DCT
2:25-cv-00486
MessageLoud Inc v. Samsung Electronics Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: MessageLoud, Inc. (Delaware)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Bochner PLLC
- Case Identification: MessageLoud, Inc. v. Samsung Electronics Co., Ltd., et al., 2:25-cv-00486, E.D. Tex., 05/05/2025
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. due to its maintenance of a "regular and established place of business" in Plano, Texas, within the district.
- Core Dispute: Plaintiff alleges that a wide range of Defendant’s smartphones and tablets infringes five patents related to methods for automatically reading aloud incoming messages from various sources without user interaction.
- Technical Context: The technology addresses hands-free communication on mobile devices, aiming to reduce distractions for users engaged in activities such as driving by converting text-based messages into speech.
- Key Procedural History: The complaint alleges Defendant was on notice of the patents-in-suit since at least April 4, 2024, a date preceding the filing of the complaint. It also notes that Defendant has not contested personal jurisdiction or venue in other recent patent infringement actions in the Eastern District of Texas.
Case Timeline
| Date | Event |
|---|---|
| 2013-01-01 | MessageLoud founded by Garin Toren |
| 2014-11-21 | Earliest Priority Date for all Patents-in-Suit |
| 2017-03-07 | U.S. Patent No. 9,591,117 Issued |
| 2018-10-23 | U.S. Patent No. 10,110,725 Issued |
| 2019-04-30 | U.S. Patent No. 10,277,728 Issued |
| 2019-12-24 | U.S. Patent No. 10,516,775 Issued |
| 2022-04-26 | U.S. Patent No. 11,316,964 Issued |
| 2024-04-04 | Alleged date of pre-suit notice to Defendant |
| 2025-05-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,591,117 - Method and System For Communication
Issued March 7, 2017
The Invention Explained
- Problem Addressed: The complaint describes the technical problem as the "inherent conflict between the immediate demands of smartphone notifications and the necessity of attentive driving," particularly at a time when automated in-car message reading was limited (Compl. ¶28). The technology aims to provide a solution for users who cannot safely or conveniently view their device screens while engaged in activities like driving, working, or exercising (Compl. ¶29).
- The Patented Solution: The invention is a computer-implemented method that automatically detects incoming messages from at least two different sources (e.g., text message, email, messenger app), places them into a "single queue to be read aloud in order of receipt time regardless of message type," and then reads the sender's identity and message body aloud without user input (Compl. ¶37). The method provides the user a time window to stop the reading via a "memorized gesture" on the touch screen; if no such action is taken, the reading proceeds automatically (Compl. ¶37(e)-(f)).
- Technical Importance: The complaint frames the invention as a "pioneering" and "innovative" application that addressed the safety risks of distracted driving before such laws were widespread (Compl. ¶28).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶38).
- Essential elements of claim 1 include:
- Determining without user input that at least two different types of messages (text, email, messenger) have arrived.
- Analyzing the content of the message without user input.
- Placing the messages in a single queue to be read aloud in order of receipt time, regardless of type.
- Informing the user of the sender's identity by reading it aloud, without user input.
- Allowing time for an affirmative action, limited to a memorized gesture on the touch screen, to stop the reading.
- If no action is taken, reading the body (and subject, for email) aloud.
- Not displaying the message on the screen if the user is driving a vehicle.
U.S. Patent No. 10,110,725 - Method and System For Communication
Issued October 23, 2018
The Invention Explained
- Problem Addressed: The patent's background section identifies the hazard of using a mobile phone for texting or communication while driving or engaged in other activities that make it difficult to access the device visually (’725 Patent, col. 1:17-30). It distinguishes itself from prior art that, even in "limited-distraction" modes, still relies on "substantial input from the user" (’725 Patent, col. 1:36-42).
- The Patented Solution: As described in the abstract and detailed description, the invention provides a method for automatically announcing and reading aloud various message types (email, text, etc.) without requiring user input (’725 Patent, Abstract). A core component is the placement of all incoming messages into a "single queue" to be read to the user in the order they were received, creating a unified, hands-free notification stream (’725 Patent, Fig. 24). The system is designed to be operated via gestures while driving, allowing a user to manage messages without looking at the screen (’725 Patent, Abstract).
- Technical Importance: The patent addresses a stated "need in the art to allow a person to receive emails and other messages while the person is engaged in an activity that limits the person's ability to read" them (’725 Patent, col. 1:54-58).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶55).
- Essential elements of claim 1 include:
- Determining without user input that two or more different types of messages have been received.
- Analyzing the message content without user input.
- Placing the messages in a single queue to be read aloud chronologically, regardless of type.
- Informing the user of the sender's identity by reading it aloud, without user input.
- Allowing time for an affirmative action, limited to a gesture on the touch screen, to stop the reading.
- Based on not receiving the input, reading the body of the message aloud.
U.S. Patent No. 10,277,728 - Method and System For Communication
Issued April 30, 2019
- Technology Synopsis: This patent, from the same family, describes a computer-implemented method to automatically detect, queue, and read aloud messages from disparate sources (email, text, messenger apps) without user input. The technology is designed for scenarios where a user's visual attention is occupied, such as driving (Compl. ¶¶29, 70).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶71).
- Accused Features: The complaint alleges that Samsung products supporting features that read notifications aloud without user input infringe this patent (Compl. ¶¶39, 71).
U.S. Patent No. 10,516,775 - Method and System For Communication
Issued December 24, 2019
- Technology Synopsis: This patent covers a method for automatically processing incoming messages by determining their arrival, analyzing their content, placing them in a queue, and reading the sender and body aloud without user input. The claim differs slightly from earlier patents by reciting "one or more different types" of messages rather than two or more (Compl. ¶¶29, 86).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶87).
- Accused Features: The complaint accuses Samsung's features for reading notifications aloud without user input of infringement (Compl. ¶¶39, 87).
U.S. Patent No. 11,316,964 - Method and System For Communication
Issued April 26, 2022
- Technology Synopsis: This patent describes a method for hands-free message consumption, including steps for automatically determining message arrival, analyzing content, queuing messages to be read aloud, and vocally informing the user of the sender's identity. This patent adds a claim element of "allowing the user an option to stop the reading aloud" (Compl. ¶¶29, 102).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶103).
- Accused Features: The complaint targets Samsung's features that read notifications aloud without user input (Compl. ¶¶39, 103).
III. The Accused Instrumentality
Product Identification
The complaint identifies a broad range of "Samsung products that support or enable features that read notifications aloud without user input" (Compl. ¶39). This includes numerous models from the Galaxy S, Galaxy Z Fold/Flip, Galaxy Note, and Galaxy Tab series of devices (Compl. ¶39). The infringement is alleged to occur when these devices are used with "‘Galaxy Buds’ headphones or earbuds, or in-vehicle devices configured with Android Auto" (Compl. ¶39).
Functionality and Market Context
The accused functionality is the software feature on the listed Samsung devices that automatically reads incoming notifications aloud to the user (Compl. ¶39). The complaint does not provide specific technical details or screenshots illustrating the operation of this feature. The extensive list of accused products, spanning from the Galaxy S10 line to the future "Galaxy S25," suggests the plaintiff views the accused functionality as a standard, widely deployed feature across Defendant's mobile product ecosystem (Compl. ¶39). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references claim chart exhibits (Exhibits F-J) that were not included with the filed complaint; therefore, the following summaries are based on the narrative allegations and the quoted claim language for the lead patents.
’117 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) determining without any input by a user that a text message, a message from a messenger application, or an email has arrived... | The complaint alleges the Accused Instrumentalities’ software automatically detects the arrival of various message types. | ¶37, ¶39 | Not Provided |
| b) analyzing without any input by the user a content of the text message, the message from the messenger application, or the email | The complaint alleges the Accused Instrumentalities’ software automatically parses message content to identify elements like the sender and body. | ¶37, ¶39 | Not Provided |
| c) placing the email, the message from the messenger application, or the text message in a single queue to be read aloud in order of receipt time regardless of message type... | The complaint alleges the Accused Instrumentalities’ software architecture queues notifications from different sources chronologically for sequential audio playback. | ¶37, ¶39 | Not Provided |
| d) informing the user without any input by the user that the...message...has arrived from a sender by reading at least aloud identity of the sender | The accused feature allegedly reads the sender's name or identifier aloud upon message arrival. | ¶37, ¶39 | Not Provided |
| e) allowing the user time to take an affirmative action to stop reading...wherein the affirmative action is limited to a memorized gesture performed on the touch screen | The complaint alleges the system provides an opportunity for user intervention via touch screen gesture before or during the audio playback. | ¶37, ¶39 | Not Provided |
| f) in accordance with not receiving an input...reading aloud the body of the text message... | The accused feature allegedly proceeds to read the message body aloud by default if the user does not intervene. | ¶37, ¶39 | Not Provided |
’725 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) determining without any input by a user that two or more different types of messages...have been received | The complaint alleges the Accused Instrumentalities’ software automatically detects the arrival of various message types. | ¶54, ¶55 | col. 2:60-65 |
| b) analyzing without any input by the user a content of the received text message... | The complaint alleges the Accused Instrumentalities’ software automatically parses message content to identify elements like the sender and body. | ¶54, ¶55 | col. 3:1-14 |
| c) placing the received email...in a single queue to be read aloud in order of receipt time regardless of message type... | The complaint alleges the Accused Instrumentalities’ software architecture queues notifications from different sources chronologically for sequential audio playback. | ¶54, ¶55 | col. 3:55-63 |
| d) informing the user without any input by the user that the received text message...has been received from a sender by reading aloud at least an identity of the sender | The accused feature allegedly reads the sender's name or identifier aloud upon message arrival. | ¶54, ¶55 | col. 3:9-14 |
| e) allowing the user a time to take an affirmative action to stop reading a body of the received text message...wherein the affirmative action is limited to a gesture performed on the touch screen | The complaint alleges the system provides an opportunity for user intervention via touch screen gesture before or during the audio playback. | ¶54, ¶55 | col. 4:45-51 |
| f) based on not receiving an input corresponding to the affirmative action from the user, reading aloud the body of the received text message... | The accused feature allegedly proceeds to read the message body aloud by default if the user does not intervene. | ¶54, ¶55 | col. 3:32-40 |
Identified Points of Contention
- Scope Questions: The claims in the ’117 and ’725 Patents require that the "affirmative action" to stop the reading be "limited to a...gesture performed on the touch screen" (Compl. ¶37(e), ¶54(e)). A central question may be whether the accused Samsung features can be stopped by other means (e.g., a voice command to a digital assistant, a physical button on connected headphones or earbuds). If other means exist, it raises the question of whether the action is truly "limited to" a gesture as the claim language requires.
- Technical Questions: Claim 1(c) of both lead patents requires placing messages from different sources into a "single queue" to be read in chronological order regardless of message type (Compl. ¶37(c), ¶54(c)). The complaint does not provide evidence regarding the software architecture of the accused feature. A key technical question will be whether the accused products actually use a single, type-agnostic chronological queue, or if they employ a different notification handling architecture that may not map to this specific claim limitation.
V. Key Claim Terms for Construction
"without any input by a user"
- Context and Importance: This phrase appears in multiple limitations of the asserted claims and is central to the invention's automated, hands-free character (Compl. ¶37, ¶54). The dispute may focus on whether initial setup or configuration of the read-aloud feature by a user constitutes "input" that would preclude infringement of the steps that follow automatically.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Language in the patent focuses on the context of a user already "engaged in an activity" (e.g., driving) when the message arrives, suggesting "without any input" refers to the moment of message receipt, not a one-time setup of the feature (’725 Patent, col. 2:60-65).
- Evidence for a Narrower Interpretation: The specification discloses different user-selectable modes like "Drive Mode," "Work Mode," and "Active Mode" (’725 Patent, Fig. 1, Fig. 9). A defendant may argue that the user's initial selection of such a mode constitutes "input by a user" that precedes and enables the automated functionality, thus negating the "without any input" requirement.
"affirmative action is limited to a...gesture performed on the touch screen"
- Context and Importance: This limitation from claim 1(e) of the ’117 and ’725 Patents is highly specific and could be a focal point of non-infringement arguments. Practitioners may focus on this term because if the accused products allow a user to stop the audio playback using anything other than a touch screen gesture (e.g., voice command, headphone button), this limitation may not be met.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification depicts a simple "tap" as a gesture to pause or interact with the system (’725 Patent, Fig. 3, 472; Fig. 4). A plaintiff could argue that "gesture" should be construed broadly to include simple interactions like tapping, not just complex swipes.
- Evidence for a Narrower Interpretation: The term "limited to" suggests exclusivity. A defendant could argue that the availability of any non-gesture-based method for stopping the read-aloud function—such as a voice command or a button on Galaxy Buds—means the available actions are not "limited to" a gesture, thereby avoiding infringement of this element.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Samsung provides "operating manuals, technical information, and other instructions" that direct users on how to configure and use the accused features (Compl. ¶¶43, 59, 75, 91, 107). It also pleads contributory infringement, alleging the accused software components are "especially designed or adapted to operate in a manner that infringes" and are not "staple article[s] of commerce suitable for substantial non-infringing use" (Compl. ¶¶45, 61, 77, 93, 109).
Willful Infringement
The complaint alleges willful infringement based on Defendant's knowledge of the patents (Compl. ¶2). For each specific count, knowledge is tied to "at least the service of this Complaint," supporting a theory of post-filing willfulness (Compl. ¶¶42, 58, 74, 90, 106). However, the complaint also makes a general allegation that Samsung has been "on notice of the Patents-in-Suit...since at least, April 4, 2024," which could form the basis for a pre-suit willfulness claim if substantiated (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the phrase "limited to a...gesture," which appears in the asserted claims, be met by an accused product that offers multiple ways to stop an audio notification, such as voice commands or physical buttons on connected earbuds, in addition to a touch screen interaction?
- A key evidentiary question will be one of technical implementation: does the accused "read notifications aloud" feature in Samsung's software architecture operate using a "single queue" that processes messages from different applications chronologically and regardless of type, as recited in the claims, or does it utilize a different technical method for handling notifications?
- A third central question will concern willfulness: what specific evidence supports the allegation of pre-suit notice as of April 2024, and does this notice apply to all five patents-in-suit, some of which were issued years apart? The answer will be critical for determining the viability of pre-suit willful infringement and the potential for enhanced damages.