DCT
2:25-cv-00811
Kiwi Intellectual Assets Corp v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: KIWI Intellectual Assets Corporation (Taiwan)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Miller Fair Henry PLLC; Sheridan Ross P.C.
- Case Identification: 2:25-cv-00811, E.D. Tex., 08/18/2025
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics America, Inc. because it maintains a regular and established place of business in the district, and for Samsung Electronics Co., Ltd. because it is not a resident of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that a wide range of Defendant’s electronic products featuring USB-C compatible sockets infringe a reissued patent related to reversible electrical connector structures.
- Technical Context: The technology concerns the physical design of electrical sockets that allow a corresponding plug to be inserted in two different orientations (i.e., "right-side up" or "upside down") while maintaining a functional connection.
- Key Procedural History: The patent-in-suit is a reissued patent, which indicates it underwent a supplemental examination process at the USPTO after its original issuance to correct a perceived error, often related to the scope of the claims.
Case Timeline
| Date | Event |
|---|---|
| 2009-04-15 | Earliest Priority Date Claimed by RE50,307 Patent |
| 2025-02-18 | U.S. Reissued Patent No. RE50,307 Issues |
| 2025-08-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Reissued Patent No. RE50,307 - SOCKET STRUCTURE WITH DUPLEX ELECTRICAL CONNECTION
- Patent Identification: U.S. Reissued Patent No. RE50,307, "SOCKET STRUCTURE WITH DUPLEX ELECTRICAL CONNECTION," issued February 18, 2025 ('307 Patent).
The Invention Explained
- Problem Addressed: The patent describes the "well-known frustration" associated with prior art connectors like the USB-A plug, which can only be inserted in a single orientation (Compl. ¶24, ¶29). This design limitation results in a 50% chance of incorrect insertion on the first attempt, requiring the user to flip the plug over, which is described as an "inconvenient manner" (’307 Patent, col. 1:50-55).
- The Patented Solution: The invention is a socket structure featuring a central tongue with two rows of electrical contacts, one on the top surface and one on the bottom surface (’307 Patent, Abstract). By arranging these contacts in a "functional reverse mirror configuration," the socket can establish a correct electrical connection regardless of whether the corresponding plug is inserted normally or in the opposite (180-degree rotated) orientation, enabling "bidirectional insertion" (Compl. ¶32-33; ’307 Patent, col. 10:13-16). Figure 37 of the patent, referenced in the complaint, shows a front view of an embodiment with contacts (60, 70) visible on both sides of a central structure (50) (Compl. ¶31).
- Technical Importance: This duplex connection design provides a mechanical solution to the usability problem of single-orientation plugs, forming the basis for the reversible functionality that has become a key feature of modern connector standards (Compl. ¶25, ¶28).
Key Claims at a Glance
- The complaint asserts at least independent claim 34 (Compl. ¶46).
- Essential elements of independent claim 34 include:
- A plastic base, a connection slot, and a tongue with first and second surfaces containing grooves.
- The tongue's position within the slot creates chambers allowing a plug to be "normally and oppositely inserted."
- At least one row of "first contacts" is arranged on the tongue's first surface, and at least one row of "second contacts" is on the second surface.
- The structure is operative to "simultaneously electrically connect via the first and second contacts."
- The first contacts have a "functional reverse mirror configuration" relative to the second contacts.
- The structure is configured for two operational states (normal insertion and opposite insertion) where the connection slot is symmetric.
- The complaint does not explicitly reserve the right to assert other claims, but states that Defendants infringe "one or more" of the patent's 102 claims (Compl. ¶45).
III. The Accused Instrumentality
Product Identification
- The accused products are a broad range of Samsung devices that include a "USB-C-compatible interface or socket," including smartphones (Galaxy S24/S25 series), tablets (Galaxy Tab S9/S10 series), monitors (ViewFinity S8), laptops, power adapters, and portable hard drives (Portable SSD T7) (Compl. ¶34, ¶35, ¶37, ¶39, ¶41, ¶43).
Functionality and Market Context
- The accused functionality is the USB-C port (or "socket") on these devices (Compl. ¶43, ¶47). This port is a standardized connector that allows for reversible plug insertion for charging, data transfer, and video output. The complaint provides a user manual diagram showing a USB-C plug being connected to the Portable SSD T7 hard drive as an example of the accused functionality in practice (Compl. ¶36, Exhibit 2). The complaint alleges these products are offered for sale through Defendant's website and other channels (Compl. ¶35, ¶37).
IV. Analysis of Infringement Allegations
RE50,307 Infringement Allegations
| Claim Element (from Independent Claim 34) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a tongue, which has a first surface with grooves, and a second surface with grooves...the tongue being disposed...within the connection slot, such that chambers of the connection slot...allow the plug to be normally and oppositely inserted | The central structure within the accused products' USB-C sockets, which has contacts on its top and bottom surfaces and is designed to accept a reversible USB-C plug. | ¶34, ¶47 | col. 10:1-8 |
| at least one row of first contacts separately arranged on the first surface of the tongue...at least one row of second contacts separately arranged on the second surface of the tongue | The electrical contacts located on the top and bottom surfaces of the central structure within the USB-C sockets of the accused products. | ¶47 | col. 10:9-12 |
| the socket structure is operative to simultaneously electrically connect via the first and second contacts | The USB-C socket is alleged to be capable of making an electrical connection using the contacts on both the top and bottom surfaces of its internal tongue structure. | ¶47 | col. 10:13-14 |
| the at least one row of first contacts has a functional reverse mirror configuration relative to the at least one row of second contacts | The arrangement of pins in the accused USB-C sockets, which allows a reversible USB-C plug to function correctly regardless of its insertion orientation. | ¶31, ¶47 | col. 10:15-17 |
| a first operational state when the plug is normally inserted...a second operational state when the plug is oppositely inserted | The ability of the accused USB-C sockets to establish a functional connection with a USB-C plug when inserted in either of two possible orientations (0 or 180 degrees). The complaint references Figure 40 and 41 from the patent to illustrate this bidirectional insertion (Compl. ¶32). | ¶32, ¶36, ¶47 | col. 10:22-42 |
| wherein the connection slot is symmetric with symmetric up and down chambers, and symmetric left and right chambers around the tongue | The physical geometry of the accused USB-C port, which is alleged to be symmetric to allow for reversible plug insertion. | ¶47 | col. 10:31-34 |
Identified Points of Contention
- Scope Questions: The dispute may center on whether the term "functional reverse mirror configuration" as defined by the patent reads on the specific, standardized pinout and signaling protocol of the USB-C standard implemented in the accused products.
- Technical Questions: A potential point of contention is whether the physical construction of a standard USB-C socket meets the claim requirement that the "connection slot is symmetric." A defendant could argue that manufacturing tolerances or specific structural features of the USB-C standard introduce asymmetries that place the accused products outside the literal scope of the claim.
V. Key Claim Terms for Construction
"functional reverse mirror configuration"
- Context and Importance: This term is the central inventive concept recited in the claim, defining how the contacts are arranged to achieve reversible connectivity. The outcome of the case could depend heavily on whether this term is construed broadly to cover any arrangement that enables reversibility or narrowly to cover only the specific layouts disclosed in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the object of the invention as creating a connection in a "simple and easy way" when a plug is "normally and oppositely inserted" (’307 Patent, col. 2:1-3). This purpose-oriented language could support a construction that covers any contact arrangement achieving this functional result.
- Evidence for a Narrower Interpretation: The specification provides a specific example where terminals on one side have serial numbers "1, 2, 3, 4" and the opposite side has "4, 3, 2, 1" to ensure the "same signal sorting" (’307 Patent, col. 6:25-31). A defendant may argue this embodiment limits the term to a direct, pin-for-pin reversed physical mapping, which may differ from the more complex pin mapping of the USB-C standard.
"symmetric"
- Context and Importance: This term describes the required geometry of the "connection slot" and its "chambers." Practitioners may focus on this term because if the accused USB-C port can be shown to have a material asymmetry, it may fall outside the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the goal of the symmetric profiles is to allow the plug to be "normally and oppositely inserted and positioned" (’307 Patent, col. 5:58-64). This could support a functional definition, where any shape that permits reversible insertion is "symmetric" for the purposes of the claim.
- Evidence for a Narrower Interpretation: The term itself implies geometric precision. A defendant could argue that the plain and ordinary meaning requires mirror-image identity between the up/down and left/right chambers, and any deviation in the actual accused products defeats a finding of infringement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants’ customers directly infringe by using the accused products "as instructed by Defendants" through promotional materials and user manuals (Compl. ¶48). The complaint also makes a conclusory allegation of contributory infringement (Compl. ¶48).
- Willful Infringement: Willfulness is alleged based on knowledge of the ’307 Patent "at least as early as the filing of this Complaint" (Compl. ¶49, ¶51). No pre-suit knowledge or copying is alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical scope: does the claim term "functional reverse mirror configuration," as described in the ’307 Patent, encompass the specific, industry-standard pinout and logic of the USB-C connector, or is it limited to the particular embodiments disclosed in the patent?
- A second central question will be evidentiary and definitional: can the "symmetric" geometry required by Claim 34 for the connection slot and its chambers be proven to exist in the accused Samsung products, and will the court construe "symmetric" to require strict geometric identity or a more functional equivalence that allows for minor physical deviations?