DCT

2:25-cv-00246

Softview LLC v. Samsung Electronics Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00246, E.D. Tex., 02/28/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. (SEA) maintains an established place of business in Plano, Texas, and has committed acts of infringement in the District. Venue over Samsung Electronics Co., Ltd. (SEC) is alleged to be proper in any district as it is a foreign entity.
  • Core Dispute: Plaintiff alleges that Defendants’ smartphones and tablets, which include the Samsung Internet and Google Chrome web browsers, infringe five patents related to the scalable, resolution-independent display of web content on mobile devices.
  • Technical Context: The patents address the challenge of rendering web pages designed for large desktop monitors on the smaller, varied screens of mobile devices while preserving the original layout and functionality.
  • Key Procedural History: The complaint details extensive prior litigation involving some of the asserted patents’ family members, including a 2010 lawsuit filed against Apple and others, which was later split into separate cases against Android device manufacturers, including Samsung. That litigation involved U.S. Patent No. 7,461,353, which is also asserted here. During that litigation, certain claims of the '353 patent were invalidated in an Inter Partes Review (IPR). The complaint notes that the prior litigation against Samsung was dismissed without prejudice as to all but 20 previously asserted claims, which may be relevant to preclusion doctrines.

Case Timeline

Date Event
2000-06-12 Patent Priority Date (’729, ’889, ’154, ’628, '353 Patents)
2008-12-02 U.S. Patent No. 7,461,353 Issues
2010-05-10 SoftView files prior litigation involving the '353 Patent
2010-11-30 U.S. Patent No. 7,844,889 Issues
2011-09-30 Samsung added as a defendant to prior litigation
2012-01-01 Accused Products sold by Samsung "since at least 2012"
2012-07-26 Prior litigation split into separate cases, including against Samsung
2013-09-10 U.S. Patent No. 8,533,628 Issues
2015-10-29 Prior litigation against Samsung dismissed
2016-12-13 U.S. Patent No. 9,519,729 Issues
2018-09-25 U.S. Patent No. 10,083,154 Issues
2025-02-28 Complaint Filing Date

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

U.S. Patent No. 9,519,729 - "Scalable Display of Internet Content on Mobile Devices"

The Invention Explained

  • Problem Addressed: The patent family addresses the technical problem of displaying internet content designed for fixed-resolution desktop computers on mobile devices with smaller screens, lower resolutions, and different aspect ratios without degrading the user experience (Compl. ¶59-60). Early approaches either stripped content, reformatted layouts in unfamiliar ways, or required cumbersome scrolling (Compl. ¶26-28).
  • The Patented Solution: The invention processes HTML and CSS content on a mobile device to generate a "scalable vector representation" of the web page. This representation allows the user to zoom in and out while preserving the original page layout, functionality, and design as seen on a desktop browser. A key feature is the ability to re-render the page in response to a user tap on a column, causing that column to fit the width of the device's display area for readability (’353 Patent, Abstract; Compl. ¶61). Figure 5 of the patent family illustrates the process of parsing content, defining objects and bounding boxes, and generating vectors to create this scalable representation (Compl. ¶40, p. 15).
  • Technical Importance: This approach allowed billions of existing web pages, which were designed for fixed desktop resolutions, to be effectively browsed on the emerging class of handheld devices without requiring web developers to create separate mobile-specific versions of their sites (Compl. ¶43, 69).

Key Claims at a Glance

  • The complaint asserts dependent Claim 21, which incorporates independent Claim 14 (Compl. ¶57, 61).
  • The essential elements of Claim 14 comprise:
    • Requesting a multi-column, HTML- and CSS-based Web page through a mobile device with a touch-sensitive display.
    • Retrieving and processing the content at the mobile device to generate a scalable vector representation of the Web page.
    • Rendering a first view at a first zoom level that preserves the original desktop page layout.
    • Re-rendering views in response to user inputs to zoom, while still preserving the original page layout.
    • In response to a tap on a column, re-rendering the Web page so the tapped column fits the display width.
  • The essential additional elements of Claim 21 comprise processing the HTML content by:
    • Parsing the HTML code to determine the original page layout.
    • Logically grouping content into objects.
    • Defining a primary datum corresponding to the original page layout.
    • For each object, defining an object datum corresponding to its layout location.
    • Generating a vector from the primary datum to the object datum for each object.

U.S. Patent No. 7,844,889 - "Resolution Independent Display of Internet Content"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problem as the ’729 Patent: the unsatisfactory experience of viewing fixed-resolution desktop web content on small-screen mobile devices (Compl. ¶142-143).
  • The Patented Solution: The invention describes a method where a wireless hand-held device retrieves markup language-based web content and uses a rendering engine to generate "scalable page layout information." This information is then used to generate views of the web page, including an initial view where the full width of the page is displayed. The user can then iteratively zoom in on portions of the page while preserving the original layout, design, and critically, hyperlink functionality (’889 Patent, Abstract; Compl. ¶144). The process involves parsing the content to define layout locations for various objects (text, images) and defining an "object datum" for each, allowing for a vectorized representation (Compl. ¶146).
  • Technical Importance: This technology was aimed at making mobile web browsing a viable alternative to desktop browsing by maintaining the "look and feel" and interactive functionality (like hyperlinks) of the original page, which prior adaptation methods failed to do (Compl. ¶150).

Key Claims at a Glance

  • The complaint asserts dependent Claim 5, which incorporates independent Claim 1 (Compl. ¶140, 144).
  • The essential elements of Claim 1 comprise:
    • Retrieving markup language-based Web content (including text, hyperlinks, and images) on a wireless hand-held device.
    • Processing the content with a rendering engine to generate page layout information.
    • Employing the page layout information to generate scalable page layout information.
    • Employing the scalable information to generate views, including a full-width view and iteratively zoomed-in views that preserve the original layout, functionality, and hyperlink functionality.
  • The essential additional elements of Claim 5 comprise:
    • Parsing markup language with the rendering engine to determine the original page layout, which defines a layout location for a plurality of text and image objects.
    • For each object, defining an object datum corresponding to its layout location.
    • Associating the object with its object datum.

U.S. Patent No. 10,083,154 - "Scalable Display of Internet Content on Mobile Devices"

  • Technology Synopsis: This patent claims a method for displaying an HTML document on a mobile device by translating it into a scalable vector representation. The method involves generating page layout information, including bounding boxes for HTML objects, and defining a "primary datum" and an "object datum" for each object to generate vectors. The invention allows rendering at a first zoom level that fits the display width, and at user-defined zoom levels thereafter, while preserving the page layout (Compl. ¶211-214).
  • Asserted Claims: Independent Claim 13 (Compl. ¶207, 211).
  • Accused Features: The Samsung Internet and Chrome browsers, along with the Gmail application, are accused of performing the claimed method by using the Blink rendering engine, the Skia graphics library, and related Android components to receive, parse, translate, and render HTML documents in a scalable, zoomable manner that preserves layout (Compl. ¶222, 245, 269).

U.S. Patent No. 8,533,628 - "Method, Apparatus, and Browser to Support Full-Page Web Browsing on Hand-Held Wireless Devices"

  • Technology Synopsis: This patent describes a method for replicating the desktop browsing experience on a hand-held wireless device. The method involves processing HTML and CSS content to generate scaled web page content at multiple scale factors. A specific feature claimed is enabling a user to zoom in on an image by scaling the image's bounding box to produce a scaled image that fits within the corresponding scaled bounding box. The method requires that the mobile and desktop browsers use the same rendering engine (Compl. ¶291, 293).
  • Asserted Claims: Dependent Claim 2, which incorporates independent Claim 1 (Compl. ¶286, 291).
  • Accused Features: The Samsung Internet and Chrome browsers are accused of using the Blink rendering engine on both mobile and desktop, thereby meeting the "same rendering engine" requirement. The browsers are further accused of employing a vector-based rendering engine (Skia) to effect scaling of display content, including zooming in on images within scaled bounding boxes (Compl. ¶332-334).

U.S. Patent No. 7,461,353 - "Scalable Display of Internet Content on Mobile Devices"

  • Technology Synopsis: This patent claims a method of translating HTML-based web content into "scalable content" that supports a resolution-independent representation preserving the original page layout. The method involves rendering the web page using a first scale factor and enabling it to be re-rendered at a different resolution using a second scale factor, while preserving the original layout, functionality, and design at both scales (Compl. ¶357-358).
  • Asserted Claims: Independent Claim 209 (Compl. ¶353, 357).
  • Accused Features: The Samsung Internet and Chrome browsers, through their use of the WebKit/Blink rendering engine and Skia graphics library, are accused of translating HTML content into a scalable representation. This representation is alleged to be rendered at different scale factors (zoom levels) while preserving the original page layout (Compl. ¶372-374, 396).

III. The Accused Instrumentality

Product Identification

  • All Samsung smartphones and tablets sold since at least 2012 that include either the Samsung Internet browser application or the Android Chrome Web browser (collectively, "Accused Products") (Compl. ¶49-50).

Functionality and Market Context

  • The complaint alleges that the accused browsers employ the WebKit rendering engine, or its "Blink" fork, which are HTML- and CSS-compliant engines that interpret web page code to render the page's layout and design (Compl. ¶49, 51). The Android operating system on the Accused Products uses a class called "WebView" to render HTML documents, which in turn utilizes the Blink engine (Compl. ¶52).
  • The core of the infringement allegations centers on the browsers' use of the Skia 2D graphics library to "paint" or "rasterize" display content (Compl. ¶53-54). The complaint alleges this system creates a scalable vector representation of the entire web page, allowing for real-time zooming and panning that preserves the original layout by recording painting instructions in a "display list" and then applying scaling and translation parameters via a transformation matrix (Compl. ¶84, 86). A screenshot provided in the complaint shows a high-level architecture diagram of the accused WebView functionality (Compl. ¶52, p. 22).

IV. Analysis of Infringement Allegations

'729 Patent Infringement Allegations

Claim Element (from Independent Claim 14 and Dependent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
From Claim 14: ...requesting through a mobile device having a touch-sensitive display a Web page comprising HTML-based Web content including HTML code for at least multiple columns and Cascading Style Sheets (CSS) content; The Accused Products are mobile devices with touch-sensitive displays that enable users to request multi-column, CSS-styled web pages via the accused browsers. The complaint provides screenshots showing a user requesting a webpage through the Chrome browser. ¶74-78, p. 29 col. 2:4-10
From Claim 14: retrieving and processing the HTML-based Web content... at the mobile device to generate a scalable vector representation of the Web page; The accused browsers allegedly use the Skia 2D vector graphics library to create a "vector representation" of the page. This is accomplished by recording painting instructions in a "display list," which functions as a scalable representation. ¶82-87 col. 15:43-16:7
From Claim 14: rendering the Web page... to produce a first view... that preserves the original page layout... and re-rendering the Web page... to iteratively zoom... while preserving the original page layout... The accused browsers allegedly allow users to zoom in and out of a web page while preserving the original layout, as shown in screenshots of a browser at different zoom levels. ¶92-93, p. 41 col. 2:54-56
From Claim 14: in response to a tap on a first of the multiple columns... re-rendering the Web page... such that the first of the multiple columns is displayed to fit a width of a display area... The accused browsers allegedly perform this function via a "double-tap" gesture on a column, which causes the column to be re-rendered to fit the screen width, as shown in screenshots. ¶94-95, p. 42 col. 24:1-15
From Claim 21: ...parsing HTML-based code corresponding to the Web page to determine an original page layout... The Blink rendering engine's LayoutNG component allegedly parses HTML to generate a Layout Tree that defines the page layout. The complaint provides a screenshot using the Chrome Web Inspector to show the layout box for a column. ¶99-100, p. 30 col. 17:3-6
From Claim 21: ...logically grouping selected content into objects; The Accused Products are alleged to logically group content into Document Object Model (DOM) objects. ¶103-104 col. 17:7-8
From Claim 21: defining a primary datum corresponding to the original page layout; The primary datum is alleged to be the upper-left corner of the viewport, which is the origin (0,0) of the local coordinate space. ¶105-106 col. 17:12-14
From Claim 21: for each object, defining an object datum corresponding to a layout location datum for the object's associated display content; Each DOM object allegedly has an associated "ClientRect" which defines its size and position (x,y coordinate) relative to the viewport origin (0,0). This coordinate is the alleged object datum. ¶107-109 col. 17:15-18
From Claim 21: generating a vector from the primary datum to the object datum for the object. The object datums (x,y coordinates) are alleged to function as position vectors, with the tail at the primary datum (0,0) and the head at the object datum. A screenshot in the complaint illustrates these alleged vectors. ¶110-112, p. 47 col. 17:19-21
  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the term "scalable vector representation" can be construed to read on the accused browsers' system of generating display lists of painting instructions and rasterizing them onto GPU tiles. The defense may argue this is a fundamentally different raster-based process, not a vector-based one as contemplated by the patent.
    • Technical Questions: What evidence does the complaint provide that the accused system's "ClientRect" data, which defines a rectangular bounding box, performs the function of "generating a vector from the primary datum to the object datum" as required by the claim? The analysis may turn on whether defining a coordinate point relative to an origin is equivalent to generating a vector in the claimed sense.

'889 Patent Infringement Allegations

Claim Element (from Independent Claim 1 and Dependent Claim 5) Alleged Infringing Functionality Complaint Citation Patent Citation
From Claim 1: in response to a request to access a Web page... retrieving markup language-based Web content... the content including text content, a plurality of hyperlinks, and a plurality of images. The accused browsers enable users to request and retrieve HTML web pages that contain text, hyperlinks, and images. ¶155-157 col. 2:13-18
From Claim 1: processing... the markup language-based Web content with a rendering engine to generate page layout information... The Blink rendering engine allegedly processes HTML to produce a DOM tree and a Layout Tree, which constitutes the generation of page layout information. The complaint includes a screenshot from the Chrome Web Inspector showing a bounding box for an entire page with a defined width. ¶158-166, p. 63 col. 15:43-52
From Claim 1: employing the page layout information to generate scalable page layout information; and employing scalable page layout information... to generate views of the Web page on the display... to iteratively zoom... The browsers allegedly use the generated layout information within the Skia graphics engine to create a scalable vector representation (display list model), which is then used to generate views at different zoom levels. A series of screenshots demonstrates this alleged iterative zooming. ¶167-178, p. 77 col. 16:1-7
From Claim 1: wherein preservation of the functionality defined by the markup language-based content includes preservation of hyperlink functionality. Hyperlink functionality is allegedly preserved when zoomed in. The complaint provides screenshots showing a hyperlink being clicked while zoomed in, and the corresponding page loading. ¶179-180, p. 80 col. 2:54-56
From Claim 5: parsing and processing markup language code with the rendering engine to determine the original page layout... wherein the original page layout defines a layout location for a plurality of objects... The Blink rendering engine allegedly parses HTML and produces a DOM and Layout Tree that define a layout location for text and image objects. ¶181-183 col. 17:3-11
From Claim 5: for each object, defining an object datum corresponding to the layout location for the object on the original page layout; and associating the object and its object datum. Each HTML element allegedly corresponds to a DOM object with an associated ClientRect, which defines its location (the alleged "object datum"). A screenshot from the Chrome Web Inspector shows a highlighted image element and its corresponding DOMRect coordinates. ¶184-190, p. 85 col. 17:15-18
  • Identified Points of Contention:
    • Scope Questions: Does the accused system's generation of a "Layout Tree" and "ClientRects" meet the specific claim limitation of "defining an object datum corresponding to the layout location for the object on the original page layout"? The dispute may center on whether these modern browser architecture concepts map onto the patent's specific terminology.
    • Technical Questions: The claim requires generating "scalable page layout information" from "page layout information." What is the technical distinction between these two types of information, and how does the accused system's single process of generating a Layout Tree and display lists satisfy this two-part claimed structure?

V. Key Claim Terms for Construction

  • For '729 Patent and '889 Patent:

    • The Term: "scalable vector representation" / "scalable page layout information"
    • Context and Importance: This term is the core of the invention. Its construction will determine whether the accused browsers' method of rendering web pages—which involves creating display lists of painting commands, applying transformation matrices, and rasterizing onto GPU tiles—falls within the scope of the claims. Practitioners may focus on whether this term requires a true, persistent vector graphics object model (like SVG) or if it can be construed more broadly to cover a process that achieves a scalable, resolution-independent outcome using intermediate data structures that are not strictly vector graphics.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The '353 patent's abstract states the invention enables content to "be rapidly rendered, zoomed, and panned." This focus on the functional outcome of rapid, scalable rendering could support an interpretation that covers any technical means of achieving that result, not just a specific vector format.
      • Evidence for a Narrower Interpretation: Figure 4C and its description explicitly show the generation of "vectors" from a "primary datum" to various "object datums" ('353 Patent, col. 17:12-21). This could support a narrower construction requiring the generation of discrete vector data, which the defense may argue is absent in the accused display list/rasterization process.

  • For '729 Patent and '889 Patent:

    • The Term: "primary datum" and "object datum"
    • Context and Importance: These terms define the specific geometry claimed for creating the scalable representation. The infringement case hinges on mapping these terms to the technical operation of the Blink rendering engine. The key question will be whether the viewport origin (0,0) and the ClientRect/DOMRect coordinates of a DOM object, as used in the accused browsers, function as the claimed "primary datum" and "object datum."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides flexibility, stating "any point on the page may be used as the page datum" and "the datum points for each object may also be located any place on the object" ('353 Patent, col. 18:5-12). This could support a functional definition covering any coordinate system origin and object reference point.
      • Evidence for a Narrower Interpretation: The specification's preferred embodiment describes the primary datum as the "upper left hand corner of the display frame" and the object datum as the "upper left hand corner of the bounding box for that object" ('353 Patent, col. 18:1-17). The complaint's own infringement theory relies on this specific mapping (Compl. ¶106, 108). This explicit example could be used to argue for a narrower construction limited to this specific geometric arrangement.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Defendants induced infringement of all asserted patents by providing the Accused Products with the Samsung Internet and Chrome browsers pre-installed (Compl. ¶122, 196, 275, 342, 399). It is further alleged that Defendants encourage infringing use through user manuals, websites, and support materials that instruct users on how to browse the web, which necessarily involves the accused scalable rendering functionality (Compl. ¶123-125, p. 52-53).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The basis is Defendants' alleged knowledge stemming from prior litigation involving the same patent family and the same technology against Samsung, which began in 2011 (Compl. ¶117, 195, 272, 337, 398). For the '729 and '154 patents, which issued after the prior litigation, the complaint alleges knowledge based on their relationship to the earlier patents and citations to the '729 patent in Samsung's own European patent applications (Compl. ¶118-121, 274). For the '628 patent, knowledge is also alleged based on notice letters sent in 2022, 2023, and 2024 (Compl. ¶339).

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

  • A core issue will be one of definitional scope: Can the term "scalable vector representation," which the patent specification illustrates with discrete vectors pointing from an origin to object datums, be construed to cover the accused browsers' modern rendering pipeline, which involves generating display lists, applying transformation matrices, and rasterizing content onto GPU tiles? This question pits the patent's specific embodiments against the functional outcome of scalable, zoomable browsing.
  • A key technical and evidentiary question will be one of structural equivalence: Does the accused browsers' architectural model—which uses a Layout Tree to define the position of DOM objects via rectangular "ClientRect" data relative to a viewport origin—satisfy the specific, multi-step geometric process required by claims reciting the definition and use of a "primary datum" and an "object datum"? The case may turn on whether these modern browser concepts are merely a new name for the same claimed structure or represent a fundamentally different, non-infringing technical approach.