DCT
2:25-cv-00759
Truesight Communications LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Truesight Communications LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:25-cv-00759, E.D. Tex., 08/01/2025
- Venue Allegations: Plaintiff alleges venue is proper because Samsung Electronics is a foreign corporation that may be sued in any district, and Samsung Electronics America has regular and established places of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that a wide range of Defendant’s smartphones, tablets, and computers, which are capable of downloading encrypted media for offline viewing, infringe a patent related to high-speed and secure content transfer methods.
- Technical Context: The technology concerns methods to improve the speed and security of downloading large, DRM-protected digital media files onto portable storage devices.
- Key Procedural History: The complaint alleges Defendant had knowledge of the asserted patent based on prior litigation filed by Plaintiff, including a suit against Samsung on different patents and a separate suit against another party, Transcend Information Inc., on the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2009-10-21 | '783 Patent Priority Date |
| 2015-03-10 | '783 Patent Issue Date |
| 2023-12-29 | Truesight sues Samsung on other patents (alleged knowledge date) |
| 2024-03-15 | Truesight sues Transcend Info. Inc. on '783 patent (alleged knowledge date) |
| 2025-08-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,977,783 - "High-Speed Secure Content Transfer to SD Card from Kiosk"
- Patent Identification: U.S. Patent No. 8,977,783, "High-Speed Secure Content Transfer to SD Card from Kiosk," issued March 10, 2015.
The Invention Explained
- Problem Addressed: The patent addresses the market demand for acquiring large digital media files, such as movies, in a quick and convenient manner, for example from a public kiosk to a portable storage device ('783 Patent, col. 1:16-21).
- The Patented Solution: The invention proposes a method to expedite the secure transfer of media to a storage device (like an SD card) by optimizing the write sequence. To increase speed, it first pre-allocates space for the media file, then writes all directory information and the large, encrypted media file to a general "unsecure" area of the storage device. Only after this transfer is complete does it write sensitive information, like decryption keys, to a separate "secure" area, thereby avoiding performance-slowing interruptions that occur when switching between writing different types of data ('783 Patent, col. 2:15-21; col. 9:50-63). The system architecture is depicted in the patent's figures, such as the process flow in Figure 3 ('783 Patent, Fig. 3).
- Technical Importance: This approach sought to improve the user experience by reducing wait times associated with downloading large, DRM-protected media files, a key friction point in digital content distribution ('783 Patent, col. 1:16-19).
Key Claims at a Glance
- The complaint asserts independent claim 12.
- The essential elements of claim 12 are:
- A non-transitory computer readable storage medium with instructions that, when executed, cause a processor to:
- identify a media file for download to an SD card;
- pre-allocate space on the SD card for an encrypted playable content portion of the media file, where the content is encrypted by a content key that is itself encrypted by a user key;
- write all directory blocks of the playable content portion together, and thereafter sequentially write all data blocks of that portion;
- write all data intended for an unsecure area of the SD card (including the encrypted content) prior in time to writing any data (except the user key) to a secure area of the SD card.
- The complaint's prayer for relief references infringement of "one or more claims," suggesting the potential to assert additional claims later in the litigation (Compl. Prayer for Relief ¶a).
III. The Accused Instrumentality
Product Identification
- The complaint identifies a broad range of "Accused Products," including Samsung Galaxy S series smartphones, Galaxy Tab series tablets, and Galaxy Book computers, with the Samsung Galaxy S25 Ultra identified as an exemplary product (Compl. ¶¶10, 15).
Functionality and Market Context
- The accused functionality involves the downloading of media content for offline viewing through pre-installed or user-installed applications such as Netflix, YouTube, Amazon Prime Video, and Google TV (Compl. ¶¶17, 19). The complaint alleges these devices use their internal UFS 4.0 flash storage as the "SD card," employ DRM systems like Google Widevine for encryption, and utilize technologies like the ExoPlayer media player and the F2FS file system to manage the download and storage process in an infringing manner (Compl. ¶¶16, 17, 19, 20). The complaint includes a screenshot of a description of the "fallocate" system call, which it alleges is used to perform the claimed "pre-allocate space" step (Compl. p. 11).
IV. Analysis of Infringement Allegations
'783 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A non-transitory computer readable storage medium storing instructions thereon... | The Samsung Galaxy S25 Ultra is alleged to comprise a non-transitory computer readable storage medium (e.g., UFS 4.0 flash storage) storing instructions. | ¶16 | col. 12:24-27 |
| identify a media file for download to an SD card; | The device, through applications like Netflix or YouTube, identifies media files (e.g., movies, TV shows) for download to its internal flash storage. | ¶17 | col. 9:1-3 |
| pre-allocate space on the SD card for a playable content portion of the media file, wherein the playable content portion...is encrypted by a content key that is encrypted by a user key; | The device allegedly pre-allocates storage space using a function like "fallocate". The media is allegedly encrypted using DRM technologies (e.g., Widevine) that use a multi-level key structure corresponding to the claimed content and user keys. | ¶18 | col. 9:46-49 |
| write all directory blocks together of the playable content portion of the media file and, thereafter in time, write all data blocks sequentially of the playable content portion of the media file; | This sequence is allegedly performed by the device's Flash-Friendly File System (F2FS) in conjunction with how media players like ExoPlayer store downloaded segments (e.g., MPEG-DASH or HLS files). A diagram from an article about ExoPlayer is provided to show how it handles offline download data flow (Compl. p. 14). | ¶20 | col. 9:50-56 |
| and write all data that is to be written to an unsecure area of the SD card, including the encrypted playable content, prior in time to writing any data to a secure area of the SD card, except for the user key. | It is alleged that all user-accessible data is written during the download, and only after the download is complete are keys written to a secure hardware-backed area like Samsung's TrustZone or Knox Vault. The complaint includes a Widevine ecosystem diagram illustrating the separation of media content and key handling (Compl. p. 13). | ¶21 | col. 10:56-65 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the patent's application to the accused technology. The patent is titled and repeatedly refers to an "SD Card" and a "kiosk." The complaint alleges infringement by a "smartphone" using its internal "UFS 4.0 flash storage" to download from cloud servers. This raises the question of whether the claim terms "SD card" and, by extension, the "kiosk" context, can be construed broadly enough to read on the accused products and their use case.
- Technical Questions: The complaint's infringement theory connects several standard technologies (F2FS, ExoPlayer, Widevine). A technical question for the court will be whether these components, when operating on a Samsung device, actually perform the specific, ordered sequence of steps mandated by claim 12. For instance, what evidence demonstrates that the device "write[s] all directory blocks together" before sequentially writing all data blocks, and that the final key storage in the TrustZone/Knox Vault occurs "prior in time" relative to all other data as claimed?
V. Key Claim Terms for Construction
The Term: "SD card"
Context and Importance: This term appears throughout the patent, including in the asserted claim. Its construction is critical because the accused products use internal UFS flash storage, not a removable Secure Digital card. The viability of the infringement claim may depend on whether this term is interpreted as exemplary of any personal storage medium or is limited to its plain and ordinary meaning.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses the invention in the context of various computing devices, including "a tablet computer, a netbook computer, a mobile phone or a smartphone" ('783 Patent, col. 2:48-50). It also refers more generally to a "storage medium" and "computer-readable medium," which could support an argument that "SD card" is merely an exemplary embodiment ('783 Patent, col. 1:30-32).
- Evidence for a Narrower Interpretation: The patent title, abstract, and claims consistently and specifically recite "SD card." The specification also discusses standards specific to SD cards, such as "CPRM for SD cards" ('783 Patent, col. 4:60-65). This repeated, specific usage may support a narrower construction limited to the well-known removable memory card format.
The Term: "kiosk"
Context and Importance: While not in the asserted claim, the term defines the context of the invention throughout the specification and title. Practitioners may focus on this term because the accused scenario involves a personal device downloading from a remote server, not interacting with a public terminal as "kiosk" typically implies. The interpretation of the overall inventive environment could influence the scope of the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the kiosk as part of a larger "kiosk distribution system" connected to servers via a network ('783 Patent, Fig. 1, col. 3:1-15). An argument could be made that a modern smartphone accessing a content delivery network is a functional equivalent of this system.
- Evidence for a Narrower Interpretation: The specification consistently describes the kiosk as a physical unit accessible to "customers" where they can "interact" and make selections, distinct from their own devices ('783 Patent, col. 1:19-26). This framing suggests a specific type of public-facing hardware, not a user's personal phone.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant supplies customers with products and provides user manuals and online support that instruct them how to use applications (e.g., Google TV, YouTube) to download media, thereby causing them to perform the infringing method (Compl. ¶¶22, 24). A screenshot from a Samsung user manual showing links to support for Google applications is provided as evidence (Compl. p. 17).
- Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the '783 Patent. Plaintiff points to two dates: December 29, 2023, when it sued Samsung on other patents (alleging a duty of diligence), and March 15, 2024, when it sued a different company on the '783 Patent itself. The complaint also alleges a policy of willful blindness (Compl. ¶23).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent's claim language, which is rooted in the technological context of a "kiosk" transferring content to an "SD card," be construed to cover the accused system of a personal "smartphone" using its internal flash memory to download content from a cloud-based service? The outcome of claim construction for these terms will likely be dispositive.
- A key evidentiary question will be one of technical implementation: does the specific combination of standard software components (e.g., F2FS, ExoPlayer, Widevine DRM) on Samsung's devices perform the precise, multi-step, and ordered write sequence recited in claim 12? The case may turn on factual evidence demonstrating whether the directory blocks, data blocks, and security keys are written in the exact temporal order required by the claim.