DCT

2:25-cv-00587

BOE Technology Group Co Ltd v. Samsung Display Co Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00587, E.D. Tex., 09/29/2025
  • Venue Allegations: Venue is alleged as proper under 28 U.S.C. § 1391(c)(3) on the basis that Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s Organic Light Emitting Diode (OLED) displays, incorporated into foldable smartphones, infringe four U.S. patents related to under-display camera technology and specialized pixel array structures.
  • Technical Context: The technology concerns advanced OLED display manufacturing, specifically methods to embed cameras and sensors beneath a display to achieve a "full-screen" device appearance without notches or cutouts.
  • Key Procedural History: The complaint alleges an extensive history of litigation between the parties, including investigations at the International Trade Commission and proceedings at the Patent Trial and Appeal Board. Plaintiff specifically alleges that Defendant gained pre-suit knowledge of one patent-in-suit ('994 Patent) during the prosecution of its own patent application, where a U.S. examiner cited the '994 patent against Defendant’s application.

Case Timeline

Date Event
2018-06-20 Earliest Priority Date for ’309 and ’976 Patents
2018-08-29 Earliest Priority Date for ’994 Patent
2018-10-11 Earliest Priority Date for ’017 Patent
2021-06-15 ’994 Patent Issued
2022-08-26 Alleged Date of Samsung’s Pre-Suit Knowledge of ’994 Patent
2022-11-25 Alleged Date Samsung Cited ’994 Patent in its Own Prosecution
2023-07-04 ’017 Patent Issued
2025-04-01 ’309 Patent Issued
2025-05-20 ’976 Patent Issued
2025-09-29 Complaint Filed

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

U.S. Patent No. 11,037,994 - "Display Panel and Method for Manufacturing the Same"

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of placing optical elements like cameras under an OLED display because the panel's constituent layers, such as metal electrodes and light-shielding structures, are typically opaque or have low transparency, blocking external light. (’994 Patent, col. 1:31-39).
  • The Patented Solution: The invention proposes a display panel structure that integrates "first pixel units" for displaying an image with "first transparent portions" designed to let light pass through. This is achieved by creating "lost regions" in otherwise opaque layers, such as the non-transparent electrode layer and a light shielding layer, in the areas designated as transparent. The result is a hybrid display area that can both show an image and allow an under-display camera to function. (’994 Patent, Abstract; col. 1:41-49; Fig. 1).
  • Technical Importance: This design facilitates the creation of "full-screen" displays, eliminating the need for notches or "punch-hole" cutouts for front-facing cameras, a significant objective in modern smartphone design. (’994 Patent, col. 5:31-36).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶32).
  • Essential elements of Claim 1 include:
    • A display area having a plurality of first pixel units and first transparent portions configured to transmit external light, where pixel units are spaced apart by transparent portions.
    • The display area comprises a non-transparent electrode layer that extends in the pixel units and has an "electrode layer lost region" in the area of the transparent portions.
    • The display area also comprises a light shielding layer on the light-emitting side and a thin film encapsulation on the electrode layer.
    • The light shielding layer has a "first light shielding layer lost region" in the pixel unit area and a "second light shielding layer lost region" in the transparent portion area.
    • A color filter layer is provided in the first light shielding layer lost region.
    • The light shielding layer and the color filter layer are arranged above the thin film encapsulation.

U.S. Patent No. 12,266,309 - "Display Substrate and Driving Method Thereof, and Display Device"

The Invention Explained

  • Problem Addressed: Integrating a camera under a display screen to increase the screen-to-body ratio is a primary goal, but creating a transparent region can result in a visible boundary and degrade display performance. (’309 Patent, col. 1:29-35).
  • The Patented Solution: The patent discloses a display substrate with two distinct regions: a first, standard display sub-region with a high pixel density, and a second display sub-region with a lower pixel density and higher light transmittance to accommodate an under-screen camera. The invention specifies distinct pixel and sub-pixel arrangements for each region. The first region uses a "sub-pixel borrowing" driving method, typical for high-resolution Pentile displays, while the second region uses a non-borrowing method. (’309 Patent, Abstract; col. 2:40-62).
  • Technical Importance: This patented architecture provides a method for integrating a high-transparency camera zone within a high-resolution display while managing the visual and functional transition between the different pixel structures.

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶52).
  • Essential elements of Claim 1 include:
    • A display substrate comprising a first display sub-region and a second display sub-region.
    • The first sub-region has first and second pixel units in a "first repeating unit."
    • The second sub-region has a third pixel unit and a "first transparent pixel" in a "second repeating unit."
    • An under-screen camera is attached to the substrate, configured to receive ambient light passing through the second sub-region.
    • The pixel density of the second sub-region is smaller than that of the first, and its light transmittance is greater.
    • The area of the first transparent pixel is greater than or equal to the sum of the areas of the sub-pixels in the third pixel unit.
    • The first repeating unit is configured to be driven in a "sub-pixel borrowing manner."
    • The second repeating unit is configured to be driven in a manner where "no sub-pixel is borrowed."
    • The sub-pixels in the different regions have different shapes.

U.S. Patent No. 12,307,976 - "Display Substrate and Driving Method Thereof, and Display Device"

  • Technology Synopsis: This patent relates to a display substrate architecture for integrating an under-display camera, similar to the ’309 Patent. It describes a substrate with a first, high-density display sub-region and an adjacent second, lower-density sub-region that includes transparent pixels to allow ambient light to pass. The invention specifies particular arrangements of sub-pixels within repeating regions in both areas and explicitly claims that the second sub-region is configured to be driven in a manner where "no sub-pixel is borrowed." (Compl. ¶¶ 61, 70).
  • Asserted Claims: Independent claim 1. (Compl. ¶70).
  • Accused Features: The complaint alleges that the pixel and sub-pixel structure of the OLED displays in the Samsung Galaxy Z Fold6, particularly in the region of the under-display camera, infringes this patent. (Compl. ¶70).

U.S. Patent No. 11,695,017 - "Array Substrate, Display Panel, and Display Device"

  • Technology Synopsis: This patent addresses the technical problem of light diffraction caused by dense electrical wiring within the transparent "sensing component region" of a display designed for an under-screen camera. The proposed solution is to rearrange the wiring passing through this transparent region by grouping adjacent wires into "gathering portions." These gathered wiring groups are then aligned with corresponding "light-shielding strips." This architecture increases the transparent space between the wiring groups, which is intended to reduce light diffraction and improve the performance of the underlying camera or sensor. (’017 Patent, Abstract; col. 1:37-54).
  • Asserted Claims: Independent claim 1. (Compl. ¶89).
  • Accused Features: The complaint accuses the array substrate within the Samsung Galaxy Z Fold6, specifically alleging that its arrangement of wiring and light-shielding strips in the under-display camera region infringes this patent. (Compl. ¶89).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "Infringing OLED Displays" that are incorporated into products including, but not limited to, the Samsung Galaxy Z Fold series of phones, such as the Fold5 and Fold6. (Compl. ¶¶ 5-6). The detailed infringement counts specifically name the Samsung Galaxy Z Fold6 as an exemplary infringing product. (Compl. ¶¶ 32, 52, 70, 89).

Functionality and Market Context

  • The accused products are foldable smartphones featuring flexible OLED displays. (Compl. ¶7). A key accused functionality is the "Under Display Camera" or "UDC," which places a camera behind the main display. (Compl. ¶9). The complaint highlights a screenshot from Defendant's website promoting its "Foldable Display" technology. (Compl. p. 3). This feature allows the display to appear as a continuous, uninterrupted surface for viewing content, which Defendant allegedly markets as the "biggest breakthrough since the mobile phone[.]" (Compl. ¶9).

IV. Analysis of Infringement Allegations

11,037,994 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a display area having a plurality of first pixel units and a plurality of first transparent portions, the first transparent portions being configured such that external light is transmitted through the first transparent portions... The display panel of the Samsung Galaxy Z Fold6 comprises a display area with first pixel units and first transparent portions configured to allow external light to pass through. ¶32.b col. 1:41-49
an electrode layer that is non-transparent which extends in the plurality of first pixel units; an electrode layer lost region in an orthographic projection area of each of the plurality of first transparent portions... The display area comprises a non-transparent electrode layer in the pixel units and an "electrode layer lost region" in the area of the transparent portions. ¶32.c col. 6:38-44
a light shielding layer on a light emitting side of the display panel; and a thin film encapsulation on the electrode layer. The display area comprises a light shielding layer on the light-emitting side and a thin film encapsulation on the electrode layer. ¶32.c col. 7:15-24
the light shielding layer is provided with a first light shielding layer lost region in the light shielding layer in an orthographic projection area of each of the plurality of first pixel units, and provided with a second light shielding layer lost region...and a color filter layer...is provided in the first light shielding layer lost region. The light shielding layer has a first "lost region" in the pixel unit area and a second "lost region" in the transparent portion area, with a color filter layer provided in the first lost region. ¶32.d col. 7:19-44
the light shielding layer and the color filter layer are arranged above the thin film encapsulation. The light shielding layer and color filter layer are located above the thin film encapsulation layer. ¶32.e col. 8:19-24
  • Identified Points of Contention:
    • Scope Questions: A potential dispute may arise over the term "lost region." The question for the court could be whether this term requires a specific manufacturing process (e.g., physically removing material that was once present) or if it can read on a process where the layer was simply never deposited in that region.
    • Technical Questions: The complaint alleges a specific multi-layer stack-up. A key factual question will be whether the accused Samsung displays contain the precise sequence and arrangement of the electrode layer, thin film encapsulation, light shielding layer, and color filter layer, including their respective "lost regions," as required by the claim. The screenshot of Defendant's US Sales Network may be used to establish business presence and infringing activities within the United States. (Compl. p. 8).

12,266,309 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a display substrate having... a first display sub-region comprising a first pixel unit and a second pixel unit... and a second display sub-region comprising a repeating unit comprising a third pixel unit and a first transparent pixel... The Samsung Galaxy Z Fold6 is a full-screen display device comprising a display substrate with a first display sub-region and a second display sub-region with the recited pixel unit structures. ¶52.a-b col. 2:40-52
an under-screen camera attached onto a side of the display substrate opposite to the light emitting side and configured to receive ambient light passing through the second display sub-region... The device has an under-screen camera positioned to receive light through the second display sub-region. ¶52.c col. 2:53-58
wherein the first transparent pixel is configured such that a pixel density of the second display sub-region is smaller than that of the first display sub-region, and a light transmittance of ambient light of the second display sub-region is greater than that of the first display sub-region... The pixel density in the camera region is lower and the light transmittance is higher compared to the main display region. ¶52.d col. 2:59-62
wherein an area of the first transparent pixel is greater than or equal to a sum of areas of the first sub-pixel, the second sub-pixel, and the third sub-pixel in the third pixel unit... The area of the transparent pixel is greater than or equal to the sum of the areas of the constituent sub-pixels of the adjacent pixel unit. ¶52.e col. 3:1-4
wherein the first... repeating unit is configured to be driven in a sub-pixel borrowing manner... The repeating unit in the first display sub-region is driven using a sub-pixel borrowing method. ¶52.f col. 20:39-42
the second repeating unit is configured to be driven in a manner in which no sub-pixel is borrowed... The repeating unit in the second display sub-region is driven without using a sub-pixel borrowing method. ¶52.g col. 21:13-16
the first sub-pixel, the second sub-pixel, and the third sub-pixel in the third pixel unit have substantially the same first shape, and the... sub-pixel in the first pixel unit and the second pixel unit have substantially the same second shape, and... the first shape is different from the second shape. The sub-pixels in the different regions have different shapes as claimed. ¶52.h-i col. 21:49-55
  • Identified Points of Contention:
    • Scope Questions: The construction of what it means to be "driven in a sub-pixel borrowing manner" versus a manner in which "no sub-pixel is borrowed" will be central. This functional language may be a significant point of dispute.
    • Technical Questions: A primary factual question will be whether the display driver and software in the accused Galaxy Z Fold6 actually operate in the manner claimed, with two different driving modes for the two distinct display regions. This may require evidence beyond a simple physical teardown of the display panel. The complaint includes a screenshot of Defendant's research lab in San Jose, which may be used to suggest that testing and development of such functionalities occurs in the U.S. (Compl. p. 9).

V. Key Claim Terms for Construction

  • Term ('994 Patent): "electrode layer lost region"

    • Context and Importance: This term is fundamental to how the patent achieves transparency. The infringement analysis for the '994 patent hinges on whether the accused product's structure for enabling its under-display camera meets this definition. Practitioners may focus on this term to determine if it is limited to a specific manufacturing method.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the region as being "formed by breaking the first electrode layer 60 in this region," which could be argued to encompass any structure where the electrode layer is absent or discontinuous in the transparent portion. (’994 Patent, col. 6:42-44).
      • Evidence for a Narrower Interpretation: The patent discloses specific embodiments for creating this region, including using a protrusion for a lift-off process or using plasma/laser ablation. A defendant may argue that the term should be limited by these disclosed examples. (’994 Patent, col. 9:6-21; col. 11:4-47).

  • Term ('309 Patent): "driven in a sub-pixel borrowing manner"

    • Context and Importance: This functional limitation is a key distinction between the two claimed display sub-regions. Plaintiff's infringement case for the '309 patent (and the related '976 patent) depends on proving that the accused product's display driver operates in this specific way for the main display area.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition for this term, suggesting it should be given its plain and ordinary meaning to a person of skill in the art of display technology.
      • Evidence for a Narrower Interpretation: The specification notes that through sub-pixel borrowing, "pixel units can achieve a resolution higher than the physical resolution." (’309 Patent, col. 9:1-4). A defendant could argue this implies a specific functional outcome that must be met for a driving method to qualify as "sub-pixel borrowing."

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced infringement and contributory infringement for all asserted patents. The allegations are based on Defendant knowingly supplying the allegedly infringing OLED displays to manufacturers of end-user products (the "Infringing Phones"). The complaint asserts these displays are specially designed to infringe and have no substantial non-infringing uses. (Compl. ¶¶ 29-30, 34, 36-37, 49-50, 67-68, 86-87).
  • Willful Infringement: Willfulness is alleged for all four patents. For the ’994 Patent, the complaint alleges pre-suit knowledge dating back to at least August 26, 2022, when a U.S. patent examiner allegedly cited the ’994 Patent in a rejection of Defendant’s own patent application, which Defendant later cited itself. (Compl. ¶35). For the ’309, ’976, and ’017 Patents, knowledge is alleged from at least their respective issue dates, based on the ongoing litigation between the parties and Defendant’s alleged practice of monitoring Plaintiff’s patent portfolio. (Compl. ¶¶ 53, 58, 72, 77, 91, 96).

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

  • A core issue will be one of structural correspondence: Do the specific, multi-layered pixel architectures and wiring layouts within Samsung’s Under Display Camera technology precisely map onto the detailed structural limitations recited in the asserted claims, particularly the specific arrangement of "lost regions" in the '994 patent and the "gathering portions" of wiring in the '017 patent?
  • A key evidentiary question will be one of operational function: Can Plaintiff demonstrate that the accused display drivers operate with two distinct modes—one "in a sub-pixel borrowing manner" for the main display and another "in which no sub-pixel is borrowed" for the camera region—as functionally required by claims of the '309 and '976 patents?
  • A central question for damages will be the scope of willfulness: Given the allegations of Defendant’s pre-suit knowledge of the '994 patent from its own patent prosecution activities, the court will need to determine when Defendant knew or should have known about each asserted patent, which will be critical to Plaintiff’s request for enhanced damages.