DCT

2:25-cv-00426

Samsung Display Co Ltd v. BOE Technology Group Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00426, E.D. Tex., 04/21/2025
  • Venue Allegations: Plaintiff alleges venue is proper because most defendants are foreign corporations that may be sued in any judicial district, and the U.S. entity, BOE Technology America, Inc., allegedly maintains a "Houston office" and conducts business in the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s OLED display panels, incorporated into consumer electronics such as smartphones, infringe four U.S. patents related to thin-film transistor (TFT) array structures, touch sensor designs, and pixel arrangement layouts for OLED displays.
  • Technical Context: The lawsuit concerns foundational technologies for modern OLED displays, which are critical components in high-end smartphones and other electronic devices, valued for their image quality and power efficiency.
  • Key Procedural History: The complaint alleges that Plaintiff sent a notice letter to Defendant on May 2, 2022, identifying infringement of two of the asserted patents. Plaintiff bases its allegations of willful infringement on Defendant’s alleged continuation of infringing activities after receiving this notice and on Defendant's alleged knowledge of the other two patents from their issuance dates.

Case Timeline

Date Event
2012-03-06 Earliest Priority Date for U.S. Patent No. 11,626,066
2012-09-19 Earliest Priority Date for U.S. Patent No. 9,299,730
2016-03-29 U.S. Patent No. 9,299,730 Issued
2016-07-29 Earliest Priority Date for U.S. Patent Nos. 10,541,279 & 11,500,496
2020-01-21 U.S. Patent No. 10,541,279 Issued
2022-05-02 Plaintiff allegedly sent notice letter to Defendant regarding '730 and '279 patents
2022-11-15 U.S. Patent No. 11,500,496 Issued
2023-04-11 U.S. Patent No. 11,626,066 Issued
2025-04-21 Complaint Filed

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

U.S. Patent No. 9,299,730 - "Thin Film Transistor Array Substrate And Organic Light-Emitting Diode Display"

The Invention Explained

  • Problem Addressed: The patent describes a problem in the manufacturing of TFT array substrates where misalignment between patterned layers can cause the capacitance of a storage capacitor within a pixel to deviate from its designed value, leading to display defects like "low-gradation spots" or "abnormal colors" ( Compl. ¶26; ’971 Patent, col. 1:40-49).
  • The Patented Solution: The invention proposes a specific capacitor structure designed to be robust against such misalignment. It features an upper electrode that is configured to "overlap with the whole lower electrode" and includes an "opening." A connection node then passes through this opening to electrically couple to the lower electrode below ( Compl. ¶26; ’971 Patent, col. 2:57-65, Fig. 2). This geometry ensures that the overlapping area, which determines capacitance, remains constant even if the layers shift slightly during manufacturing.
  • Technical Importance: This design improves manufacturing yield and display quality by making the pixel's electrical characteristics less sensitive to common process variations.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶43).
  • The essential elements of claim 1 include:
    • A thin film transistor (TFT) array substrate.
    • A capacitor comprising a lower electrode and an upper electrode.
    • The upper electrode is arranged to overlap with the whole lower electrode, extends beyond an edge of the lower electrode, and has an opening.
    • An inter-layer insulation film covers the capacitor.
    • A node contact hole is located in the insulation film within the opening.
    • A connection node electrically couples the lower electrode and at least one TFT through the node contact hole.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,541,279 - "Display Device"

The Invention Explained

  • Problem Addressed: The patent aims to prevent the occurrence of a crack in an insulating layer within a display device's integrated touch sensing unit, which can cause short circuits and device failure (Compl. ¶28; ’279 Patent, col. 1:15-18).
  • The Patented Solution: The invention specifies a touch sensing unit built with two conductive patterns separated by an insulating layer. The core of the solution is a structural requirement: the "second conductive pattern" (the upper layer) must have a "thickness that is greater than a thickness of the first conductive pattern" (the lower layer) (’279 Patent, Abstract; col. 2:47-50). This intentional disparity in thickness is intended to manage mechanical stress within the layered structure, reducing the likelihood of cracks forming in the critical insulating layer.
  • Technical Importance: This technology enhances the mechanical durability and reliability of displays with integrated touch sensors, a crucial consideration for consumer electronics, especially flexible or foldable devices.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶62).
  • The essential elements of claim 1 include:
    • A display device with a display panel and a touch sensing unit.
    • The touch sensing unit comprises a first conductive pattern, an insulating layer covering it, and a second conductive pattern on the insulating layer.
    • The first conductive pattern comprises "electrically conductive second connection parts."
    • The second conductive pattern comprises "first touch sensor parts," "second touch sensor parts," and "first connection parts."
    • The key limitation is that the "second conductive pattern has a thickness that is greater than a thickness of the second connection parts" (which are part of the first conductive pattern).
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,500,496 - "Display Device"

Technology Synopsis

This patent, a continuation of the ’279 Patent, integrates a specific touch sensor structure with the underlying OLED pixel layer. It claims a display device that includes red, green, and blue light-emitting areas of different sizes, a thin film encapsulation layer, and a touch sensing unit where metal mesh lines are located "within" mesh holes and do "not" overlap the light-emitting areas, thereby minimizing optical interference while providing touch functionality (Compl. ¶30; ’496 Patent, col. 23:55-64).

Asserted Claims

Independent claim 1 (Compl. ¶88).

Accused Features

The complaint alleges that the BOE OLED display's entire layered structure infringes, including its base layer, circuit layer, organic light-emitting device layer with different-sized color areas, thin film encapsulation layer, and the on-panel touch sensing unit with its specific metal mesh arrangement (Compl. ¶¶ 91-106).

U.S. Patent No. 11,626,066 - "Pixel Arrangement Structure for Organic Light Emitting Diode Display"

Technology Synopsis

This patent claims a specific geometric arrangement of sub-pixels in an OLED display. The invention defines a "virtual square" where the center and vertices are defined by the centers of green pixels. The claims require that at least two red pixels and two blue pixels be located entirely within this virtual square and impose further constraints on the relative sizes, shapes (e.g., convex shape for the green pixel), and spacing of the different colored pixels (Compl. ¶32; ’066 Patent, col. 1:57-67). This type of sub-pixel layout is designed to optimize perceived resolution, color accuracy, and display longevity.

Asserted Claims

Independent claim 1 (Compl. ¶115).

Accused Features

The complaint accuses the physical layout of the red, green, and blue sub-pixels in the BOE OLED display, using annotated microscopic images to allege that the arrangement satisfies the specific geometric constraints of the "virtual square" defined in the claim (Compl. ¶¶ 118-128).

III. The Accused Instrumentality

Product Identification

The Accused Products are OLED displays manufactured, used, sold, or imported by Defendants (Compl. ¶36). The complaint specifically identifies as exemplary infringing products the OLED displays incorporated into the Nubia Z60 Ultra and REDMAGIC 9S Pro smartphones (Compl. ¶36).

Functionality and Market Context

The complaint alleges the accused displays are based on BOE's "Q9+" screen material technology (Compl. ¶39). Through analysis of a purchased Nubia Z60 Ultra, the complaint provides technical details of the accused displays, including cross-sectional images identifying the substrate, TFT array, multiple insulation layers, capacitor structures, and a conductive metal mesh touch sensing unit located on the display panel (Compl. ¶¶ 46-52, 66-78). Figure 4 of the complaint provides a teardown image showing the display's primary components: the device chassis, the display panel substrate, and the glass panel (Compl. ¶46, Fig. 4). The complaint alleges BOE is a direct supplier to Nubia and that these products are sold and promoted within the United States (Compl. ¶¶ 39, 40).

IV. Analysis of Infringement Allegations

9,299,730 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a capacitor comprising a lower electrode on the first insulation layer, and an upper electrode arranged to overlap with the whole lower electrode... The BOE display allegedly contains a capacitor with an upper electrode (red dashed lines) shown overlapping a whole lower electrode (blue dashed lines). ¶50, Fig. 8 col. 3:14-18
...the upper electrode extending beyond an edge of the lower electrode and having an opening... The upper electrode is alleged to extend beyond the lower electrode and have an opening (yellow dashed lines). Figure 8, an annotated front-side image of the circuit, illustrates this alleged opening and overlap (Compl. ¶50, Fig. 8). ¶50, Fig. 8 col. 3:18-20
an inter-layer insulation film covering the capacitor; An annotated cross-section image allegedly shows an inter-layer insulation film that covers the capacitor structure. ¶51, Fig. 9 col. 3:28-29
a node contact hole in the inter-layer insulation film and the second insulation layer, and within the opening; A cross-section and front-side image allegedly show a node contact hole made through the insulation films and located within the capacitor's opening. ¶52, Fig. 11 col. 3:30-33
a connection node on the inter-layer insulation film and electrically coupling the lower electrode and at least one TFT to each other through the node contact hole. The complaint alleges a connection node on the insulation film that connects to the lower electrode and a TFT (T3) via the node contact hole. ¶52, Fig. 11 col. 3:33-37

Identified Points of Contention

  • Scope Questions: A potential point of dispute may be the term "overlap with the whole lower electrode." The analysis will question whether evidence shows complete, 100% overlap, or if minor edge misalignments exist that could take the accused product outside the literal scope of the claim.
  • Technical Questions: The complaint's evidence relies on analysis of 2D images. A key question will be what evidence confirms that the structure identified as a "connection node" performs the specific function of "electrically coupling" the lower electrode to a TFT as required by the claim.

10,541,279 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a touch sensing unit on the display panel... comprising: a first conductive pattern... an insulating layer... and a second conductive pattern on the insulating layer... The complaint presents cross-section and EDS analysis images allegedly showing a first conductive pattern (Ti/Al/Ti), an insulating layer (Si), and a second conductive pattern (Ti/Al/Ti) built directly on the display panel. ¶¶ 67-71, Fig. 19 col. 1:43-47
...partially crossing the first conductive pattern... An annotated image of the touch sensing unit's metal mesh allegedly shows the second conductive pattern (red lines) crossing the first conductive pattern (yellow lines). ¶72, Fig. 21 col. 1:47-48
...the first conductive pattern comprises electrically conductive second connection parts connecting respective ones of the second touch sensor parts... A cross-section image allegedly identifies structures within the first conductive pattern that serve as "second connection parts" connecting the second touch sensor parts. ¶76, Fig. 24 col. 2:44-46
...wherein the second conductive pattern has a thickness that is greater than a thickness of the second connection parts. An annotated cross-section image with a magnified inset visually compares the thickness of the second conductive pattern to the thickness of the second connection parts, alleging the former is greater than the latter. Figure 26 is the primary visual evidence for this key limitation (Compl. ¶78, Fig. 26). ¶78, Fig. 26 col. 2:47-50

Identified Points of Contention

  • Technical Questions: The central technical question will be the measurement of the relative thicknesses. The complaint's visual assertion in Figure 26 raises the question of what quantitative evidence supports the claim that one layer's thickness is definitively "greater than" another's, and whether this difference is consistent across the device.
  • Scope Questions: The definition of claim terms such as "touch sensor parts" and "connection parts" may be disputed. The analysis will question whether the physical structures identified in the accused device perform the specific roles defined by the patent's claims.

V. Key Claim Terms for Construction

U.S. Patent No. 9,299,730

  • The Term: "overlap with the whole lower electrode"
  • Context and Importance: This term is critical because the patent's asserted novelty for overcoming manufacturing misalignment hinges on this complete overlap. If any portion of the lower electrode is found to be uncovered by the upper electrode in the accused device, it may support a non-infringement argument. Practitioners may focus on whether "whole" allows for any manufacturing tolerances or requires 100% coverage.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's focus on solving the problem of misalignment (col. 1:40-49) could support an interpretation where the term is understood to mean substantial or functional overlap that achieves the stated purpose, even with minor edge effects.
    • Evidence for a Narrower Interpretation: The claim language itself is absolute ("whole"). The repeated use of this precise phrase in the patent's summary and detailed description (e.g., Abstract; col. 2:58) suggests that complete overlap is an essential and deliberate feature of the invention, not merely an ideal embodiment.

U.S. Patent No. 10,541,279

  • The Term: "a thickness that is greater than"
  • Context and Importance: This relational term defines the core structural invention for preventing cracks. The entire infringement case for this patent rests on proving this dimensional relationship in the accused device. The dispute will center on how this comparison is made and whether any measured difference is sufficient to meet the claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning of "greater than" suggests any measurable, non-zero positive difference in thickness would satisfy the limitation. The claim does not recite a specific ratio or minimum difference.
    • Evidence for a Narrower Interpretation: The specification provides exemplary thickness ranges in angstroms for the different conductive layers (e.g., first pattern at 1800-2100 Å, second pattern at 2700-3500 Å) (col. 2:60-65). While these are embodiments, a party could argue they provide context that the claimed "greater" thickness implies a structurally significant and substantial difference, not a trivial or incidental one.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all four asserted patents. The inducement claims are based on allegations that BOE knowingly encourages and instructs its customers (e.g., smartphone manufacturers) to import, sell, and use products containing the allegedly infringing displays (Compl. ¶¶ 56, 82, 109, 131). The basis for knowledge for the '730 and '279 patents is an alleged notice letter from May 2, 2022; for the '496 and '066 patents, knowledge is alleged from their issuance dates. Contributory infringement is alleged on the basis that the BOE OLED displays are especially designed to infringe and are a material component with no substantial non-infringing uses (Compl. ¶¶ 58, 84, 111, 133).
  • Willful Infringement: Willfulness is alleged for all four patents. The complaint bases this allegation on Defendant’s alleged continued infringement after receiving the May 2, 2022 notice letter regarding the '730 and '279 patents, and for the '496 and '066 patents, on knowledge since their issuance due to their relationship to the noticed patents and alleged "copying of Samsung Display's patented OLED technologies" (Compl. ¶¶ 34, 59, 85, 112, 134).

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

  1. A core issue will be one of empirical verification: can the plaintiff's technical analysis of the accused BOE displays, based on teardowns and microscopic imaging, definitively establish that the device's physical structures meet the precise and quantitative limitations of the asserted claims, particularly the "overlap with the whole lower electrode" ('730 patent) and "thickness that is greater than" ('279 patent) requirements?
  2. A central question for damages will be one of scienter and willfulness: did the Defendant possess the requisite knowledge and intent for indirect and willful infringement, particularly for the two patents issued after the date of the alleged notice letter, and can the plaintiff substantiate its allegation of "copying"?
  3. A key dispute for the '066 patent will likely be one of definitional scope: does the pixel arrangement in the accused displays fall within the patent's specific and complex geometric constraints for a "virtual square," and how will the court construe terms defining the relative sizes, shapes, and locations of the various sub-pixels?