DCT
2:24-cv-00920
Wave Sense LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wave Sense, LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Skiermont Derby LLP
- Case Identification: 2:24-cv-00920, E.D. Tex., 11/12/2024
- Venue Allegations: Venue is alleged against Samsung America based on its "regular and established places of business" in the district, specifically in Plano, Texas. Venue is alleged against Samsung Electronics as a foreign entity subject to personal jurisdiction in the district.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones and tablets infringe a patent related to digital signal processing methods for identifying motion signatures from sensor data.
- Technical Context: The technology concerns methods for analyzing data from sensors like accelerometers to recognize and classify specific physical motions, a foundational technology for gesture controls in modern consumer electronics.
- Key Procedural History: The complaint notes the patented invention originated from academic research at the Technical University of Crete between 2000 and 2004, including experiments involving a physically disabled person, which led to the realization that the technology could be applied to the video gaming industry. No prior litigation or licensing history is mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-01 | Start of academic work leading to the invention |
| 2004-11-05 | '819 Patent Priority Date |
| 2009-09-01 | '819 Patent Issue Date |
| 2024-11-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,583,819, “Digital Signal Processing Methods, Systems and Computer Program Products that Identify Threshold Positions and Values,” Issued September 1, 2009
The Invention Explained
- Problem Addressed: The patent addresses the general need to create a "signature or characteristic" from a digital signal, such as an acceleration signal generated by physical motion, to allow for the signal to be identified and classified (ʼ819 Patent, col. 1:25-39).
- The Patented Solution: The invention proposes a method to convert a raw signal into a simplified, structured signature. The process involves sampling the signal, dividing the samples into discrete "windows," and then classifying each window as "relatively constant, incremental or decremental" to create a new data structure called an "approximation vector." (’819 Patent, Abstract). Key inflection points, or "thresholds," are identified within this vector, and specific values are assigned to them, resulting in a final signature that can be used to characterize the original motion (ʼ819 Patent, col. 1:40-57; Fig. 1).
- Technical Importance: This method provides a systematic way to abstract complex, continuous motion data into a simplified, machine-readable format, enabling devices to recognize specific gestures or movements without traditional inputs (ʼ819 Patent, col. 1:34-39).
Key Claims at a Glance
- The complaint asserts independent claim 23 (Compl. ¶25).
- The essential elements of independent claim 23 are:
- A motion detection system comprising a motion sensor and a digital signal processor.
- The motion sensor is configured to generate an acceleration signal.
- The digital signal processor is configured to:
- sample the acceleration signal and divide the samples into windows;
- associate one of at least three values (e.g., constant, incremental, decremental) with each window to generate an "approximation vector";
- determine locations of thresholds in the "approximation vector" to generate a "threshold position vector"; and
- assign threshold values to the positions in the "threshold position vector" to generate a "set of threshold values".
- The complaint reserves the right to assert additional claims (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The Accused Products are Samsung's "smartphones and tablets," with the Samsung Galaxy S8 identified as an "exemplary Accused Product." A non-limiting list includes various models from the Galaxy S7 to the Galaxy S21 series and the Galaxy Fold (Compl. ¶21, ¶26, ¶27 fn. 1).
Functionality and Market Context
- The complaint alleges the Accused Products contain an STMicroelectronics inertial sensor module (e.g., the LSM6DSL), which includes an accelerometer for detecting motion (Compl. ¶27). This module is accused of implementing motion detection features like "single-tap and double-tap recognition" and "relative tilt" detection (Compl. ¶29-30, ¶33). These features are allegedly enabled by the module's "digital Slope filter," which processes the acceleration signal to identify specific motion events (Compl. ¶31, ¶35). The complaint provides a screenshot from a Samsung product specification sheet listing the "Accelerometer" as one of the Galaxy S8's sensors (Compl. ¶27).
IV. Analysis of Infringement Allegations
’819 Patent Infringement Allegations
| Claim Element (from Independent Claim 23) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a motion sensor that is configured to generate an acceleration signal in response to motion thereof; | The Accused Products contain an STMicroelectronics inertial sensor module, which includes an accelerometer capable of generating an acceleration signal. | ¶27-28 | col. 2:65-67 |
| a digital signal processor that is configured to: | The STMicroelectronics module itself is alleged to operate as a digital signal processor. | ¶31 | col. 2:67-3:2 |
| sample the acceleration signal and divide the samples into windows; | The STMicro Module allegedly samples the acceleration signal and divides it into "windows" of two consecutive samples when applying its slope filter. A complaint visual shows these windows as purple boxes overlaid on an acceleration signal graph (Compl. ¶32, ¶33). | ¶32-33 | col. 1:41-42 |
| associate one of at least three values with a respective window based upon whether the samples in the window are relatively constant, incremental, or decremental, to thereby generate an approximation vector; | The complaint alleges that the module's calculation of a "slope" between consecutive samples determines if the trend is incremental, decremental, or constant, and that the resulting "slope graph" constitutes the claimed approximation vector. | ¶34, ¶36 | col. 1:43-48 |
| determine locations of thresholds in the approximation vector to generate a threshold position vector that indicates the locations of thresholds...; | The module is alleged to determine threshold locations within the slope graph (the alleged approximation vector) to detect events like a double-tap. A complaint visual illustrates this by showing "Tap Threshold" lines on a slope graph (Compl. ¶37). | ¶37 | col. 1:48-52 |
| assign threshold values to the threshold positions in the threshold position vector to thereby generate a set of threshold values. | The module allegedly assigns a specific "tap threshold" value, which can be set in a register, to the identified threshold positions. A complaint visual displays a settings table from a technical document showing the "tap threshold" setting (Compl. ¶38). | ¶38 | col. 1:52-55 |
Identified Points of Contention
- Scope Questions: A primary question will be whether the accused module's calculation of a "slope" value (e.g.,
[acc(tn) - acc(tn-1)]/2) meets the claim limitation of associating one of "at least three values" (constant, incremental, decremental) to generate an "approximation vector". The defense may argue that a continuous slope value is fundamentally different from the patent's teaching of a symbolic vector with discrete states (e.g., +1, 0, -1). - Technical Questions: The case may turn on whether the complaint's mapping of claim terms onto the functionality of the STMicro module is technically and legally sound. It raises the question of whether the accused system performs the discrete logical steps recited in the patent (e.g., creating distinct "approximation" and "threshold position" vectors) or if it performs a more integrated, single-step process of calculating a slope and comparing it to a pre-set value.
V. Key Claim Terms for Construction
The Term: "approximation vector"
- Context and Importance: This term is central to the claimed invention and the infringement theory. The plaintiff's case appears to depend on construing the series of "slope" values calculated by the accused chip as the claimed "approximation vector". Its definition will likely determine whether the accused functionality falls within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines the term by its function: "to thereby generate an approximation (or motion) vector" based on whether samples are "relatively constant, incremental or decremental" (’819 Patent, col. 1:43-48). This functional language may support a construction that is not limited to a specific data format.
- Evidence for a Narrower Interpretation: Figure 2 of the patent explicitly illustrates the "approximation vector" as a sequence of discrete integer values: {0, 0, 0, -1, 0, +1, +1, 0, -1, ...}. This embodiment may support a narrower construction limited to a vector of symbolic, quantized states rather than a series of continuous calculated values (’819 Patent, Fig. 2).
The Term: "window"
- Context and Importance: The complaint alleges a "window" consists of "two consecutive acceleration samples" (Compl. ¶33), which is the basis for the slope calculation. The patent, however, discloses an embodiment where windows contain "40 samples" (’819 Patent, col. 9:37-38). This discrepancy raises a question about the required size and nature of a "window".
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify a size for the "window", which may support a construction that encompasses any grouping of two or more samples.
- Evidence for a Narrower Interpretation: The defense may argue that a "window" must be large enough to meaningfully determine if the samples within it are "relatively constant, incremental or decremental," as required by the claim, and that two samples are insufficient to establish such a trend, pointing to the 40-sample embodiment as context for the term's meaning.
VI. Other Allegations
Indirect Infringement
- The complaint makes a conclusory allegation that Samsung "actively induces its customers" to use the infringing products (Compl. ¶10). It does not, however, plead specific facts to support the knowledge and intent elements of inducement, such as referencing user manuals that instruct on the use of the accused motion-detection features.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "approximation vector", which the patent illustrates as a vector of discrete symbolic states {+1, 0, -1}, be construed to read on the series of continuous "slope" values calculated by the accused processor?
- A key evidentiary question will be one of technical mapping: does the plaintiff's evidence, based on publicly available datasheets, demonstrate that the accused chip performs the specific, multi-step logical process recited in Claim 23 (e.g., creating a distinct vector, then determining threshold locations within it), or does it show a fundamentally different technical operation (e.g., a single-step slope calculation and comparison) onto which the claim language has been mapped?