating system, which could be viewed as a single, unified "computer environment."

  • Term: "persistent application management items" ('079 Patent, Claim 11)

    • Context and Importance: This term defines the core component of the claimed GUI. Practitioners may focus on this term because its construction will determine whether a simple, persistent collection of application launch icons infringes, or if the claim requires a more specialized "management" tool as depicted in the patent's figures.
    • Intrinsic Evidence for a Broader Interpretation: The claim language requires items that "remain constant" and are "configured for launching" applications, which could be interpreted to read on any stable group of application icons in a menu (’079 Patent, col. 14:1-3).
    • Intrinsic Evidence for a Narrower Interpretation: The specification describes a "persistent application manager item to access an application menu" (’079 Patent, col. 2:45-47) and depicts a specific "MANAGER" menu item that opens a submenu with further options (e.g., ’079 Patent, Fig. 5). This could support a narrower construction requiring a dedicated management-focused element.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by its customers and end users. This is based on allegations that Defendant provides instructions, such as user manuals and promotional materials, that advise and direct users to operate the Accused Products in a manner that allegedly performs the steps of the asserted claims (Compl. ¶50, ¶72, ¶94).
  • Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit conduct. The claim for pre-suit willfulness is grounded in allegations that Defendant gained actual knowledge of the asserted patent family as early as April 2018, when the U.S. Patent and Trademark Office allegedly cited Plaintiff's patent application during the prosecution of Defendant's own application, and through subsequent citations in other related prosecution histories (Compl. ¶98-101). Post-suit willfulness is based on notice provided by the filing of the complaint itself (Compl. ¶102).

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

  • A core issue will be one of definitional scope: can the term "regardless of a computer environment context," rooted in patent examples of distinct desktop and browser environments, be construed to cover the integrated notification system of a modern mobile operating system where the lines between application, OS, and desktop are blurred?
  • A key evidentiary question will be one of technical mapping: does Samsung’s "Dex mode" feature, which provides a desktop-like interface, actually generate a GUI with "persistent application management items" that "remain constant" in the specific manner required by the '079 patent's claims, or will evidence reveal a fundamental mismatch in technical operation?
  • A central question for the willfulness claim will be whether constructive or actual knowledge can be established through citations made by a patent examiner during the prosecution of Defendant's own, separate patent applications. The court will need to determine if such prosecution history events are sufficient to demonstrate that the Defendant "knew or should have known" that its actions constituted an unjustifiably high risk of infringement.