Bison Patent Licensing LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Bison Patent Licensing LLC (Georgia)
  • Defendant: Samsung Electronics Co., Ltd (Republic of Korea) & Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:25-cv-00448, E.D. Tex., 04/29/2025
• Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. because it has a regular and established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s smartphones, network solutions, and smart televisions infringe a portfolio of eight patents related to video processing, mobile device location, wireless communication architecture, and digital rights management.
• Technical Context: The asserted patents cover a broad range of technologies central to modern consumer electronics, including video compression, location-based services, and secure content delivery, which are foundational to the functionality of smartphones and smart devices.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

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

U.S. Patent No. 7,391,808 - "System and Method for Upgrading Processing Capabilities of a Media Center", Issued June 24, 2008

The Invention Explained

• Problem Addressed: The patent’s background section describes the economic challenge faced by multi-system operators (MSOs) when rapid advancements in video compression standards render their large installed base of set-top boxes (STBs) obsolete long before the end of their physical useful life (’808 Patent, col. 1:24-30). Replacing these STBs on a massive scale is cost-prohibitive (’808 Patent, col. 1:50-55).
• The Patented Solution: The invention discloses an external "adaptive module" that connects to an existing STB to handle video encoded with newer compression standards that the STB cannot process natively (’808 Patent, Abstract). The module receives the incompatible video stream, transcodes it into a format the STB can decode (e.g., MPEG-2), and streams it back to the STB for display (’808 Patent, col. 3:1-6). This architecture also allows the module to re-compress video files already stored on the STB's hard drive into a more efficient format to increase storage capacity (’808 Patent, col. 3:6-19).
• Technical Importance: This technology offered a modular, cost-effective upgrade path that extended the functional lifetime of deployed STBs, allowing service providers to adopt new compression standards without incurring the expense of replacing entire subscriber terminals (Compl. ¶10; ’808 Patent, col. 2:48-55).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-5 and 7 (Compl. ¶33).
• Independent Claim 1 recites a system comprising:
  • a client terminal interface configured to stream video data encoded according to a first compression standard;
  • an adaptive module configured to transcode the video data to a second compression standard and stream it back to the interface;
  • wherein the adaptive module is also configured to perform graphics processing based on user input and encode the processed video data; and
  • a client terminal processor configured to process the transcoded video data.

U.S. Patent No. 8,160,609 - "System and Method for Multiple Range Estimation Location", Issued April 17, 2012

The Invention Explained

• Problem Addressed: The patent’s background describes how location estimation techniques that rely on signal arrival times are often compromised by signal multipath—reflections of the signal off objects between the transmitter and receiver—which degrades accuracy (’609 Patent, col. 1:12-20).
• The Patented Solution: The invention proposes a location method based on "Range Rings." The system first determines the precise time a signal is transmitted from a mobile station by observing both downlink signals from a serving base station to the mobile device and uplink signals from the mobile device itself, using a functional timing relationship between them (’609 Patent, col. 2:1-10). Once this transmission time is known, the direct distance (range) to multiple geographically dispersed receiving stations can be calculated. The intersection of these calculated ranges, or "rings," provides the location estimate, a method claimed to be more robust against multipath and ambiguity than traditional Time Difference of Arrival (TDOA) techniques (’609 Patent, Abstract).
• Technical Importance: The invention aimed to provide a more accurate method for estimating the location of a mobile device, a critical capability for both emergency services (E911) and commercial location-based applications, by mitigating errors from multipath propagation (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts at least independent claim 31 (Compl. ¶38).
• Independent Claim 31 recites a system comprising:
  • a first monitoring unit at a known location for receiving transmissions from a mobile device and a base station;
  • the unit having a processor programmed to: (i) determine the transmission time of a first signal from the base station to the mobile device; (ii) identify a timing parameter in that first signal; (iii) determine the receipt time of a second signal from the mobile device; and (iv) determine the range to the mobile device as a function of these three inputs.

U.S. Patent No. 8,331,956

• Patent Identification: U.S. Patent No. 8,331,956, "System and Method of UMTS UE Location Using Uplink Dedicated Physical Control Channel and Downlink Synchronization Channel", Issued December 11, 2012 (Compl. ¶15).
• Technology Synopsis: The patent addresses the need for location-based services for mobile phone users by providing a method for estimating a wireless device's location (Compl. ¶¶16, 44). The technology appears to relate to analyzing specific uplink and downlink channels within the UMTS cellular standard to derive location information (’956 Patent, Title; Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶43).
• Accused Features: The complaint accuses Samsung Galaxy smartphones that support the 802.11mc standard (Compl. ¶43).

U.S. Patent No. 8,489,122

• Patent Identification: U.S. Patent No. 8,489,122, "System and Method for Total Flight Time Ratio Pattern Matching", Issued July 16, 2013 (Compl. ¶18).
• Technology Synopsis: The patent discloses a technology for determining the location of a mobile device while combating multipath effects (Compl. ¶19). The invention involves calculating a "total flight time" for signals and using ratio pattern matching to estimate location (’122 Patent, Title; Abstract).
• Asserted Claims: At least claim 15 is asserted (Compl. ¶50).
• Accused Features: The complaint accuses Samsung Galaxy smartphones that support the 802.11mc standard (Compl. ¶50).

U.S. Patent No. 8,576,781

• Patent Identification: U.S. Patent No. 8,576,781, "Femtocell Architecture in Support of Voice and Data Communications", Issued November 5, 2013 (Compl. ¶21).
• Technology Synopsis: The patent addresses a need for improved data handling efficiency and performance in wireless communications (Compl. ¶22). It discloses a femtocell architecture that integrates with an I-WLAN architecture to handle voice and data traffic differently, enhancing data efficiency while using existing network components for voice (’781 Patent, Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶57).
• Accused Features: The complaint accuses Defendant’s "LTE network solutions" (Compl. ¶57).

U.S. Patent No. 9,693,030

• Patent Identification: U.S. Patent No. 9,693,030, "Generating Alerts Based Upon Detector Outputs", Issued June 27, 2017 (Compl. ¶24).
• Technology Synopsis: The patent describes improved video processing that permits an enhanced viewing experience, such as generating alerts based on the detection of on-screen data (Compl. ¶25; ’030 Patent, Abstract). The system determines textual data from video content and monitors it for a "triggering item" to generate an alert (’030 Patent, Abstract).
• Asserted Claims: Claims 1, 2, 5, 9, and 11 are asserted (Compl. ¶62).
• Accused Features: The complaint accuses Samsung Galaxy smartphones with tracking auto-focus functionality (Compl. ¶62).

U.S. Patent No. 9,693,333

• Patent Identification: U.S. Patent No. 9,693,333, "System and Method for Location Boosting Using Proximity Information", Issued June 27, 2017 (Compl. ¶27).
• Technology Synopsis: The patent claims to provide improved techniques for locating a mobile device within a communication network, particularly in challenging environments like urban or indoor settings (Compl. ¶28). The method involves using proximity information among a set of mobile devices to "boost" the available location measurement data (’333 Patent, Abstract).
• Asserted Claims: Claims 20, 24, and 25 are asserted (Compl. ¶69).
• Accused Features: The complaint accuses the "Samsung SmartThings Find network" (Compl. ¶69).

U.S. Patent No. 10,162,944

• Patent Identification: U.S. Patent No. 10,162,944, "Library Style Media DRM APIs in a Hosted Architecture", Issued December 25, 2018 (Compl. ¶30).
• Technology Synopsis: The patent relates to digital rights management (DRM) technology that uses client and server "library components" accessed through APIs by hosting applications (Compl. ¶31; ’944 Patent, Abstract). A key feature is that a server-side application can proactively issue licenses to a client in addition to those specifically requested, facilitating license prefetching (’944 Patent, col. 2:1-3; Compl. ¶31).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶74).
• Accused Features: The complaint accuses Samsung smart televisions (Compl. ¶74).

III. The Accused Instrumentality

• Product Identification: The complaint accuses a range of Samsung products, primarily:
  • Samsung Galaxy smartphones, specifically identifying those with the "Gallery video editor" and those "supporting 802.11mc" (Compl. ¶¶33, 38).
  • Samsung "LTE network solutions" (Compl. ¶57).
  • The "Samsung SmartThings Find network" (Compl. ¶69).
  • Samsung smart televisions (Compl. ¶74).
• Functionality and Market Context: The complaint alleges infringement based on specific functionalities within these product categories. For smartphones, the accused functionalities include video editing, location services via the 802.11mc Wi-Fi standard, and tracking auto-focus in the camera (Compl. ¶¶33, 38, 62). For network equipment, the accused functionality relates to the architecture of LTE solutions (Compl. ¶57). The SmartThings Find network is accused based on its function of locating devices (Compl. ¶69), and Samsung smart televisions are accused based on their digital rights management systems (Compl. ¶74). The complaint provides minimal detail regarding the market context of these products, other than what is publicly known about Samsung's significant presence in the consumer electronics market.
  No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim chart exhibits for each asserted patent but does not attach them. The infringement theories are therefore summarized based on the complaint's narrative allegations.

• ’808 Patent Infringement Allegations

  • Narrative Summary: The complaint alleges that the Gallery video editor in Samsung Galaxy smartphones directly infringes at least claim 1 of the ’808 Patent (Compl. ¶33). While the complaint defers all technical detail to the unattached Exhibit I, the theory presumably maps the software functions of the video editor to the claimed system of a "client terminal interface," an "adaptive module," and a "client terminal processor." The act of editing a video, such as changing its format or resolution, is likely alleged to constitute the claimed "transcoding" and "graphics processing."
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether a software application integrated within a smartphone (the Gallery video editor) can constitute the "adaptive module" described in a patent whose specification is focused on external hardware boxes connected to set-top boxes (’808 Patent, Fig. 1; col. 3:1-6). The interpretation of "module" and "client terminal" will be critical.
    • Technical Questions: The complaint does not specify what technical operation within the Gallery video editor corresponds to "transcoding... from a first compression standard to a second compression standard" as recited in claim 1. It also raises the question of what evidence will be presented to show that the editor performs the separate claimed function of "graphics processing... based on the user input" in a manner that maps to the claim language.

• ’609 Patent Infringement Allegations

  • Narrative Summary: The complaint alleges that Samsung Galaxy smartphones supporting the 802.11mc Wi-Fi standard infringe at least claim 31 of the ’609 Patent (Compl. ¶38). The 802.11mc standard enables precise indoor positioning by measuring Wi-Fi Round-Trip-Time (RTT). The infringement theory, contained in the unattached Exhibit J, likely contends that the RTT measurement process meets the claim limitations of determining signal transmission and receipt times using a "timing parameter" to calculate a range.
  • Identified Points of Contention:
    • Scope Questions: A key dispute may arise over whether the protocols and signals used in the 802.11mc Wi-Fi standard fall within the scope of claim terms rooted in the patent's description of cellular (GSM) technology. For instance, can a Wi-Fi RTT process be said to use a "timing parameter transmitted in the first signal" in the same way the patent describes a cellular "Timing Advance (TA) parameter"? (’609 Patent, col. 2:40-43).
    • Technical Questions: The complaint does not identify which specific transmissions in the 802.11mc protocol constitute the claimed "first signal" from a base station and "second signal" from the mobile device. The analysis will depend on whether the technical operation of Wi-Fi RTT can be functionally mapped onto the distinct steps recited in claim 31.

V. Key Claim Terms for Construction

• ’808 Patent, Claim 1

  • The Term: "adaptive module"
  • Context and Importance: The viability of the infringement allegation against the software-based Gallery video editor hinges on this term's construction. Practitioners may focus on this term because Defendant is likely to argue that the patent’s specification and figures limit the term to an external hardware device, whereas Plaintiff may argue for a broader interpretation that covers software components.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 itself does not specify that the module must be hardware or external to the "client terminal." The term "module" is commonly used in the art to refer to both hardware and software components.
    • Evidence for a Narrower Interpretation: The detailed description consistently portrays the invention as a physical "module 300" separate from the "STB 200" and connected via a physical port like USB2.0 or P1394 (’808 Patent, Fig. 1; col. 3:39-42). The abstract describes it as an "adaptive module that transcodes the video data into a format compatible with the processing capabilities of the client terminal," suggesting a role of bridging an incompatibility between external data and an existing terminal.

• ’609 Patent, Claim 31

  • The Term: "timing parameter"
  • Context and Importance: This term is central to determining whether the accused 802.11mc Wi-Fi protocol infringes. Practitioners may focus on this term because its construction will likely determine whether the claim is limited to the specific cellular mechanisms described in the patent or can be read more broadly onto different wireless standards.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim recites the term without further qualification: "a timing parameter transmitted in the first signal." This language does not, on its face, restrict the type of parameter or the protocol in which it is used.
    • Evidence for a Narrower Interpretation: The specification provides a specific example, stating, "The parameter P is the Timing Advance (TA) parameter and the function f(P) is given by f(TA)=3.6928TA-3T" in the context of the GSM cellular protocol (’609 Patent, col. 2:40-43). A defendant may argue this context limits the scope of "timing parameter" to cellular timing advance signals or their close equivalents.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for seven of the eight patents asserted (’808, ’609, ’956, ’122, ’781, ’030, ’944). The allegations are based on Defendant allegedly selling the accused products and "distributing product literature or videos inducing end users" to use them in an infringing manner (e.g., Compl. ¶34, ¶39, ¶45). These allegations are predicated on knowledge acquired, at the latest, upon service of the complaint.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or seek enhanced damages on that basis.

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

• A core issue will be one of definitional scope: Can claim terms rooted in the context of older technologies, such as the "adaptive module" for set-top boxes or the cellular "timing parameter," be construed broadly enough to cover the accused software features and modern Wi-Fi protocols in Samsung's products? The outcome of claim construction for such terms may be dispositive for several of the asserted patents.
• A key evidentiary question will be one of technical mapping: Given the breadth of the asserted patent portfolio and the range of accused technologies, will the plaintiff be able to provide sufficient factual and technical evidence to connect the specific operation of each accused product—from video editors to tracking auto-focus and DRM systems—to the precise limitations of the asserted claims, especially where the complaint defers all technical specifics to unprovided exhibits?