DCT

2:25-cv-00378

SnapAid Ltd v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00378, E.D. Tex., 04/10/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains a regular and established place of business in the district, including a corporate office in Plano and a retail "Samsung Experience Store" in Frisco, and has committed acts of infringement within the district. Venue over the foreign parent company, Samsung Electronics Co., Ltd., is asserted as proper in any U.S. judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones and tablets, incorporating features such as "Flaw Detection," "Shot Suggestions," and "Palm Gesture," infringe eight patents related to real-time assessment and improvement of digital image quality.
  • Technical Context: The technology at issue resides in the field of computational photography, where software algorithms and sensor data are used in real-time within a camera system to analyze scene characteristics and guide a user to capture a higher quality image.
  • Key Procedural History: The complaint alleges a pre-suit business relationship, beginning with a non-disclosure agreement around September 2015, under which Plaintiff provided Defendant with its proprietary image improvement technology, including software packages (APKs) and technical details. Plaintiff further alleges it made Defendant aware of the ’348 and ’226 patents specifically on or about September 14, 2017. This history may be relevant to allegations of knowledge and willful infringement.

Case Timeline

Date Event
2012-10-23 Priority Date for Asserted Patents
2015-09-01 Parties allegedly enter into a non-disclosure agreement
2015-10-01 Plaintiff allegedly begins providing proprietary technology to Defendant
2016-05-10 U.S. Patent No. 9,338,348 Issues
2017-05-23 U.S. Patent No. 9,661,226 Issues
2017-09-14 Defendant allegedly made aware of ’348 and ’226 Patents
2018-06-26 U.S. Patent No. 10,009,537 Issues
2020-05-19 U.S. Patent No. 10,659,682 Issues
2021-03-09 U.S. Patent No. 10,944,901 Issues
2022-02-15 U.S. Patent No. 11,252,325 Issues
2022-02-15 U.S. Patent No. 11,671,702 Issues
2025-03-11 U.S. Patent No. 12,250,452 Issues
2025-04-10 Complaint Filing Date

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

U.S. Patent No. 9,338,348 - "Real Time Assessment of Picture Quality"

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of assessing picture quality in real-time when relying on multiple, independent quality metrics (Compl. ¶36).
  • The Patented Solution: The invention is a digital image acquisition system that computes multiple "quality indicators" in real-time. The system is designed to automatically capture and store an image only after a "first logical criterion" based on these indicators is met. If the criterion is not met, the system uses a "second logical criterion" to select and present a suggestion from a pre-stored table to help the user improve the image. A key aspect is that at least one of these criteria is defined over a "time-dependent confidence level" for one or more quality indicators, making the system responsive to the reliability of its own data (Compl. ¶37; '537 Patent, col. 3:6-21).
  • Technical Importance: This technology represents a shift from passive quality measurement to an active, guided photography experience, aiming to prevent the capture of poor-quality images by providing real-time, context-aware feedback to the user (Compl. ¶36).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶117).
  • The essential elements of independent Claim 1 are:
    • A digital image acquisition system comprising an image capture component and at least one digital processor.
    • The processor is programmed for real-time computation of multiple quality indicators.
    • The system performs automatic image capturing and storing only after a first logical criterion based on the multiple quality indicators is satisfied.
    • A message provider is operative, while the first criterion is not satisfied, to select a suggestion from a pre-stored table based on at least one second logical criterion.
    • At least one of the logical criteria is pre-defined over a time-dependent confidence level associated with at least one of the quality indicators.

U.S. Patent No. 9,661,226 - "Real Time Assessment of Picture Quality"

The Invention Explained

  • Problem Addressed: Prior art methods for assessing picture quality using independent indicators were seen as potentially unreliable because they did not account for the interplay between different factors affecting an image (Compl. ¶45).
  • The Patented Solution: The patent claims a method for real-time image quality estimation that integrates and weighs data from three distinct sources: device motion (e.g., from an accelerometer), camera parameters (e.g., ISO, focus), and image content analysis (e.g., object detection). The method calculates a "total value" by combining a first weighted value from the motion sensor, a second weighted value from the camera, and a third weighted value from the image analysis. This total value is then compared to a threshold to determine a subsequent action (Compl. ¶46; '226 Patent at 22:7-37).
  • Technical Importance: This approach creates a more robust and holistic quality score by synthesizing disparate data sources into a single, weighted metric, moving beyond a simple pass/fail on individual quality checks (Compl. ¶45).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶130).
  • The essential elements of independent Claim 1 are:
    • A method for real-time estimating of image quality in a device with a camera, motion sensor, and processor.
    • Obtaining a first value (QI1) from the motion sensor and estimating a first weight (c1).
    • Obtaining a second value (QI2) from the digital camera and estimating a second weight (c2).
    • Analyzing the captured image to obtain a third value (QI3) and estimating a third weight (c3).
    • Calculating a total value based on the three weighted values (QI1, QI2, QI3).
    • Comparing the total value to a threshold, determining the result, and acting in response.

U.S. Patent No. 10,009,537 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent describes a method for estimating the quality of a digital image frame from a video stream. It involves calculating a total quality value from a weighted camera-related value (QI1) and a weighted image-analysis value (QI2), where the second weight (c2) is partially based on data from previous images in the video stream (Compl. ¶54-55).
  • Asserted Claims: At least Claim 1 (Compl. ¶144).
  • Accused Features: The "Flaw Detection Accused Products" (Compl. ¶144).

U.S. Patent No. 10,659,682 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent claims a method for estimating image quality from a video stream by combining multiple weighted values, including device motion (QI1), camera parameters like exposure and focus (QI2), and a third value (QI3) derived from deep learning analysis of the image. The total quality value is calculated using these values and their weights, as well as previous values and weights from the image stream (Compl. ¶63-64).
  • Asserted Claims: At least Claim 17 (Compl. ¶158).
  • Accused Features: The "Flaw Detection Accused Products" (Compl. ¶158).

U.S. Patent No. 10,944,901 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent describes a method for estimating image quality by obtaining a first value related to the device's angle to the horizon and a second value related to the aesthetic quality/composition of the image. If either value is below a threshold, the system selects and presents a suggestion from a pre-stored table to the user to help improve the value (Compl. ¶72-73).
  • Asserted Claims: At least Claim 1 (Compl. ¶172).
  • Accused Features: The "Shot Suggestion Accused Products" (Compl. ¶172).

U.S. Patent No. 11,252,325 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent discloses a method for evaluating image quality by obtaining and weighting four distinct quality values: device motion, image exposure, facial properties (e.g., smiling, looking at camera), and lens obstruction. At least one value or weight is calculated using an artificial neural network with deep learning. If a value is unreliable, a suggestion from a pre-stored table is presented to the user (Compl. ¶81-82).
  • Asserted Claims: At least Claim 1 (Compl. ¶186).
  • Accused Features: The "Flaw Detection Accused Products" (Compl. ¶186).

U.S. Patent No. 11,671,702 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent describes a method for estimating image quality using four values: device motion (QI1), exposure (QI2), facial properties (QI3), and lens obstruction (QI4). The system selects and presents suggestions from a pre-stored table to the user on how to improve at least one of the values (Compl. ¶91-92).
  • Asserted Claims: At least Claim 1 (Compl. ¶200).
  • Accused Features: The "Flaw Detection Accused Products" (Compl. ¶200).

U.S. Patent No. 12,250,452 - "Real Time Assessment of Picture Quality"

  • Technology Synopsis: This patent claims a method for providing movement suggestions to a user. It involves calculating a quality indicator for a face or object (QI1), an aesthetic quality indicator using a background blurring test (QI2), and a total quality indicator based on at least one of these. Based on the total indicator, the system selects a suggestion from a pre-stored table to move the device to a different location (Compl. ¶101-102).
  • Asserted Claims: At least Claim 1 (Compl. ¶214).
  • Accused Features: The "Shot Suggestion Accused Products" (Compl. ¶214).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies Samsung's Galaxy series smartphones and tablets, such as the Samsung Galaxy 21 FE 5G, as the accused instrumentalities (Compl. ¶112-115).
  • Functionality and Market Context: The infringement allegations center on three specific software functionalities:
    • Palm Gesture: This feature allows a user to trigger the camera's shutter by showing their palm to the camera, and is accused of infringing the ’348 Patent (Compl. ¶115, 117).
    • Flaw Detection: This feature automatically analyzes a photo after it is taken to identify potential issues such as motion blur, closed eyes, or smudges on the lens, and then suggests retaking the photo. It is accused of infringing the ’226, ’537, ’682, ’325, and ’702 Patents (Compl. ¶113, 130, 144, 158, 186, 200).
    • Shot Suggestion: This feature analyzes the scene in the viewfinder and provides on-screen guidance to help the user improve the composition of their photo before taking it. It is accused of infringing the ’901 and ’452 Patents (Compl. ¶114, 172, 214).
      The complaint alleges these functionalities are significant selling points that contribute to a "top-tier photography experience" for consumers (Compl. ¶111). It supports its venue allegations with a screenshot of a "Samsung Experience Store" in Frisco, Texas, where accused products are allegedly sold and serviced (Compl. ¶27).

IV. Analysis of Infringement Allegations

The complaint incorporates claim charts by reference to exhibits which were not available for analysis. The following tables summarize the infringement allegations based on the narrative of the complaint.

U.S. Patent No. 9,338,348 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A digital image acquisition system comprising an image capture component...and...at least one digital processor... Samsung's "Palm Gesture Accused Products" are alleged to be digital image acquisition systems containing cameras and processors (Compl. ¶115, 117). ¶117 '537 Patent, col. 8:28-31
...programmed for real time computation of multiple quality indicators... The accused systems are alleged to compute multiple quality indicators in real-time to assess image quality (Compl. ¶37). ¶37 '537 Patent, col. 2:19-25
automatic image capturing...only after a first logical criterion predefined on said multiple quality indicators, is satisfied... The complaint alleges the accused systems have special features that satisfy certain logical criteria before acting (Compl. ¶127). ¶127 '537 Patent, col. 4:10-13
a message provider operative...to select...at least one appropriate suggestion from a pre-stored table... The accused systems are alleged to present suggestions to a user if a captured image does not satisfy a logical criterion (Compl. ¶127). ¶127 '537 Patent, col. 4:15-20
...wherein at least one of said logical criteria are pre-defined over a time-dependent confidence level... The complaint alleges the inventions use a time-dependent confidence level for quality indicators (Compl. ¶37). ¶37 '537 Patent, col. 3:12-14

U.S. Patent No. 9,661,226 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for real-time estimating of an image quality...with a device that comprises...a digital camera...a motion or location sensor; and a processor... Samsung's "Flaw Detection Accused Products" are alleged to be devices containing these components that perform real-time image quality estimation (Compl. ¶113, 130). ¶130 '537 Patent, col. 11:7-12
obtaining a first value (QI1) responsive to the device motion from the motion or location sensor; The "Flaw Detection" feature is alleged to obtain quality indicator values, which would include motion data, to determine if a flaw like motion blur exists (Compl. ¶141). ¶141 '537 Patent, col. 11:1-2
obtaining a second value (QI2) associated with the digital camera; The "Flaw Detection" feature is alleged to obtain quality indicator values, which would include camera data like focus, to determine if a flaw exists (Compl. ¶141). ¶141 '537 Patent, col. 13:21-25
analyzing the captured image for detecting or recognizing one or more objects...obtaining a third value (QI3) associated with the analysis; The "Flaw Detection" feature is alleged to analyze the image for flaws like eye blinks, which constitutes detecting characteristics of an object (a face) (Compl. ¶111, 141). ¶141 '537 Patent, col. 12:20-24
calculating a total value according to...the first value (QI1) weighted...second value (QI2) weighted...and the third value (QI3) weighted... The complaint alleges the processor in the accused products obtains quality indicator values and estimates associated weights to determine if the total value is reliable (Compl. ¶141). ¶141 '537 Patent, col. 17:48-52
comparing the total value to a threshold...determining whether the total value is higher than, or below...and acting in response... The accused system is alleged to determine if the total value is higher than a threshold value and act accordingly, such as by suggesting a retake (Compl. ¶141). ¶141 '537 Patent, col. 18:1-3

Identified Points of Contention:

  • Scope Questions: A potential question for the court regarding the ’348 patent is whether the "Palm Gesture" feature, which a user primarily understands as a remote shutter, can be shown to practice the claim's limitations related to assessing image quality and providing corrective suggestions. The complaint does not explicitly detail how the gesture function performs these quality-assessment steps.
  • Technical Questions: A central technical question for the ’226 patent and related patents will be what evidence shows that the "Flaw Detection" feature performs the specific multi-factor, weighted calculations recited in the claims. The analysis may focus on whether the accused feature arrives at its "flaw" determination by combining weighted values from the three distinct sources required by Claim 1 (device motion, camera data, image analysis), or if it uses an alternative technical method.

V. Key Claim Terms for Construction

  • The Term: "calculating a total value according to, or based on, the first value (QI1) weighted... the second value (QI2) weighted... and the third value (QI3) weighted..." (from Claim 1 of the '226 Patent)
  • Context and Importance: This term is the central processing step of the claim and defines the specific inventive method of combining disparate data types. The outcome of the infringement analysis will likely depend on whether the accused "Flaw Detection" feature can be shown to perform this specific three-part weighted calculation. Practitioners may focus on this term because it requires evidence of a particular technical implementation, not just a similar outcome.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Parties advocating for a broader scope may argue that the phrase "based on" does not require a strict mathematical summation and could encompass any algorithm that considers these three types of inputs in determining an outcome. The specification describes this as one "possible method for computation," which may suggest other methods are contemplated ('537 Patent, col. 11:51-52).
    • Evidence for a Narrower Interpretation: The claim's structure, which separately lists obtaining three distinct values and their corresponding weights before calculating a "total value," suggests a specific, structured combination is required. The patent's description of a "total quality indicator" based on combining separate indicators supports a narrower view that a simple, unweighted check for an individual flaw (e.g., just checking for blur) would not meet this limitation ('537 Patent, col. 2:38-41).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement allegations are based on Samsung's alleged actions of advertising the infringing features and providing instructions, user manuals, and customer support that encourage customers to use the accused products in an infringing manner (Compl. ¶122, 126). The complaint includes a screenshot from Samsung's website inviting consumers to "Explore. Learn. Test-drive" its products at retail stores as evidence supporting inducement (Compl. ¶28). Contributory infringement is alleged on the basis that the accused software features are specially designed for infringing use and have no substantial non-infringing uses (Compl. ¶127, 141).
  • Willful Infringement: Willfulness is alleged for all asserted patents. For the ’348 and ’226 patents, the allegation is based on alleged pre-suit knowledge dating to at least September 14, 2017, stemming from direct communications and the parties' prior business dealings (Compl. ¶119, 132). For the other six patents, willfulness is alleged to have begun at least upon service of the complaint (e.g., Compl. ¶146, 160).

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

  • A core issue will be one of evidentiary proof: What technical evidence will be presented to demonstrate that Samsung's "Flaw Detection" and "Shot Suggestion" features perform the specific multi-factor, weighted calculations recited in the asserted claims, as opposed to using alternative, unpatented methods to achieve a similar result?
  • A key question will be one of functional mapping: Can the plaintiff successfully argue that a feature like "Palm Gesture," which users perceive as a remote shutter, is part of a broader system that practices the claimed method of assessing image quality and providing corrective suggestions as required by the '348 patent?
  • A third central question will relate to knowledge and intent: Given the alleged pre-suit business relationship where the plaintiff provided its technology to the defendant, how will this history influence the analysis of pre-suit knowledge, willfulness, and potential damages, particularly for the patents issued before the relationship soured?