DCT

2:25-cv-00715

BOE Technology Group Co Ltd v. Samsung Display Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00715, E.D. Tex., 07/15/2025
  • Venue Allegations: Plaintiff alleges venue is proper because 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 OLED display screens, incorporated into products such as the Samsung Galaxy Z Fold and S-series smartphones, infringe four U.S. patents related to OLED manufacturing, protective coatings, and display circuitry.
  • Technical Context: The technology at issue involves advanced semiconductor display manufacturing, specifically for OLED screens, which are a critical component in the premium consumer electronics market, including the growing sector of foldable devices.
  • Key Procedural History: The complaint notes that Defendant filed multiple patent infringement lawsuits against Plaintiff in the same district in April 2025, suggesting this case is part of a broader, ongoing competitive dispute between two major global display manufacturers.

Case Timeline

Date Event
2004-11-15 U.S. Patent 8,704,211 Priority Date
2012-12-12 U.S. Patent 9,147,772 Priority Date
2014-04-22 U.S. Patent 8,704,211 Issued
2015-09-29 U.S. Patent 9,147,772 Issued
2019-12-20 U.S. Patent 12,073,037 Priority Date
2021-03-24 U.S. Patent 12,205,506 Priority Date
2022-07-07 Alleged date of Defendant's knowledge of the ’211 Patent
2023-04-03 Alleged date of Defendant's knowledge of the ’772 Patent
2024-08-27 U.S. Patent 12,073,037 Issued
2025-01-21 U.S. Patent 12,205,506 Issued
2025-07-15 Complaint Filing Date

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

U.S. Patent No. 8,704,211 - “High integrity protective coatings”

  • Issued: April 22, 2014

The Invention Explained

  • Problem Addressed: The patent addresses the susceptibility of optoelectronic devices to environmental degradation from species like moisture and oxygen. It also notes that surface defects on substrates, such as microscopic spikes or pinholes, can compromise device performance and longevity (U.S. Patent 8,704,211, col. 1:24-44).
  • The Patented Solution: The invention is a multi-layer protective coating designed to both seal the device and smooth its surface. It consists of a "planarizing layer" that covers surface defects and an "organic-inorganic composition barrier coating layer." This barrier layer features graded zones—a "substantially organic zone," a "substantially inorganic zone," and an "interface zone" between them—to create an effective barrier while matching refractive indices to prevent optical interference and maintain high light transmission ('211 Patent, Abstract; col. 4:9-17; Fig. 2).
  • Technical Importance: This approach provides a method for encapsulating sensitive electronic components, like OLEDs, to protect them from environmental damage without significantly degrading their optical performance, which is critical for display applications ('211 Patent, col. 3:1-5).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (Compl. ¶26).
  • Claim 1 Elements:
    • A composite article comprising: at least one high integrity protective coating,
    • said high integrity protective coating comprising at least one organic-inorganic composition barrier coating layer and at least one planarizing layer,
    • wherein the barrier coating layer comprises a substantially organic zone and a substantially inorganic zone and an organic-inorganic interface zone between the substantially organic zone and the substantially inorganic zone.

U.S. Patent No. 9,147,772 - “Complementary Metal Oxide Semiconductor Circuit Structure, Preparation Method Thereof and Display Device”

  • Issued: September 29, 2015

The Invention Explained

  • Problem Addressed: Conventional manufacturing of CMOS circuits for display backplanes using Low-Temperature Polysilicon (LTPS) technology is described as complex and costly. The process requires numerous photolithography and doping steps, and the extensive use of laser crystallization to form polysilicon increases production costs and reduces the lifespan of manufacturing equipment (U.S. Patent 9,147,772, col. 1:15-24).
  • The Patented Solution: The patent discloses a hybrid CMOS architecture that combines two different transistor technologies. The PMOS (P-channel) region is built using traditional LTPS (P-type doped polysilicon), while the NMOS (N-channel) region is built using an Oxide TFT, where the semiconductor layer is made of an "oxide material" (e.g., IGZO). This approach simplifies manufacturing by omitting several doping steps required for a traditional LTPS NMOS region, thereby reducing complexity and cost ('772 Patent, Abstract; col. 2:9-25).
  • Technical Importance: This hybrid structure presents a more cost-effective manufacturing process for the high-performance pixel-driving circuits required by modern display technologies such as OLED ('772 Patent, col. 2:2-5).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (Compl. ¶41).
  • Claim 1 Key Elements:
    • A complementary metal oxide semiconductor CMOS circuit structure, having a PMOS region and an NMOS region,
    • comprising a specific sequence of layers including a base substrate, a PMOS semiconductor layer, a gate insulating layer, PMOS and NMOS gates, a first interlayer dielectric layer, and an NMOS semiconductor layer arranged on the first interlayer dielectric layer,
    • wherein the PMOS semiconductor layer is prepared from a P type doped polysilicon material,
    • and wherein the NMOS semiconductor layer is made of an oxide material.
  • The complaint notes that it also accuses infringement of dependent claims 5, 6, and 7 (Compl. ¶49).

U.S. Patent No. 12,073,037 - “Display Panel and Display Device”

  • Issued: August 27, 2024
  • Technology Synopsis: The patent relates to display panels designed for "in-screen camera technology," where a camera is placed behind the display. It addresses the technical problem of light interference and diffraction caused by light passing through the "slits" between signal traces in the pixel driving circuitry, which can degrade camera image quality. The proposed solution is to configure the wiring of the "touch function layer" so that its orthographic projection overlaps with the slits, effectively shielding them from incident light. The patent also describes a panel with a high-pixel-density primary display region and a lower-pixel-density secondary (camera) region to enhance light transmission to the sensor (’037 Patent, Abstract; col. 1:25-33; col. 5:6-21).
  • Asserted Claims: Independent Claim 1 (Compl. ¶57).
  • Accused Features: The technology is accused of being used in Defendant's displays that incorporate an "Under Display Camera" (UDC), such as those in the Samsung Galaxy Z Fold series phones (Compl. ¶11, ¶64).

U.S. Patent No. 12,205,506 - “Display substrate and display device”

  • Issued: January 21, 2025
  • Technology Synopsis: This patent focuses on the design of Gate Driver on Array (GOA) circuits used to drive pixels in a display. The invention describes a specific "charge pump circuit" within the shift register units, intended to improve the stability of the driving signal and reduce the effects of leakage current, particularly in advanced LTPO displays. The claims detail a specific arrangement of transistors and capacitors, including a transistor configured as a "diode structure," and define the spatial relationship of these components on the substrate to ensure reliable operation during the "keeping phase" of the pixel driving cycle (’506 Patent, Abstract; col. 1:19-39; col. 9:14-20).
  • Asserted Claims: Independent Claim 1 (Compl. ¶72).
  • Accused Features: The patent is asserted against the GOA circuitry within the Defendant’s "Infringing OLED Displays," such as those allegedly used in the Samsung Galaxy Z Fold6 (Compl. ¶71, ¶79).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendant's "Infringing OLED Displays" which are incorporated into various mobile phones, including but not limited to the Samsung Galaxy Z Fold series (e.g., Fold5 & Fold6) and Samsung Galaxy S-series (e.g., S25 Ultra) (Compl. ¶6).

Functionality and Market Context

  • The complaint identifies the accused products as displays for high-end smartphones featuring advanced capabilities. This includes flexible screens for foldable devices, as shown in a screenshot from Defendant's website promoting its "Foldable Display" technology (Compl. p. 5, ¶9). The complaint also points to marketing materials for the Samsung Galaxy S25 Ultra, which describe a high-resolution QHD+ OLED display with a variable refresh rate up to 120Hz, designed for power efficiency and improved image quality (Compl. p. 4, ¶8). Another key feature identified is the "Under Display Camera" or "UDC," which places a camera behind the screen without a visible cutout, a feature touted in the Galaxy Z Fold series (Compl. ¶11).

IV. Analysis of Infringement Allegations

’211 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A composite article comprising: at least one high integrity protective coating, The Samsung Galaxy Z Fold6 has a display that is a composite article comprised of at least one high integrity protective coating. ¶33a, ¶33b col. 3:5-8
said high integrity protective coating comprising at least one organic-inorganic composition barrier coating layer and at least one planarizing layer, The high integrity protective coating is comprised of at least one organic-inorganic composition barrier coating layer and at least one planarizing layer. ¶33c col. 4:9-12
wherein the barrier coating layer comprises a substantially organic zone and a substantially inorganic zone and an organic-inorganic interface zone between the substantially organic zone and the substantially inorganic zone. The barrier coating layer comprises a substantially organic zone, a substantially inorganic zone, and an organic-inorganic interface zone between them. ¶33d col. 4:10-17
  • Identified Points of Contention:
    • Structural Questions: The infringement theory depends on the physical structure of the protective layers in Defendant's OLED displays. A central question will be whether the accused displays contain a "planarizing layer" and a "barrier coating layer" that function as claimed.
    • Technical Questions: A key technical dispute may arise over the existence of the claimed "organic-inorganic interface zone." The complaint's allegation is conclusory. The case may turn on what evidence Plaintiff can produce to demonstrate that Defendant's displays utilize a graded transitional zone between organic and inorganic layers, rather than distinct, sharply-defined layers.

’772 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A complementary metal oxide semiconductor CMOS circuit structure, having a PMOS region and an NMOS region... The Samsung Galaxy Z Fold6 has a display comprising a CMOS circuit structure with a PMOS region and an NMOS region. ¶49a col. 2:35-40
an NMOS semiconductor layer arranged on a portion of the first interlayer dielectric layer that corresponds to the NMOS gate; An NMOS semiconductor layer is arranged on a portion of the first interlayer dielectric layer corresponding to the NMOS gate. ¶49g col. 2:40-44
the PMOS semiconductor layer is prepared from a P type doped polysilicon material; The PMOS semiconductor layer, gate, and source/drain are located in the PMOS region, and the semiconductor layer is prepared from a P type doped polysilicon material. ¶49k col. 2:45-49
the NMOS semiconductor layer is made of an oxide material. The NMOS semiconductor layer, gate, and source/drain are located in the NMOS region, and the semiconductor layer is made of an oxide material. ¶49l col. 2:50-53
  • Identified Points of Contention:
    • Architectural Questions: The claim recites a specific hybrid LTPS/Oxide TFT architecture. The infringement analysis will depend entirely on the physical construction of the backplane circuitry in the accused displays. A primary question for the court will be whether Defendant's displays utilize this combination of polysilicon for the PMOS region and an oxide material for the NMOS region.
    • Structural Questions: The claim requires a specific vertical arrangement of layers, with the NMOS semiconductor layer being formed "on a portion of the first interlayer dielectric layer." This suggests a top-gate structure for the NMOS transistor, in contrast to a bottom-gate structure for the PMOS transistor. Verification of this specific layered arrangement in the accused products will be a critical factual issue.

V. Key Claim Terms for Construction

For the ’211 Patent:

  • The Term: "organic-inorganic interface zone"
  • Context and Importance: This term is central to defining the novel structure of the barrier layer. Whether Defendant's products infringe may depend on whether their coatings have a distinct, graded transition between organic and inorganic materials, as opposed to simply stacking different layers with sharp boundaries. Practitioners may focus on this term because it distinguishes the claimed invention from a simple multi-layer stack.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes these as "transitional zones" that are "neither substantially organic nor substantially inorganic" ('211 Patent, col. 4:38-40), which could be interpreted to cover any region of mixed composition between the primary zones.
    • Evidence for a Narrower Interpretation: The patent describes creating the coating by "changing the compositions of the reactants fed into the reactor chamber during the deposition" ('211 Patent, col. 2:60-64). This could support a narrower construction limited to zones created by a continuous, graded deposition process, potentially excluding interfaces formed by other means.

For the ’772 Patent:

  • The Term: "oxide material"
  • Context and Importance: This term defines the material composition of the NMOS semiconductor layer, which is the core distinction from an all-LTPS CMOS structure. The scope of this term will determine whether the semiconductor material used in Defendant's NMOS transistors falls within the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of examples, stating the material "may be at least one of indium gallium zinc oxide (IGZO), zinc oxide (ZnO), indium zinc oxide (IZO), indium tin zinc oxide (ITZO) and the like, and no limitation is made to the present disclosure herein" ('772 Patent, col. 4:31-36). This language suggests the term is open-ended and not limited to the enumerated examples.
    • Evidence for a Narrower Interpretation: A defendant could argue that "oxide material" should be construed in the context of its function as a semiconductor in an Oxide TFT structure. This might limit the term to materials known to have suitable semiconductor properties for such applications at the time of the invention, potentially excluding novel oxide compositions not contemplated by the patent.

VI. Other Allegations

  • Indirect Infringement: For all asserted patents, the complaint alleges both induced and contributory infringement. The inducement allegations are based on claims that Defendant "intentionally causes, urges, or encourages manufacturers, shippers, distributors, and retailers" to use the infringing displays (e.g., Compl. ¶34, ¶50). The contributory infringement allegations assert that the infringing displays are "specially designed" for infringement and have "no substantial non-infringing uses" (e.g., Compl. ¶35, ¶51).
  • Willful Infringement: The complaint alleges willful infringement for all patents. For the ’211 and ’772 Patents, it alleges pre-suit knowledge based on Defendant's awareness of the patent families through other litigation or related applications, with alleged knowledge dates of July 7, 2022, and April 3, 2023, respectively (Compl. ¶34, ¶50). For the more recently issued ’037 and ’506 Patents, willfulness is based on knowledge "at least as early as the date this Complaint was filed" (Compl. ¶65, ¶80).

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

  • A central issue will be one of structural proof: For the ’211 and ’772 patents, which claim specific microscopic physical structures—a graded "interface zone" in a coating and a hybrid polysilicon/oxide transistor architecture—can the Plaintiff produce sufficient evidentiary proof, likely from destructive reverse engineering, to demonstrate that Defendant's mass-produced commercial displays actually embody these precise structural limitations?
  • A key dispute will likely be one of functional scope: For the ’037 patent concerning Under Display Camera technology, the core question is whether Defendant's method for improving camera performance achieves this via the claimed mechanism of using a "touch function layer" to physically block "slits" in the pixel driving layer, or if it uses a fundamentally different technical approach to manage light transmission and interference.
  • A third question will be one of circuit-level identity: For the ’506 patent, which claims a specific arrangement of transistors and capacitors in a GOA charge pump circuit, the analysis will focus on whether the accused display drivers contain the exact "diode structure" and component layout claimed, raising detailed questions of literal infringement or functional equivalence at the microelectronic level.