DCT
2:25-cv-00562
Sookbox LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sookbox LLC (Delaware)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 2:25-cv-00562, E.D. Tex., 05/21/2025
- Venue Allegations: Venue is alleged to be proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. based on its regular and established places of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s SmartThings platform and its ecosystem of smart TVs and mobile devices infringe two patents related to managing, distributing, and controlling media and functions across a network of devices.
- Technical Context: The technology at issue resides in the Internet of Things (IoT) and smart home sector, focusing on methods for orchestrating control and content streaming between a central host, mobile control devices, and various output peripherals.
- Key Procedural History: The complaint alleges an extensive pre-suit history, including meetings at CES in 2013 and 2014 and subsequent presentations where Plaintiff’s founders allegedly disclosed the patented technology and the existence of their pending patent applications to Samsung. These allegations form the basis of the willfulness claims. The complaint also notes that Samsung acquired two of Plaintiff’s competitors, Boxee (2013) and SmartThings Inc. (2014), after these alleged disclosures.
Case Timeline
| Date | Event |
|---|---|
| 2013-01-04 | Earliest Priority Date for ’486 and ’561 Patents |
| 2013-01-XX | Sookbox product unveiled at CES 2013; Inventors meet with Samsung |
| 2013-XX-XX | Sookbox presents technology at Samsung's Boston Office |
| 2013-07-XX | Samsung acquires Boxee |
| 2014-01-XX | Sookbox meets with Samsung at CES 2014, demonstrates product |
| 2014-05-XX | Sookbox holds follow-up meeting with Samsung in New York |
| 2014-08-XX | Samsung acquires SmartThings Inc. |
| 2016-11-22 | U.S. Patent No. 9,503,486 Issues |
| 2023-11-28 | U.S. Patent No. 11,831,561 Issues |
| 2025-05-21 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,503,486 - Configuring, Networking, and Controlling a Plurality of Unique Network-Capable Devices, issued November 22, 2016
The Invention Explained
- Problem Addressed: The patent describes the difficulty for users to "easily manage (control) and stream digital content seamlessly and transparently throughout the various output devices and associated locations (zones)" in a home network comprising many disparate devices (’486 Patent, col. 2:42-50).
- The Patented Solution: The invention proposes a method for configuring a "control session" from a mobile device. The system aggregates multiple "real-world connectable processing nodes" (e.g., smart appliances, displays) into a session and allocates specific functions to each node based on its processing requirements and capabilities, thereby creating a unified, multi-device application experience managed by a host (’486 Patent, Abstract; Fig. 4c).
- Technical Importance: The technology provides a framework for device interoperability and centralized control in the nascent smart home market, abstracting away the complexity of managing individual devices.
Key Claims at a Glance
- The complaint asserts at least independent claim 9 (Compl. ¶24).
- The essential elements of claim 9 are:
- An input/output processing system comprising a content control application on a mobile device for configuring a content control session.
- A host content control application that aggregates a plurality of real-world input/output processing nodes into a set for collectively executing the content input/output application.
- A plurality of functions that collectively determine the operation of the input/output application.
- A plurality of different types of input/output devices connected individually to distinct processing nodes.
- An application instantiation facility for identifying the set of processing nodes and instantiating each function on distinct processing nodes, where the instantiation is based on a class parameter of the nodes.
- The complaint reserves the right to assert other claims (Compl. ¶23).
U.S. Patent No. 11,831,561 - System, Apparatus, and Method for Controlling Internet Devices via a Mobile Device Session, issued November 28, 2023
The Invention Explained
- Problem Addressed: The patent highlights the "cumbersome navigation of a complicated website" or other content on a smart television using a "limited static unidirectional remote control," which contrasts with the richer control experience available on a personal computer or mobile device (’561 Patent, col. 2:5-12).
- The Patented Solution: The invention describes a display device (e.g., a smart TV) that receives streaming video from a content server while simultaneously receiving control signals from a separate mobile device. The mobile device displays a user interface with controls and a visual representation of its connection to the display device and the content, effectively acting as an enhanced, "second screen" remote (’561 Patent, Abstract; claim 7).
- Technical Importance: This patent addresses the user experience gap by formalizing the now-common paradigm of using a smartphone or tablet as an intelligent remote control for a primary media display device.
Key Claims at a Glance
- The complaint asserts at least independent claim 7 (Compl. ¶39).
- The essential elements of claim 7 are:
- A display device with one or more processing devices and a network interface.
- The device is configured to receive streaming video data from a content server and control signals from one or more mobile devices.
- The video data and feedback for control signals are displayed on the display device.
- Content items displayed on the mobile device include a connection to the display device and to the content on the server, and controls that invoke display of that content on the display device.
- The complaint reserves the right to assert other claims (Compl. ¶38).
III. The Accused Instrumentality
Product Identification
- The complaint names two categories of accused products: (1) "Samsung Applications," which include the Samsung Connect Home and SmartThings Platform, for infringing the ’486 Patent; and (2) "Samsung Display Devices," including Samsung smart televisions and the Samsung Galaxy S24, for infringing the ’561 Patent (Compl. ¶23, 38).
Functionality and Market Context
- The accused Samsung Applications constitute a smart home ecosystem where a mobile app (SmartThings) is used to connect and control various smart devices like TVs and lights (Compl. ¶25). Users can create automated "Routines" or "Scenes" that define how multiple devices interact in response to triggers (e.g., turning off all lights and TVs when the user leaves home) (Compl. ¶26-28). The complaint includes an architectural diagram showing how a mobile device, a SmartThings Hub, and various smart devices communicate with the SmartThings Cloud (Compl. p. 12).
- The accused Samsung Display Devices functionality centers on the interaction between a Samsung smart TV and a Samsung mobile device. The TV is allegedly capable of receiving streaming video from a content server (e.g., Samsung TV Plus) over Wi-Fi, while also receiving wireless control signals from a paired mobile device running the SmartThings app, which acts as a remote control for functions like channel and volume changes (Compl. ¶40, 41, 44).
IV. Analysis of Infringement Allegations
’486 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a content control application executing on a mobile control device for configuring a content control session... | The SmartThings app on a Samsung smartphone allows a user to configure a "routine" (alleged to be a "content control session"). | ¶26 | col. 4:18-24 |
| a host content control application that is adapted to aggregate a plurality of real-world input/output processing nodes... into a set of processing nodes for collectively executing the content input/output application... | The SmartThings Cloud and/or Hub aggregates multiple smart devices (e.g., TVs, lights) selected by the user into a "routine" for coordinated execution. | ¶27 | col. 6:39-44 |
| a plurality of functions that collectively determine the operation of the input/output application; | The user-defined conditions and triggers in a "Routine" (e.g., turn off lights, turn off TV) collectively define the automation's operation. | ¶28 | col. 19:27-38 |
| a plurality of different types of input/output devices connected individually to distinct processing nodes... | The SmartThings platform connects to different device types (displays, lights, sensors), each constituting a distinct processing node with its own processor. | ¶29 | col. 39:46-52 |
| an application instantiation facility for identifying the set of processing nodes and for instantiating each function of the plurality of functions on distinct processing nodes...wherein... a class parameter of the distinct processing nodes. | The SmartThings Cloud or Hub allegedly evaluates available smart devices and assigns tasks (functions) based on device type, supported functions, and I/O capabilities (class parameters). | ¶30 | col. 40:41-52 |
Identified Points of Contention
- Scope Questions: A central question may be whether the term "application instantiation facility" can be construed to read on the functionality of the SmartThings Cloud/Hub. The defense may argue that the accused system is a conventional rules engine, while the patent's use of "instantiation" implies a more complex software process of creating new application instances on distributed nodes, as detailed in the patent's specification (e.g., ’486 Patent, Fig. 1c-1d).
- Technical Questions: The complaint alleges that the "class parameter" is used to determine which node executes a function (Compl. ¶30). The case may require evidence demonstrating that the SmartThings backend performs this specific type of capability-based allocation, rather than simply executing a pre-defined set of commands on designated devices within a routine.
’561 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display device comprising: one or more processing devices... a network interface... | The Samsung Neo QLED 8K Smart TV contains a processor (Neural Quantum Processor 8K) and a network interface (Wi-Fi). | ¶40 | col. 47:56-62 |
| wherein the display device is configured to receive: streaming video data via the network interface over a network from the content server... and control signals from one or more mobile devices... | The smart TV receives streaming video (e.g., from Samsung TV Plus) and control signals from a paired Samsung Galaxy S24 via Wi-Fi. | ¶41, 43 | col. 47:63-67 |
| wherein the video data from the content server and feedback for control signals sent from the one or more mobile devices is displayed on the display device... | Control signals from the mobile device (e.g., channel change) cause a corresponding change in the video displayed on the TV. | ¶44 | col. 49:6-9 |
| wherein the one or more content items displayed on a mobile device include: a connection of the mobile device to the display device, and to content on the content server associated with the video data... | The SmartThings app on a Galaxy S24 shows the pairing with the smart TV and provides controls for content (e.g., from Samsung TV Plus) associated with the video. A screenshot shows a "Device Control" interface for the TV. | ¶45, 32 | col. 50:1-5 |
| and one or more controls that invoke display of the content on the content server on the display device. | Remote control buttons displayed on the Galaxy S24 (e.g., via the interface shown on Compl. p. 32) are used to control the display of content from Samsung TV Plus on the paired smart TV. | ¶46 | col. 50:6-9 |
Identified Points of Contention
- Scope Questions: Infringement may turn on the construction of "a connection... to content on the content server." The defense may argue that the accused mobile app only shows a connection to the display device itself, not a separate, direct visual representation of a connection to the underlying third-party content server (e.g., Netflix's or Samsung's own streaming server), as the claim language could be interpreted to require.
- Technical Questions: The complaint must provide evidence that the mobile device UI satisfies all sub-elements of the "content items" limitation. While the complaint shows a general device control screen (Compl. p. 32), the trial may focus on whether this UI element technically represents a connection to the content on the server in addition to the display device itself.
V. Key Claim Terms for Construction
Term: "application instantiation facility" (’486 Patent, claim 9)
- Context and Importance: This term is central to the ’486 Patent infringement theory. Its construction will determine whether Samsung's system for executing "Routines" in the SmartThings platform falls within the claim scope. Practitioners may focus on this term because its technical specificity could be a key non-infringement defense if construed narrowly.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Abstract of the ’486 Patent describes the invention in broad functional terms, such as "allocating at least one function required by the input/output application for execution on each processing node," which could support interpreting the term to cover any system that assigns tasks to networked devices.
- Evidence for a Narrower Interpretation: The detailed description and figures, particularly Figures 1c-1d and their accompanying text in the patent, describe a specific process of nodes discovering each other, creating messaging libraries, and confirming availability. The defense may argue that "instantiation" is a term of art tied to this specific architectural process, not a generic rules engine.
Term: "a visual representation of a connection of the mobile device ... to content on the content server" (’561 Patent, claim 7)
- Context and Importance: This limitation is critical for infringement of the ’561 Patent, as it defines a specific feature that must be present on the mobile device's user interface. A narrow construction could allow Samsung to argue its app does not meet this element, even if it performs a similar overall function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A patentee might argue that a UI which allows control of content inherently represents a "connection" to that content's source, and that the term should be interpreted functionally.
- Evidence for a Narrower Interpretation: The claim language explicitly requires a visual representation of a connection to two things: the display device AND the content on the server. A defendant could argue this requires more than just a generic remote control interface; it may require a specific UI element indicating a link to the streaming source itself, which may be absent from the accused app. The patent's own figures (e.g., Fig. 8A) are abstract and may not provide a clear definition.
VI. Other Allegations
Indirect Infringement
- The complaint alleges both induced and contributory infringement for both patents. The inducement theory is based on Samsung allegedly providing the accused products along with instructions, documentation, SDKs, and marketing materials that encourage and enable end-users to use the products in an infringing manner (e.g., creating routines in SmartThings or using a phone as a TV remote) (Compl. ¶31, 47).
Willful Infringement
- Willfulness is a central theme of the complaint. The allegations are based on Samsung's alleged pre-suit knowledge of the technology and pending patent applications, stemming from a series of meetings and technology demonstrations between Plaintiff and Samsung from 2013 to 2014. The complaint frames Samsung's subsequent development and acquisition of similar technologies as evidence of deliberate infringement or, alternatively, willful blindness (Compl. ¶13-19, 33, 49).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of pre-suit knowledge and intent: The case's trajectory, particularly regarding willfulness and potential damages enhancement, will depend heavily on factual evidence concerning the 2013-2014 meetings. The key question for the court will be whether the information Plaintiff allegedly shared was specific enough to put Samsung on notice of the inventions that would later be claimed in the issued patents-in-suit.
- A key claim construction battle for the ’486 Patent will be one of technical scope: Can the term "application instantiation facility," which the patent illustrates with a specific node-discovery architecture, be construed broadly enough to cover the cloud-based rules engine that powers Samsung’s SmartThings "Routines"?
- A key evidentiary question for the ’561 Patent will be one of functional representation: Does the accused SmartThings mobile application display a "visual representation of a connection ... to content on the content server," as the claim requires, or does it merely show a connection to the TV hardware, creating a potential mismatch between the accused functionality and the literal claim language?