DCT

2:25-cv-00438

Gamba Group Holdings LLC v. Samsung Electronics America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00438, E.D. Tex., 10/02/2025
  • 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 its "Flagship North Texas Campus" in Plano and a "Samsung Experience Store" in Frisco. Defendant Samsung Electronics Co., Ltd. is a foreign corporation alleged to have solicited business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy line of devices and associated "SmartThings Find" and "Samsung Find" services infringe three patents related to location-based services that use a network of radio-frequency beacons.
  • Technical Context: The technology at issue involves using short-range wireless beacons, such as Bluetooth or Wi-Fi, to enable location services in environments like building interiors or dense urban areas where GPS is often unreliable.
  • Key Procedural History: The complaint is a First Amended Complaint; no other significant procedural events such as prior litigation or post-grant proceedings are mentioned.

Case Timeline

Date Event
2005-04-12 Earliest Priority Date for ’507, ’684, and ’193 Patents
2017-06-06 U.S. Patent No. 9,674,684 Issues
2017-09-26 U.S. Patent No. 9,772,193 Issues
2018-05-01 U.S. Patent No. 9,961,507 Issues
2025-10-02 Complaint Filed

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

U.S. Patent No. 9,961,507 - Beacon Deployment Enabling Location Based Services (LBS) in an Urban or City Environment

  • Patent Identification: U.S. Patent No. 9,961,507, entitled “Beacon Deployment Enabling Location Based Services (LBS) in an Urban or City Environment,” issued May 1, 2018 (Compl. ¶18).

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of Global Positioning System (GPS) technology, which performs poorly or not at all indoors and in dense "urban canyons" due to signal obstruction, thereby limiting the effectiveness of location-based services (LBS) in these environments (’507 Patent, col. 1:45-68).
  • The Patented Solution: The invention proposes creating an infrastructure of radio-frequency (RF) beacons (e.g., Bluetooth or Wi-Fi) deployed in a given area. These beacons broadcast signals containing unique identifiers. A mobile device can detect a nearby beacon, decode its identifier, and use that information to determine its own location and activate location-specific services, effectively replacing unreliable satellite signals with a local, ground-based positioning network (’507 Patent, Abstract; col. 4:6-33).
  • Technical Importance: This approach provided a framework for extending valuable location-based navigation, tracking, and information services into indoor and other GPS-denied environments, a significant area of market demand (’507 Patent, col. 2:65-col. 3:2).

Key Claims at a Glance

  • The complaint asserts at least independent claim 57 (Compl. ¶43).
  • Claim 57 is a method claim comprising the essential elements of:
    • Deploying a series of beacons in a localized geographic area within an urban environment.
    • Encoding "Location Based Service (LBS) informative data" into an identification portion of a beacon signal.
    • Broadcasting the beacon signal from the beacons.
    • Scanning for, detecting, and receiving the beacon signal using a mobile device.
    • Decoding the signal to obtain the LBS informative data.
    • Activating an LBS based on the received LBS informative data.
  • The complaint reserves the right to assert additional claims (Compl. ¶43).

U.S. Patent No. 9,674,684 - Beacon Deployment for Use with Location Based Services (LBS)

  • Patent Identification: U.S. Patent No. 9,674,684, entitled “Beacon Deployment for Use with Location Based Services (LBS),” issued June 6, 2017 (Compl. ¶19).

The Invention Explained

  • Problem Addressed: Similar to the ’507 Patent, the background section describes the inadequacy of GPS for indoor applications and the resulting need for a cost-effective system that can provide location services inside buildings or in dense urban centers (’684 Patent, col. 1:41-col. 2:2).
  • The Patented Solution: The patent describes deploying RF tags or beacons that broadcast a unique identification using a unidirectional signal (e.g., Bluetooth). A mobile device, such as a cell phone, receives this signal, and an application on the device decodes the identification to determine the user's location and provide services like indoor navigation, as illustrated by the deployment map in Figure 2 (’684 Patent, Abstract; col. 4:6-33; Fig. 2).
  • Technical Importance: The invention enabled precise, interactive indoor guidance for users in complex commercial spaces like shopping malls or department stores where traditional navigation systems fail (’684 Patent, col. 4:44-56).

Key Claims at a Glance

  • The complaint asserts at least independent claim 52 (Compl. ¶59).
  • Claim 52 is a method claim comprising the essential elements of:
    • Deploying at least one beacon adapted to transmit a unidirectional Bluetooth or Wi-Fi signal.
    • Encoding beacon information into an identification segment for unidirectional transmission to a mobile device.
    • Broadcasting the beacon signal.
    • Scanning for, receiving, and decoding the beacon information with the mobile device.
    • Acting upon the decoded information in accordance with either conveying the information to a user or initiating an LBS.
  • The complaint reserves the right to assert additional claims (Compl. ¶59).

U.S. Patent No. 9,772,193 - Vehicle Beacon and Method of Use

  • Patent Identification: U.S. Patent No. 9,772,193, entitled "Vehicle Beacon and Method of Use," issued September 26, 2017 (Compl. ¶20).

Technology Synopsis

This patent describes installing an RF beacon within a vehicle to enable vehicle-specific location services. It addresses use cases such as a "return to parking" feature, which helps a user navigate back to their parked car, and using the vehicle's beacon to create a geofence that can trigger reminders or other actions when a user moves away from the vehicle (’193 Patent, Abstract).

Asserted Claims

The complaint asserts at least independent claim 12 (Compl. ¶75).

Accused Features

The complaint accuses Samsung's location services of infringement for functionalities such as locating "a car in which a phone has been traveling" via the Samsung Find and SmartThings Find applications (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as Samsung's Galaxy line of smartphones (e.g., Galaxy S25), tablets, smartwatches, and earbuds; Samsung SmartTags; and the associated "SmartThings Find" and "Samsung Find" applications and services, which include an "offline finding" feature (Compl. ¶¶4, 25).

Functionality and Market Context

The complaint alleges that the Accused Products facilitate location-based services and tracking. A central accused functionality is the "offline finding" feature, which reportedly allows a user's lost device, even one without an internet connection, to be located by other nearby Samsung Galaxy devices. These other devices are alleged to detect a signal from the lost item and anonymously relay its location to Samsung's servers, making the location visible to the owner through the SmartThings Find application (Compl. ¶¶9, 25). A screenshot in the complaint shows marketing language stating, "Find your Galaxy phone, tablet, watch, and other devices with SmartThings Find" (Compl. p. 9). Another visual depicts the multi-device compatibility of the "Samsung Find" service (Compl. p. 10).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (D, E, and F) that were not attached to the filed document, precluding a detailed tabular analysis (Compl. ¶¶43, 59, 75). The narrative infringement theory for each patent is summarized below.

'507 and '684 Patent Infringement Allegations

The complaint's infringement theory appears to map the elements of the patented methods onto the functionality of Samsung's "offline finding" feature (Compl. ¶¶25-26). In this asserted theory, the large network of third-party Samsung Galaxy devices in public circulation collectively functions as the claimed "series of deployed beacons." A user's lost device (e.g., a SmartTag or smartphone) is alleged to be the source of the "beacon signal," broadcasting a unique identifier via Bluetooth Low Energy (BLE). The nearby third-party Galaxy devices perform the "scanning," "detecting," and "receiving" steps. Upon detecting the lost device's signal, a third-party device "decodes" the identifier and "activates" the Location Based Service by relaying the location data through Samsung's servers back to the owner. The unidirectional nature of BLE broadcast packets is what may be alleged to meet the "unidirectional" signal limitation of the ’684 Patent.

Identified Points of Contention

  • Scope Questions: A primary issue may be whether a dynamic, crowd-sourced network of user-owned mobile devices constitutes a "series of deployed beacons" as this term is used in the patents. The defendants may argue that the patents contemplate a static, deliberately installed infrastructure, such as beacons placed in a shopping mall by a single entity, not an ad-hoc network of unaffiliated user devices.
  • Technical Questions: A factual question for the court will be whether the technical operation of Samsung's "offline finding" network performs the specific functions required by the claims. For instance, what evidence does the complaint provide that a third-party device detecting a lost phone's BLE signal performs the claimed step of "activating" a "Location Based Service," as opposed to simply relaying a data point?

V. Key Claim Terms for Construction

"deploying a series of beacons" (asserted in ’507 and ’684 Patents)

  • Context and Importance: The definition of this term appears central to the dispute. Practitioners may focus on whether "deploying" requires intentional, systematic placement of a fixed infrastructure by a service provider, or if it can be construed to cover the creation of an ad-hoc network formed by the incidental public presence of millions of user-owned devices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstracts refer generally to "An infrastructure of...beacons deployed within...an urban environment," which does not explicitly restrict the manner of deployment or the nature of the beacons (’507 Patent, Abstract). This language could support a reading focused on the functional result of having an operational beacon network in place.
    • Evidence for a Narrower Interpretation: The patent specifications consistently provide examples and figures depicting planned, static installations. For example, Figure 2 of the ’684 Patent shows beacons ("B") deliberately placed on a floor map of an indoor facility, suggesting an engineered and fixed infrastructure (’684 Patent, Fig. 2; col. 4:37-43).

"activating at least one Location Based Service (LBS)" (asserted in ’507 Patent)

  • Context and Importance: This term's construction will be critical for determining if the accused system's function meets the claim requirements. The question is whether the relay of a lost device's location constitutes "activating" an "LBS" in the sense contemplated by the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patents broadly describe LBS as "rapidly expanding" and include a wide range of applications, suggesting the term is not narrowly limited (’684 Patent, col. 1:41-42). A service that provides the location of an object is, by definition, a location-based service.
    • Evidence for a Narrower Interpretation: The specification provides numerous examples of LBS that are more complex than simple object-finding, such as providing navigation, triggering automation, or delivering real estate information (’684 Patent, Abstract). Defendants may argue that "activating" an LBS requires initiating one of these more substantive services, not just reporting a coordinate.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all asserted patents. The factual basis for inducement is that Samsung allegedly provides customers with the Accused Products and instructs them, through promotional materials and user manuals, to use features like "offline finding" in a manner that directly infringes the patented methods (Compl. ¶¶30-31, 37).

Willful Infringement

Willfulness is alleged for all patents, based on Samsung's purported knowledge of its infringing activities (Compl. ¶¶35, 42). The complaint also pleads willful blindness, alleging Samsung knew of a high probability of infringement but took "deliberate actions to avoid learning of these facts" (Compl. ¶38).

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

The resolution of this case may turn on the following central questions:

  1. A core issue will be one of definitional scope: can the term "deployed beacons," rooted in patent examples of static, planned infrastructure, be construed to cover the dynamic, crowd-sourced network of user-owned mobile devices that constitutes Samsung's "offline finding" system?
  2. A key evidentiary question will be one of functional operation: does the accused system—where one user's device detects another's lost device and relays its location to a server—perform the specific, multi-step method of "activating" a "Location Based Service" as required by the claims, or is there a fundamental mismatch in technical function?
  3. A central issue for indirect infringement will be intent: assuming users directly infringe, what evidence can Plaintiff establish to demonstrate that Samsung provided its device-finding technology with the specific knowledge and intent to encourage infringement of the Gamba patents?