DCT

2:25-cv-00980

Polaris Wireless Inc v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00980, E.D. Tex., 09/29/2025
  • Venue Allegations: Venue is alleged as proper for Samsung Electronics America, Inc. because it maintains a regular and established place of business in Plano, Texas, within the district. Venue is alleged as proper for Samsung Electronics Co., Ltd. on the basis that it is a foreign corporation and may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile devices and associated location services infringe six patents related to wireless geolocation technology, including methods for improving accuracy through signal-strength analysis and the use of atmospheric data.
  • Technical Context: Wireless geolocation technology is fundamental to a wide range of modern applications, from E911 emergency services and national security to consumer-facing navigation and asset tracking.
  • Key Procedural History: The complaint alleges that Defendant was aware of the asserted patents and their relevance to its business since at least 2023, when Defendant cited several Polaris patents as prior art in inter partes review (IPR) proceedings it initiated against patents held by a third party, Broadphone LLC. The complaint also alleges Defendant gained knowledge through business discussions with Plaintiff between 2018 and 2019 and by hiring at least five former Polaris employees.

Case Timeline

Date Event
2003-02-04 ’166 Patent Priority Date
2003-07-19 ’987 Patent Priority Date
2006-01-06 ’762 Patent Priority Date
2006-10-03 ’987 Patent Issue Date
2006-10-26 ’278 Patent Priority Date
2010-07-13 ’278 Patent Issue Date
2010-12-07 ’762 Patent Issue Date
2013-03-26 ’166 Patent Issue Date
2014-08-06 ’423 Patent Priority Date
2014-08-06 ’811 Patent Priority Date
2016-01-12 ’423 Patent Issue Date
2016-08-30 ’811 Patent Issue Date
2020-10-01 Accused SmartThings Find service launched
2023-01-01 Samsung files IPRs citing Polaris patents as prior art
2025-09-29 Complaint Filing Date

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

U.S. Patent No. 8,406,166 - "location estimation of wireless terminals through pattern matching of signal-strength differentials,"

The Invention Explained

  • Problem Addressed: Various factors—such as the make and model of a wireless terminal, its antenna and battery condition, and whether it is in a vehicle—can introduce errors and biases into signal strength measurements, reducing the accuracy of location estimations that rely on them (Compl. ¶45; ’166 Patent, col. 3:25-33).
  • The Patented Solution: The invention proposes to ameliorate these biases by calculating the difference in signal strength between signals received from two or more transmitters. This differential value is compared to a database of expected differential values to estimate location. The technique is based on the principle that many sources of error will affect both signal measurements similarly, making their difference a more stable metric than their absolute values (Compl. ¶45; ’166 Patent, col. 3:34-38, 3:59-62).
  • Technical Importance: This approach provided a more robust, software-based method for location estimation that is less sensitive to hardware and environmental variations, thereby improving accuracy over methods that rely on absolute signal strength (Compl. ¶¶ 18-19, 45).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶86).
  • Claim 1 is a method claim comprising the essential elements of:
    • Receiving a first signal-strength measurement for a first signal at a wireless terminal.
    • Receiving a second signal-strength measurement for a second signal at the wireless terminal, where the signals are from different transmitters at different locations.
    • Estimating the terminal's location by pattern matching the difference of the first and second measurements against a signal-strength database that associates locations with tuples of first and second signal-strength measurements.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,753,278 - "estimating the location of a wireless terminal based on non-uniform locations,"

The Invention Explained

  • Problem Addressed: Traditional location estimation methods often rely on databases that map signal traits to uniform geographic grids, which may not accurately reflect the real-world environment with its varied topography and structures (Compl. ¶50; ’278 Patent, col. 1:17-26).
  • The Patented Solution: The invention describes building a location-trait database by partitioning a geographic region into a plurality of locations whose boundaries are based, at least in part, on empirical data, such as the physical attributes of the environment (e.g., roads, buildings, parks). A terminal's location is then estimated by comparing a measured signal trait to the expected value for one or more of these non-uniform locations (Compl. ¶¶ 51, 92; ’278 Patent, col. 1:49-54, Fig. 5).
  • Technical Importance: This method allows for the creation of more accurate location databases by defining location boundaries that correspond to actual physical features, rather than an arbitrary grid, making pattern matching more precise (’278 Patent, col. 1:49-54).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶91).
  • Claim 1 is a method claim comprising the essential elements of:
    • Estimating the location of a wireless terminal by comparing a measured signal trait to an expected value for one or more of a plurality of locations.
    • Wherein the boundaries of one or more of these locations are based, at least in part, on empirical data regarding the location of individuals in the environment.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,848,762 - "Computationally Efficient Estimation of the Location of a Wireless Terminal Based on Pattern Matching,"

  • Technology Synopsis: The patent addresses the problem that generating multi-dimensional probability distributions for location estimation can be computationally intensive (Compl. ¶56; ’762 Patent, col. 19:14-18). The proposed solution is a method to improve computational efficiency by designating certain potential locations as "improbable" early in the process, thereby reducing the search space and eliminating those locations from more intensive calculations (’762 Patent, col. 19:18-41).
  • Asserted Claims: At least independent claim 1 (Compl. ¶96).
  • Accused Features: Samsung's location calculation process, which allegedly "designates certain possible locations of the device as improbable" using techniques like geographic filtering or signal improbability filtering (Compl. ¶¶ 81, 97).

U.S. Patent No. 7,116,987 - "Location estimation of wireless terminals through pattern matching of deduced and empirical signal-strength measurements,"

  • Technology Synopsis: The patent addresses the desire to use more signal-strength measurements to enhance location accuracy, even when a wireless terminal cannot physically measure all relevant signals (Compl. ¶¶ 58-59). The solution involves "deducing" the signal strength of a downlink signal (from a base station to the terminal) based on the measured strength of an uplink signal (from the terminal to the base station), using the principle of reciprocity. These deduced measurements are then used, alone or in combination with empirically measured signals, to estimate location (’987 Patent, col. 3:65-4:7).
  • Asserted Claims: At least independent claim 1 (Compl. ¶101).
  • Accused Features: Samsung Galaxy devices allegedly can transmit signals to access points and "use those transmitted signal measurements to deduce access point signal strength" (Compl. ¶¶ 80, 102).

U.S. Patent No. 9,237,423 - "Estimating the elevation of a wireless terminal based on temperature and atmospheric pressure,"

  • Technology Synopsis: The patent addresses inaccuracies in estimating a wireless terminal's vertical location (elevation) within tall buildings, which can be caused by the atmospheric "stack effect" (Compl. ¶63). The invention teaches a process for generating an elevation estimate based on a barometric pressure measurement at the terminal, which is then compared to a "stack-effect compensation model" selected based on the terminal's estimated lateral location (’423 Patent, col. 9:53-67).
  • Asserted Claims: At least independent claim 13 (Compl. ¶106).
  • Accused Features: Samsung Galaxy devices, which include barometric sensors, are accused of performing elevation calculations using these methods. The complaint includes a screenshot from a Samsung specification sheet highlighting the "Barometer" sensor (Compl. p. 25; Compl. ¶¶ 83, 107).

U.S. Patent No. 9,432,811 - "Estimating the Lateral Location of a Wireless Terminal Based on Temperature and Atmospheric Pressure,"

  • Technology Synopsis: This patent seeks to improve the accuracy of lateral (i.e., XY) location estimates by using atmospheric data (Compl. ¶68). The solution involves using atmospheric pressure measurements to designate certain possible lateral locations as "improbable." For example, if a pressure reading implies an elevation that is higher than any building at a given lateral location, that lateral location can be eliminated from consideration, thus narrowing the search space for the final lateral estimate (’811 Patent, col. 11:26-66).
  • Asserted Claims: At least independent claim 7 (Compl. ¶112).
  • Accused Features: Samsung's alleged process of designating possible locations as improbable based on barometric pressure measurements, such as "to discount locations where a device reads an atmospheric pressure that indicates it is located in an uninhabitable location" (Compl. ¶¶ 83, 113).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Samsung wireless devices, including Galaxy smartphones, tablets, and watches, that perform location-based services (Compl. ¶¶ 73-74). Specific services mentioned include "SmartThings Find" and the enterprise-focused "Knox Asset Intelligence" (Compl. ¶¶ 74, 76).

Functionality and Market Context

The accused devices are alleged to perform location estimation using a combination of signals from GPS, Wi-Fi, and cellular networks, as well as data from embedded sensors such as barometers (Compl. ¶¶ 78-80). The complaint alleges these devices measure signal traits such as Received Signal Strength Indicator ("RSSI"), compare these measurements to a database of known signal characteristics, and can deduce signal strength from transmitted signals (Compl. ¶¶ 80-81). Samsung's services also allegedly incorporate third-party APIs, such as Google's Network Location Provider, to improve accuracy (Compl. ¶82). A screenshot provided in the complaint shows the user interface for activating these location services on a Samsung device (Compl. p. 24). Samsung is identified as a leading global manufacturer and seller of mobile devices, and its SmartThings application is alleged to have over one billion downloads (Compl. ¶¶ 3, 75).

IV. Analysis of Infringement Allegations

’166 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving a first signal-strength measurement for a first signal at the wireless terminal ... [and] receiving a second signal-strength measurement for a second signal at the wireless terminal, wherein the first signal is transmitted by a first transmitter at a first location and the second signal is transmitted by a second transmitter at a second location that is different from the first location Samsung devices receive and process signal strength measurements (e.g., RSSI) from multiple distinct access points, such as cellular base stations or Wi-Fi routers. ¶¶ 78-80, 82, 87 col. 6:17-19
estimating the location of the wireless terminal by pattern matching the difference of the first signal-strength measurement minus the second signal-strength measurement against a signal-strength database that associates location with tuples of first signal signal-strength measurements and second signal signal-strength measurements Samsung performs a method for estimating a location by pattern matching the difference between the two signal-strength measurements against a database that associates locations with tuples of signal-strength measurements. ¶87 col. 6:19-23

’278 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
estimating the location of a wireless terminal in an environment based on comparing a measurement of a trait of a signal processed by said wireless terminal to an expected value of said trait for one or more of a plurality of locations Samsung devices compare measured signal characteristics, such as RSSI received from multiple access points, to known or expected RSSI values from a location database to calculate the device's location. ¶¶ 81, 92 col. 1:42-49
wherein the boundaries of one or more of said plurality of locations are based, at least in part, on empirical data regarding the location of individuals in said environment The boundaries of the locations in Samsung's location database are alleged to be based, at least in part, on empirical data, such as "crowdsourced access point data." ¶¶ 81, 92 col. 1:49-54

Identified Points of Contention

  • ’166 Patent: A primary point of contention may be evidentiary and technical. The complaint alleges that Samsung performs "pattern matching the difference" of signal strengths (Compl. ¶87). The question for the court will be whether the specific algorithms used in Samsung's location services, which may rely on complex data fusion from multiple sources including third-party APIs, actually calculate a simple difference between two signal strengths and match that value as required by the claim, or if they employ a different, non-infringing method (e.g., vector matching of absolute values).
  • ’278 Patent: The analysis may focus on claim scope. A key question will be whether the use of "crowdsourced access point data" (Compl. ¶81) satisfies the claim limitation that location boundaries are "based, at least in part, on empirical data regarding the location of individuals in said environment." A dispute may arise over whether this limitation requires a deliberate partitioning of geography based on known human activity or physical structures, as depicted in the patent's figures, or if the passive collection of signal data that happens to originate from users' devices is sufficient.

V. Key Claim Terms for Construction

’166 Patent, Claim 1: "pattern matching the difference of the first signal-strength measurement minus the second signal-strength measurement against a signal-strength database"

  • Context and Importance: This term recites the core functional step of the claim. Its construction will be critical to determining infringement, as the dispute may turn on the precise nature of Samsung's algorithm and database structure. Practitioners may focus on this term because it contains both the mathematical operation ("difference") and the type of comparison ("pattern matching") that define the invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the process in general terms, stating the invention "computes the signal-strength differentials for the reported values" and then generates a probability distribution based on a "goodness of fit" with database values (’166 Patent, col. 14:26-38). This may support an interpretation that covers various statistical matching techniques applied to a calculated differential.
    • Evidence for a Narrower Interpretation: The claim language recites matching the "difference...against a signal-strength database that associates location with tuples of first signal signal-strength measurements and second signal signal-strength measurements." A party could argue this requires a specific sequence: calculating a difference from live measurements and then comparing that single value to a database of raw measurement tuples, rather than, for example, comparing a vector of live measurements to a database of pre-calculated differentials.

’278 Patent, Claim 1: "boundaries of one or more of said plurality of locations are based, at least in part, on empirical data regarding the location of individuals in said environment"

  • Context and Importance: This term defines the novel structure of the location database that distinguishes it from a simple uniform grid. The interpretation of what constitutes "empirical data regarding the location of individuals" will be central to whether Samsung's use of crowdsourced data infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The phrase "based, at least in part" suggests that any influence from such data could suffice. The patent's summary states the invention is based on the recognition that signal traits are dependent on "topography, the receiver, the location of the transmitter, and other factors" (’278 Patent, col. 1:20-23), which could be read broadly to include any real-world data.
    • Evidence for a Narrower Interpretation: The detailed description and figures show locations partitioned along clear physical and man-made features like roads, parks, and building footprints (’278 Patent, Figs. 6a-6k, col. 9:5-30). This may support an argument that the "empirical data" must be used to define boundaries that correlate to tangible aspects of the environment where individuals are located, not just an amorphous collection of signal data points.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement of infringement for all six patents, asserting that Samsung encourages its "third-party vendors to infringe" (Compl. ¶¶ 88, 93, 98, 103, 108, 114). The complaint also includes screenshots of Samsung's instructions to end-users on how to enable the accused location services, which may also form a basis for inducement allegations (Compl. p. 24).
  • Willful Infringement: Willfulness is alleged for all six patents (Compl. ¶¶ 89, 94, 99, 104, 109, 115). The complaint alleges pre-suit knowledge based on multiple grounds, including: (1) Defendant's use of Polaris patents as prior art in IPR proceedings it filed against another company's patents, allegedly beginning in 2023 (Compl. ¶¶ 31-33); (2) business development meetings between 2018-2019 where Plaintiff allegedly shared information about its "deep patent portfolio" (Compl. ¶¶ 38-41); and (3) Defendant's hiring of former Plaintiff employees (Compl. ¶36).

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

  • A central evidentiary question will be one of algorithmic correspondence: Does the software in Samsung's accused devices, which integrates multiple data sources and third-party APIs like Google's Fused Location Provider, actually execute the specific methods claimed in the patents—such as "pattern matching the difference" of signal strengths (’166 Patent) or deducing downlink strength from uplink signals (’987 Patent)—or does it achieve a similar result through technically distinct, non-infringing means?
  • A core issue of claim construction will be whether the use of "crowdsourced access point data" satisfies the ’278 Patent’s requirement that location "boundaries" be "based...on empirical data regarding the location of individuals," or if that claim requires a more deliberate partitioning of a geographic area based on defined physical structures.
  • A key question for damages will be willfulness: Given the detailed allegations that Samsung analyzed and relied upon Polaris's patents in its own IPR proceedings years before this suit was filed, can Samsung establish a good-faith belief of non-infringement or invalidity sufficient to rebut the claim of willful infringement?