DCT

2:25-cv-00430

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-00430, E.D. Tex., 04/23/2025
  • Venue Allegations: Venue is alleged against the foreign-domiciled defendants as they may be sued in any judicial district. Venue is alleged against the U.S. subsidiary, BOE Technology America, Inc., based on its purposeful availment of the district, including maintaining a Houston office and facilitating the supply of accused products into the stream of commerce reaching consumers in Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s OLED displays, incorporated into third-party smartphones, infringe four patents related to OLED device structure, manufacturing, and pixel layout.
  • Technical Context: The technology concerns Organic Light Emitting Diode (OLED) displays, which are critical components for high-performance screens in consumer electronics such as smartphones.
  • Key Procedural History: The complaint alleges that Plaintiff sent a letter to Defendant BOE Beijing on May 2, 2022, providing notice of alleged infringement of three of the four asserted patents. The complaint also references a prior proceeding in which Defendant Mianyang BOE allegedly admitted that it manufactures and sells AMOLED screens that are imported into the United States.

Case Timeline

Date Event
2004-05-29 U.S. Patent No. 7,279,708 Priority Date
2007-10-09 U.S. Patent No. 7,279,708 Issue Date
2012-03-06 U.S. Patent No. 10,832,616 Priority Date
2012-09-19 U.S. Patent No. 10,720,483 Priority Date
2014-06-17 U.S. Patent No. 11,081,503 Priority Date
2020-07-21 U.S. Patent No. 10,720,483 Issue Date
2020-11-10 U.S. Patent No. 10,832,616 Issue Date
2021-08-03 U.S. Patent No. 11,081,503 Issue Date
2022-05-02 Plaintiff sends notice letter to Defendant BOE Beijing
2025-04-23 Complaint Filing Date

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

U.S. Patent No. 7,279,708 - "Electroluminescence Display Device and Method of Manufacturing the Same"

The Invention Explained

  • Problem Addressed: The patent's background describes how conventional manufacturing of OLED displays can lead to defects when gas generated from organic layers (e.g., an overcoat layer) becomes trapped, or when terminal layers are peeled or damaged during processing (ʼ708 Patent, col. 1:14-25).
  • The Patented Solution: The invention discloses an OLED structure designed to improve manufacturing reliability. It involves placing a "sub-conductive layer" over an organic insulating layer that covers a power supply line. This sub-conductive layer electrically connects the power supply line to the device's main second electrode. Crucially, this sub-conductive layer is designed with a "penetration portion," which creates a path for gas generated from the underlying organic layer to be discharged during vacuum annealing, thereby preventing defects (ʼ708 Patent, Abstract; col. 2:27-33).
  • Technical Importance: The described structure aims to improve manufacturing yield and device longevity by mitigating common physical failure modes associated with fabricating complex, multi-layered OLED displays (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶43).
  • Essential elements of claim 1 include:
    • A display area with pixels having first and second electrode layers.
    • An electrode power supply line.
    • An insulating layer containing an organic material, disposed on the power supply line and having a via hole.
    • A sub-conductive layer on the insulating layer, extending along the power supply line.
    • The power supply line and second electrode layer are coupled through the via hole by the sub-conductive layer.
    • The sub-conductive layer includes a "penetration portion".

U.S. Patent No. 11,081,503 - "Array Substrate and Method of Mounting Integrated Circuit Using the Same"

The Invention Explained

  • Problem Addressed: The patent's background explains that flexible display substrates can expand or contract during manufacturing, causing misalignment between the contact pads on the substrate and the contact bumps on the driving integrated circuit (IC) that must be attached to it (’503 Patent, col. 1:49-56).
  • The Patented Solution: The invention proposes a specific geometric design for the contact pads and IC bumps to compensate for such deformation. The pads (and corresponding bumps) are designed as inclined parallelograms, arranged symmetrically on either side of an imaginary centerline. This geometry allows a misalignment caused by substrate expansion or contraction (in a first direction) to be corrected by simply shifting the IC in a perpendicular (second) direction, ensuring a reliable electrical connection ('503 Patent, Abstract; col. 7:1-19).
  • Technical Importance: This design provides a mechanical solution to a critical manufacturing challenge for flexible electronics, potentially increasing production yields and reliability by accommodating material instabilities (Compl. ¶28).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶60).
  • Essential elements of claim 1 include:
    • An electronic device with an array substrate, a pad portion, and an integrated circuit with a bump portion.
    • The pad portion comprises a first sub-pad unit with an inclined first pad and a second sub-pad unit with an inclined second pad.
    • The first and second pads are "inclined in different directions symmetrically about an imaginary line" that divides the pad portion.
    • The bump portion similarly comprises first and second sub-bump units with inclined bumps.
    • The first and second bumps are also "inclined in different directions symmetrically about the imaginary line" that divides the pad portion.

U.S. Patent No. 10,832,616 - "Pixel Arrangement Structure for Organic Light Emitting Diode Display"

  • Technology Synopsis: The patent addresses the need for improved image quality and manufacturing efficiency in OLED displays by defining a novel geometric layout for pixels. The invention describes a specific spatial relationship between different colored pixels (e.g., red, green, blue) by defining their centers relative to the vertices and center of a "virtual square," and specifies their relative sizes, shapes, and distances to optimize performance and manufacturability (Compl. ¶30; ʼ616 Patent, Abstract).
  • Asserted Claims: Independent claim 1 (Compl. ¶79).
  • Accused Features: The complaint alleges that the specific arrangement, shape, and relative sizing of the pixels in the accused BOE OLED displays meet the geometric constraints defined in the patent's claims (Compl. ¶¶82-96).

U.S. Patent No. 10,720,483 - "Thin Film Transistor Array Substrate and Organic Light-Emitting Diode Display"

  • Technology Synopsis: The patent describes a specific structure for a thin film transistor (TFT) array substrate used in OLED displays. The asserted claim focuses on the physical layout of the transistors and interconnects, claiming a particular arrangement of first and second TFTs, three distinct insulating layers, a first metal pattern, and a connection member that electrically connects the first gate electrode and the second TFT while overlapping a portion of the first channel region in a plan view (’483 Patent, cl. 22).
  • Asserted Claims: Independent claim 22 (Compl. ¶105).
  • Accused Features: The complaint accuses the physical, layered structure of the TFT array in the BOE OLED displays, alleging that the arrangement of its transistors, electrodes, insulating layers, and connection members reads on the elements of the claim (Compl. ¶¶108-115).

III. The Accused Instrumentality

Product Identification

  • The Accused Products are OLED displays manufactured and sold by the BOE defendants. The complaint identifies the display incorporated into the Nubia Z60 Ultra smartphone as a specific, representative example (Compl. ¶¶36, 42).

Functionality and Market Context

  • The Accused Products are active matrix OLED (AMOLED) display panels. The complaint provides visual evidence from a teardown of a Nubia Z60 Ultra, showing the device chassis, the display panel substrate, and the glass panel as separate components. Figure 4 of the complaint depicts these disassembled components, with the "Display Panel Substrate" identified as the accused instrumentality (Compl. ¶46, Fig. 4). The complaint alleges that BOE is a supplier to smartphone original equipment manufacturers (OEMs) and that BOE’s displays are incorporated into products sold in the United States, citing Nubia's own product pages that identify BOE as the supplier of its "Q9+ Screen material" (Compl. ¶39).

IV. Analysis of Infringement Allegations

’708 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an electroluminescent display device... a display area with pixels... on a substrate The BOE OLED Display is an electroluminescent device with a substrate supporting pixels. The complaint provides an image of the disassembled phone showing the display panel substrate (Fig. 4). ¶46-47 col. 3:3-9
an electrode power supply line to supply electrode power to the display area The accused display contains an electrode power supply line that supplies power to the display area, as identified in cross-section images. ¶48 col. 4:65-67
an insulating layer disposed on the electrode power supply line, including a via hole and containing an organic material An insulating layer containing organic material (carbon) is disposed on the power supply line. The complaint provides cross-section images (Fig. 8, 9) identifying this layer and a via hole within it. ¶49 col. 3:58-62
a sub-conductive layer formed on the insulating layer including the via hole along the electrode power supply line A sub-conductive layer containing silver (Ag) is identified on the insulating layer and in the via hole, as shown in cross-section EDS analysis images. ¶50 col. 4:47-50
the electrode power supply line and the second electrode layer are coupled to each other at the via hole through the sub-conductive layer The sub-conductive layer is shown electrically coupling the power supply line and the second electrode layer through the via hole. ¶51 col. 5:28-34
the sub-conductive layer on the insulating layer includes a penetration portion A cross-section image (Fig. 13) identifies a "penetration portion" located in the sub-conductive layer that is on the insulating layer. ¶51 col. 6:50-57

Identified Points of Contention

  • Technical Question: The complaint identifies a structural feature in a micrograph and labels it the "penetration portion" (Compl. Fig. 13). A central question will be whether this feature performs the gas-discharging function described as an object of the invention in the ’708 patent specification (ʼ708 Patent, col. 2:30-33). The complaint's evidence is structural, not functional.
  • Scope Question: The infringement analysis may turn on the definition of "penetration portion." Does the term, as used in the claim, require a specific gas-venting capability, as suggested by the specification, or can it be read more broadly to cover any void or opening in the sub-conductive layer, regardless of its intended or actual function?

’503 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an electronic device, comprising: an array substrate; a pad portion disposed on the array substrate; and an integrated circuit disposed on the pad portion and comprising a bump portion The accused BOE OLED Display is an electronic device containing an array substrate. Annotated images show a pad portion on the substrate and an integrated circuit with a bump portion disposed on the pad portion (Fig. 18, 19). ¶63-65 col. 4:20-42
the pad portion comprises a first sub-pad unit comprising an inclined first pad and a second sub-pad unit comprising an inclined second pad The pad portion is shown in annotated images (Fig. 20) to have sub-pad units containing pads that are inclined. ¶66 col. 5:5-9
the first pad and the second pad are inclined in different directions symmetrically about an imaginary line that divides the pad portion Annotated images (Fig. 21) show the inclined first and second pads arranged on opposite sides of a dashed "imaginary line" and allege they are symmetrical. ¶67 col. 5:10-18
the bump portion comprises a first sub-bump unit... and a second sub-bump unit... the first bump and the second bump are inclined in different directions symmetrically... The complaint alleges that because the pad portion is electrically connected to the bump portion, the bump portion must also have bumps that are inclined symmetrically to match the pad layout. This is supported by reference to Figure 21 showing the inclined pads. ¶69-70 '503 Patent, Abstract

Identified Points of Contention

  • Technical Question: The allegation of symmetrical pads and bumps relies on visual interpretation of micrographs (Compl. Fig. 21). A point of contention may be whether these structures are, in fact, geometrically symmetrical to the degree required by the claims, which could become a battle of expert measurements and analysis.
  • Scope Question: The case will likely require construction of the term "symmetrically". Does it imply a strict, mathematical mirror-image relationship, as the patent's language "mirror pair relationship" might suggest (ʼ503 Patent, col. 5:14-15), or a more general, functional symmetry that allows for manufacturing tolerances?

V. Key Claim Terms for Construction

Patent: '708 Patent

  • The Term: "penetration portion"
  • Context and Importance: This term appears to be the point of novelty for claim 1 of the ’708 patent. The definition of this term is critical, as it distinguishes the claimed structure from a simple conductive layer. Practitioners may focus on this term because its interpretation—whether purely structural or requiring a gas-venting function—will likely determine the outcome of the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader (Structural) Interpretation: The language of claim 1 itself requires only that the "sub-conductive layer on the insulating layer includes a penetration portion," without explicitly reciting a function (ʼ708 Patent, cl. 1). An argument could be made that any structural void or opening satisfies this limitation.
    • Evidence for a Narrower (Functional) Interpretation: The patent’s Abstract and Summary repeatedly tie the invention to solving the problem of discharging gas from the underlying organic layer (ʼ708 Patent, Abstract; col. 2:30-33). The specification states the annealing process "can serve to discharge the gas... that can be generated from the insulating layer... Thus, the insulation can be saved from being damaged by the gas" (ʼ708 Patent, col. 6:54-60). This suggests the term should be limited to structures capable of performing this function.

Patent: '503 Patent

  • The Term: "symmetrically about an imaginary line"
  • Context and Importance: This geometric limitation appears in claim 1 four times, defining the required relationship for both the pads on the substrate and the bumps on the IC. Infringement directly depends on whether the accused device's physical layout meets this precise spatial arrangement. Practitioners may focus on this term because disputes over geometric relationships are common and often dispositive.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that in the context of mass manufacturing of flexible electronics, "symmetrically" should be understood to include minor deviations and tolerances, and that a general visual symmetry is sufficient.
    • Evidence for a Narrower Interpretation: The patent specification describes the first and third sub-pad units as having a "'mirror pair' relationship" (ʼ503 Patent, col. 5:14-15), which implies a strict, geometric reflection. The figures consistently depict a highly regular and precise mirrored arrangement (e.g., ʼ503 Patent, Fig. 2), which could support a construction requiring strict mathematical symmetry.

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 sells the accused OLED displays to downstream product manufacturers (e.g., Nubia) with the knowledge and specific intent that they will be incorporated into end-products imported, used, and sold in the U.S. (Compl. ¶¶54-55, 73-74). The contributory infringement claims allege the displays are especially designed for infringement, constitute a material part of the patented inventions, and have no substantial non-infringing uses (Compl. ¶¶56, 75).

Willful Infringement

  • The complaint alleges willful infringement for all asserted patents. For the ’708, ’616, and ’483 patents, willfulness is primarily based on BOE’s alleged continued infringement after receiving Plaintiff's notice letter dated May 2, 2022 (Compl. ¶¶57, 102, 121). For the ’503 patent, willfulness is based on alleged knowledge of the patent and its infringement since at least the date of its issuance (Compl. ¶76).

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

  • A core issue will be one of claim scope and function: Can the term "penetration portion" in the ’708 patent be met by a purely structural feature shown in a micrograph, or will its construction require evidence that the accused feature performs the specific gas-venting function described throughout the patent's specification?
  • A second key issue will be one of geometric interpretation: Will terms such as "symmetrically" (in the ’503 patent) and the complex spatial relationships between pixels (in the ’616 patent) be construed to require strict, mathematical precision, or will a more functional interpretation that accommodates manufacturing tolerances be adopted by the court?
  • A central evidentiary question will be one of proof: Is the static, structural evidence presented in the complaint's images sufficient to prove infringement of claims that describe functional solutions (like correcting for misalignment in the ’503 patent) and complex, multi-layered structures, or will a more detailed, functional analysis of the accused devices be required?