Cloud Controls LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Controls LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: WILLIAMS SIMONS & LANDIS PLLC
• Case Identification: 2:24-cv-00925, E.D. Tex., 11/13/2024
• Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign entity and for Samsung Electronics America, Inc. because it has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and other consumer electronics infringe five patents related to mobile device user interfaces, wireless connectivity management, predictive text input, and data serving.
• Technical Context: The technologies at issue concern fundamental user interaction and connectivity features that are core to the functionality and user experience of modern portable electronic devices.
• Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date	Event
2001-09-25	’703 Patent Priority Date
2004-04-27	’866 Patent Priority Date
2004-06-21	’003 Patent Priority Date
2007-01-08	’552 and ’087 Patents Priority Date
2007-01-23	’703 Patent Issue Date
2012-06-05	’087 Patent Issue Date
2012-06-12	’866 Patent Issue Date
2017-02-28	’003 Patent Issue Date
2018-07-17	’552 Patent Issue Date
2024-11-13	Complaint Filing Date

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

U.S. Patent No. 10,025,552 - "Selective Locking of Input Controls of a Portable Media Player," issued July 17, 2018

The Invention Explained

• Problem Addressed: The patent states that conventional locking mechanisms on portable media players are often too restrictive, preventing users from performing simple, desired actions like adjusting volume without fully unlocking the device, which can be cumbersome (’552 Patent, col. 1:32-42).
• The Patented Solution: The invention is a system that allows for the selective locking of input controls. A user can configure the device to operate in different "operational modes" (e.g., a "walking" mode or "traveling" mode), where in a locked state for a given mode, a pre-selected subset of controls remains active while others are disabled (’552 Patent, col. 4:16-29; Abstract). This allows, for example, volume buttons to function while the main touchscreen or track selection buttons are locked to prevent accidental input (’552 Patent, col. 2:24-34).
• Technical Importance: This technology aims to improve the usability of portable devices by balancing the need to prevent accidental inputs with the user's desire for quick access to essential controls.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶47).
• Essential elements of claim 1 include:
  • A "selection input" for configuring which controls remain enabled in a locked state for a specific "individual operational mode".
  • A "first control component" and a "second control component".
  • A "control selection component" (e.g., a lock switch) to switch between locked and unlocked states.
  • The system is configured such that in the locked state for a specific operational mode, the selected first component is active, but the unselected second component is not.
  • Crucially, the system is also configured such that in a locked state during a different operational mode, the first control component is also prevented from acting.
  • In the unlocked state, both components are active. (’552 Patent, col. 7:6 - col. 8:1).
• The complaint alleges infringement of "one or more claims," preserving the right to assert additional claims (Compl. ¶47).

U.S. Patent No. 8,195,087 - "Controlling of Wireless Connection of a Portable Device Including an Illuminating Component or Switch," issued June 5, 2012

The Invention Explained

• Problem Addressed: The patent notes that for many portable media players, wireless connectivity is not a primary feature, and users "may find it difficult to manage or properly utilize the wireless capabilities" of the device (Compl. ¶26; ’087 Patent, col. 1:32-35).
• The Patented Solution: The invention provides a dedicated physical "actuator" (e.g., a button) for initiating and controlling wireless connections. This actuator is linked to an "illumination component" that provides a visual indication of the connection's status (e.g., searching, connecting, downloading) through different "modes of illumination," such as varying colors or blinking patterns (’087 Patent, Abstract; col. 2:1-14).
• Technical Importance: This provides a simple, physical, one-touch interface and an intuitive, at-a-glance status indicator for a function that might otherwise require navigating complex software menus.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶59).
• Essential elements of claim 1 include:
  • An "actuator" located on the portable media player.
  • A "wireless connection component" that, upon detection of the actuator being selected, searches for and displays available wireless networks.
  • An "illumination component associated with the actuator" that is configured to "indicate a communications state" of the wireless connection via a "mode of illumination". (’087 Patent, col. 8:51-68).
• The complaint alleges infringement of "one or more claims," preserving the right to assert additional claims (Compl. ¶59).

U.S. Patent No. 9,585,003 - "Serving Data/Applications from a Wireless Mobile Phone," issued February 28, 2017

• Technology Synopsis: The patent addresses the challenge of a mobile phone, which typically lacks a persistent internet connection or static IP address, acting as a server. The invention describes a system using intermediary domain name and proxy servers that employ special logic to bridge this connectivity gap, enabling a remote client computer to locate and access data or applications hosted on the phone (Compl. ¶31; ’003 Patent, col. 3:20-31).
• Asserted Claims: Claim 1 (Compl. ¶71).
• Accused Features: The complaint accuses Samsung's smartphones and the Samsung Cloud service of infringing by enabling mobile devices to serve data to other computers (Compl. ¶71).

U.S. Patent No. 8,200,866 - "Reduced Keypad for a Mobile Communication Device for Predictive Input," issued June 12, 2012

• Technology Synopsis: The patent seeks to solve the difficulty of text entry on small devices by providing a non-conventional, reduced keypad layout. The key arrangement is specifically designed to "provide a reduced set of word collisions when using predictive input," thereby making text entry faster and more efficient than with standard keypad layouts (Compl. ¶35; ’866 Patent, col. 2:4-9).
• Asserted Claims: Claim 1 (Compl. ¶83).
• Accused Features: The complaint accuses Samsung mobile devices that utilize a "reduced keypad" in conjunction with a "predictive word generator" of infringement (Compl. ¶¶ 35, 92).

U.S. Patent No. 7,167,703 - "Wireless Mobile Image Messaging," issued January 23, 2007

• Technology Synopsis: To overcome the "limited input capabilities" of early mobile devices, this patent describes a system for non-verbal communication. It facilitates sending messages composed of pre-defined images organized into categories such as "location," "mood," or "activity," allowing users to convey information graphically and efficiently (Compl. ¶39; ’703 Patent, col. 2:3-9).
• Asserted Claims: Claim 10 (Compl. ¶95).
• Accused Features: The complaint accuses Samsung mobile devices of infringement for providing systems that send image messages between devices (Compl. ¶¶ 39, 104).

III. The Accused Instrumentality

Product Identification

• The complaint names a wide array of products, including dozens of models of "Samsung Galaxy" smartphones and tablets, "Samsung Sound Tower" audio devices, and the "Samsung Cloud" service (collectively, the "Accused Products") (Compl. ¶42).

Functionality and Market Context

• The complaint alleges that the Accused Products incorporate specific functionalities that map to the asserted patents. These allegedly include a "selective locking system" (’552 Patent), an "illumination component" indicating wireless connection state (’087 Patent), methods for "serving data or applications from mobile devices" (’003 Patent), a "reduced keypad and predictive word generator" (’866 Patent), and the ability to send "image messages from one mobile device to another" (’703 Patent) (Compl. ¶¶ 56, 68, 80, 92, 104).
• The complaint positions the Accused Products as part of Samsung's major consumer electronics business, which are marketed, sold, and distributed throughout the United States (Compl. ¶¶ 4, 5, 9).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference exemplary claim charts (Exhibits F-J) but does not include them in the body of the filing; therefore, a summary of the narrative infringement theory is provided in lieu of a chart (Compl. ¶¶ 48, 60, 72, 84, 96).

’552 Patent Infringement Allegations
The complaint alleges that the Accused Products directly, indirectly, and willfully infringe at least claim 1 of the ’552 Patent (Compl. ¶¶ 47, 55, 57). The theory of infringement is based on the Accused Products allegedly including a "selective locking system" which is described as a "special feature" constituting a material part of the invention with no substantial non-infringing uses (Compl. ¶56).

Identified Points of Contention (’552 Patent):

• Scope Questions: A primary question will be whether the accused locking features meet the claim requirement for configuration across multiple, distinct "individual operational modes". The claim requires that a control component enabled in one locked mode must be disabled in another locked mode, raising the question of whether the accused products support such granular, mode-dependent configurations (’552 Patent, col. 7:40-44).
• Technical Questions: What evidence demonstrates that the accused systems allow a user to make "individual selections" of which controls remain active, as required by the claim's "selection input" limitation, versus offering a static, pre-determined set of active controls when locked?

’087 Patent Infringement Allegations
The complaint alleges that the Accused Products directly, indirectly, and willfully infringe at least claim 1 of the ’087 Patent (Compl. ¶¶ 59, 67, 69). The infringement theory relies on the allegation that the Accused Products have "special features," specifically that an "illumination component indicates a communication state of the wireless connection," and that this feature is a material part of the patented invention (Compl. ¶68).

Identified Points of Contention (’087 Patent):

• Scope Questions: The analysis may focus on whether a general-purpose notification LED on a smartphone, which may be physically separate from any wireless control button, can be considered an "illumination component associated with the actuator" as claimed, or if the patent requires a more integrated physical unit.
• Technical Questions: What evidence shows the accused device's illumination provides distinct "modes of illumination" corresponding to different "communications states" (e.g., searching, connecting, transferring data), as taught by the patent and required by the claim, rather than a generic "blinking for activity" notification?

V. Key Claim Terms for Construction

Term (’552 Patent): "individual operational mode"

• Context and Importance: This term is critical for infringement of claim 1. The dispute may center on whether the accused devices support multiple, distinct locked states with different control permissions, or if they only have a single, universal locked state. Practitioners may focus on this term because it appears to require a level of user-configurability that may not be present in a standard device lock screen.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides examples such as "walking," "working out," and "traveling," which could suggest that any user-defined context or profile qualifies as an "individual operational mode" (’552 Patent, col. 4:26-29).
  • Evidence for a Narrower Interpretation: Claim 1 requires that a control component active in one locked mode is prevented from acting in another locked mode. This may support a narrower construction requiring formally defined and technically distinct modes, rather than simple preference sets (’552 Patent, col. 7:40-44).

Term (’087 Patent): "illumination component associated with the actuator"

• Context and Importance: The definition of this term will likely determine whether a standard notification LED falls within the scope of the claims. The degree of physical and functional linkage required by "associated with" will be a central question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not explicitly require the actuator (e.g., a button) to be the source of illumination, potentially allowing a physically separate but functionally linked LED to meet the limitation (’087 Patent, col. 8:64-65).
  • Evidence for a Narrower Interpretation: The specification describes placing the button on the top of the player's housing for easy viewing, which may imply a single, integrated component for both action and status indication, supporting a narrower reading that requires the actuator itself to be illuminated or have an immediately adjacent, dedicated light source (’087 Patent, col. 5:11-28).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all five patents-in-suit. The inducement allegations are based on Samsung's alleged provision of instructions and customer support encouraging infringing use (Compl. ¶¶ 51, 63, 75, 87, 99). The contributory infringement allegations assert that the accused products contain "special features" that are material to the inventions and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶¶ 56, 68, 80, 92, 104).
• Willful Infringement: Willfulness is alleged for all five patents. The complaint establishes a basis for post-suit willfulness by alleging knowledge "at least through the service of this Complaint" (e.g., Compl. ¶49). It further preserves the right to prove pre-suit willfulness by stating that "discovery may reveal earlier knowledge" of the patents (Compl. ¶44).

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

• A central issue will be one of definitional scope and claim construction: Can terms rooted in the context of earlier, simpler "portable media players" and mobile devices (e.g., "individual operational mode" in the ’552 patent, "image message system" in the ’703 patent) be construed to read on the features of modern, highly integrated smartphone operating systems, or will a court find a fundamental disconnect in technology and terminology?
• A key evidentiary question will be one of functional specificity: For the hardware-centric claims of the ’087 Patent (illuminated wireless button) and ’866 Patent (reduced predictive keypad), does the evidence show that Samsung's general-purpose notification LEDs and standard on-screen keyboards perform the specific, structured functions required by the claims, or is there a technical mismatch between the patented invention and the accused implementation?
• Finally, the case may turn on the question of materiality and apportionment: Given the vast number of features in the accused smartphones, a critical challenge for the Plaintiff will be to demonstrate that these specific, arguably incremental UI and connectivity features provide the inventive contribution claimed and to apportion their value from the overall value of the accused devices for the purpose of calculating damages.