DCT

2:25-cv-00634

Vkansee Technology Inc v. OnePlus Technology Shenzhen Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00634, E.D. Tex., Filed 06/13/2025
  • Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign entity organized under the laws of China, which under 28 U.S.C. § 1391(c)(3) may be sued in any judicial district. The complaint also alleges substantial business activity within Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones incorporating in-display optical fingerprint sensors infringe a patent related to methods and apparatuses for controlling the illumination of a display screen to acquire a fingerprint.
  • Technical Context: The technology concerns optical under-display fingerprint sensors, a common biometric security feature in modern smartphones that allows for a full-face screen without separate physical buttons.
  • Key Procedural History: The complaint alleges that Defendant’s corporate parent, OPPO, was made aware of the patent-in-suit during the prosecution of its own U.S. patent application, a fact Plaintiff may use to support allegations of pre-suit knowledge and willful infringement.

Case Timeline

Date Event
2016-07-25 '309 Patent Priority Date
2018-01-01 OnePlus introduces accused in-display fingerprint sensor technology
2019-11-19 '309 Patent Issue Date
2020-04-01 '309 patent family allegedly identified to Defendant's parent (OPPO)
2022-04-20 '309 patent allegedly cited by USPTO examiner to Defendant's parent
2025-06-13 Complaint Filing Date

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

U.S. Patent No. 10,482,309 - "Method and apparatus for controlling fingerprint acquisition based on a display screen and electronic device," issued November 19, 2019

The Invention Explained

  • Problem Addressed: As smartphones moved toward full-screen designs, integrating fingerprint sensors under the display became desirable. However, using the display itself as a light source for the optical sensor presented a technical problem: illuminating the entire screen would consume excessive power and could potentially cause screen damage (e.g., burn-in) over time (Compl. ¶22; ’309 Patent, col. 1:46-61).
  • The Patented Solution: The invention provides a control system that detects a "fingerprint acquisition triggering instruction," such as a user waking the device or an application requesting authentication. In response, the system selectively illuminates only a "preset fingerprint acquisition region" of the screen directly over the sensor to light the user's finger. It then triggers the sensor to capture the fingerprint image. This method conserves power and protects the display by localizing the high-brightness illumination to a small, specific area only when needed (’309 Patent, Abstract; col. 2:8-15).
  • Technical Importance: This technology provided a power-efficient and screen-safe solution for implementing optical in-display fingerprint sensors, facilitating their widespread adoption in consumer electronics like smartphones (Compl. ¶¶21-22).

Key Claims at a Glance

  • The complaint asserts independent apparatus claim 9 (Compl. ¶27).
  • Essential elements of claim 9 include:
    • A "triggering instruction detecting unit" for detecting a fingerprint acquisition trigger from a user or application.
    • An "acquisition region control unit" for controlling a preset region of the display to emit light and illuminate a finger.
    • A "fingerprint acquisition triggering unit" for triggering the sensor to capture an image after the region is illuminated.
    • A limitation requiring the "preset fingerprint acquisition region" to be located in specific areas defined relative to an "exploring hot region" of a right or left thumb.
  • The complaint reserves the right to assert additional claims (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are OnePlus smartphones that include an "In-Display Fingerprint Sensor," including but not limited to the OnePlus 6/6T, 7/7T/7 Pro, 8/8T/8 Pro, 9 5G/9 Pro 5G, 10/10 Pro 5G, 11/11Pro 5G, 12/12R, Nord3/N20/N30, and Nord4 models (Compl. ¶14).

Functionality and Market Context

The accused devices utilize their display screens to illuminate a user's finger for biometric authentication, allowing the user to unlock the device by touching a designated area of the screen (Compl. ¶¶13, 31). Plaintiff alleges it purchased and tested an accused OnePlus 12 phone (Compl. ¶10, Ex. 1). The complaint references a screenshot from an online video showing the accused functionality. A screenshot of an online video is provided as Exhibit 7, which purportedly shows the accused in-display fingerprint sensor in operation (Compl. ¶13). The feature is advertised by Defendant as a "reliable and convenient touchpoint for OnePlus users to unlock their smartphone" (Compl. ¶31).

IV. Analysis of Infringement Allegations

The complaint alleges that the detailed infringement analysis for claim 9 of the '309 Patent is contained in Exhibit 9, which was not publicly filed with the complaint (Compl. ¶27). The general narrative theory of infringement is that the accused OnePlus smartphones, when performing fingerprint authentication, execute a process that meets every element of the asserted claims. The complaint alleges that a user action, such as touching the screen to unlock the phone, serves as a "triggering instruction." This allegedly causes the phone's hardware and software (the "acquisition region control unit") to illuminate a specific part of the screen over the sensor, which in turn prompts the sensor (via the "fingerprint acquisition triggering unit") to capture the fingerprint image (Compl. ¶¶13, 26, 31).

Identified Points of Contention

  • Structural Questions: The asserted apparatus claim recites distinct functional "units" (e.g., "triggering instruction detecting unit"). A central dispute may be whether the integrated hardware and software of the accused smartphones contain structures that correspond to these claimed units, or if the claim limitations are simply describing functions of a single, undifferentiated system.
  • Technical Questions: Claim 9 requires the fingerprint acquisition region to be located within a defined "exploring hot region" of a thumb (’309 Patent, col. 24:25-40). A key factual question will be whether the physical placement of the sensor on the accused OnePlus phones falls within the scope of this location-based limitation, which will likely require expert analysis of ergonomic data and device measurements.

V. Key Claim Terms for Construction

"triggering instruction detecting unit"

  • Context and Importance: This "unit" limitation appears in the preamble of apparatus claim 9. The parties will likely dispute whether this term requires a distinct physical or software structure or can be met by the general functionality of the phone's operating system. Its construction will determine the structural evidence Plaintiff must provide to prove infringement.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the function broadly, stating the unit is "configured for detecting a fingerprint acquisition triggering instruction from a user or an application" (’309 Patent, col. 24:11-13). This could support an interpretation covering any software module or hardware component that senses a trigger.
  • Intrinsic Evidence for a Narrower Interpretation: The patent discloses specific examples of triggers, such as pressing a "power key or a start key" or performing specific touch operations (’309 Patent, col. 2:21-34). A defendant may argue that the scope of the "unit" is implicitly limited to the structures necessary to perform these disclosed functions.

"exploring hot region of a right hand thumb"

  • Context and Importance: This term is critical for infringement as it defines the required physical location of the sensor on the device. Practitioners may focus on this term because its definition appears subjective and potentially vulnerable to an indefiniteness challenge.
  • Intrinsic Evidence for a Broader Interpretation: The specification provides a functional definition: "a region which is easy to be touched by the right hand thumb in a state that the right hand thumb bends naturally and a finger pulp thereof touches the screen when the electronic device is held by a right hand" (’309 Patent, col. 3:32-37). Plaintiff may argue this creates a clear, albeit functional, boundary.
  • Intrinsic Evidence for a Narrower Interpretation: Defendant may argue the term is indefinite because what is "easy to be touched" is subjective and varies between users. Alternatively, Defendant could argue the term should be limited to the specific depictions shown in patent figures like Figure 4B (’309 Patent, Fig. 4B).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that Defendant encourages infringement through advertising and by providing technical information and instructions that guide users to operate the phones in an infringing manner (Compl. ¶¶30-31). It also pleads contributory infringement, alleging the accused devices are "especially configured to enable fingerprinting functionality" and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶32).

Willful Infringement

Willfulness is alleged based on both post-suit knowledge via service of the complaint and, more significantly, alleged pre-suit knowledge. The complaint asserts that Defendant's corporate parent, OPPO, was notified of the '309 patent family in an international search report in April 2020 and that the '309 patent itself was cited by the USPTO examiner to OPPO during the prosecution of a related U.S. application in April 2022 (Compl. ¶29).

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

  • A core issue will be one of definitional scope and validity: Can the term "exploring hot region," which is defined by the ergonomics of a user's natural thumb placement, be construed with sufficient objective certainty to be enforceable, or is it fatally indefinite?
  • A key evidentiary question will be one of structural infringement: Can Plaintiff demonstrate that the accused phones' software and hardware architecture embodies the distinct "detecting unit," "control unit," and "triggering unit" of the apparatus claim, or will these be found to be functional limitations not met by the accused integrated systems?
  • A central question for damages will be one of willfulness: Does the alleged notice of the '309 patent to Defendant’s corporate parent during a separate patent prosecution constitute pre-suit knowledge attributable to the Defendant, sufficient to support a claim for enhanced damages?