DCT

2:25-cv-01012

Aq Corp v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01012, E.D. Tex., 10/07/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains a regular place of business in the district, employs personnel there, and conducts substantial business, including the sale of the accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy S, Z Fold, and Z Flip series smartphones infringe three U.S. patents related to the design of thin, flexible antenna modules for wireless charging.
  • Technical Context: The technology concerns compact, multi-function antenna assemblies for smartphones, which integrate different wireless capabilities (e.g., NFC, wireless charging) onto a single flexible circuit board to save space and improve performance.
  • Key Procedural History: The complaint alleges a prior business relationship where Plaintiff designed and supplied antennas to Defendant. Plaintiff claims it confidentially disclosed its new antenna design to Defendant in late 2019, filed for patent protection shortly after, and subsequently discovered that Defendant had adopted the allegedly proprietary design for its Galaxy S21 and later smartphones without permission.

Case Timeline

Date Event
2019-11-22 Plaintiff AQ confidentially pitches new antenna design to Samsung.
2019-11-27 Priority date for all Asserted Patents ('011, '875, '564 Patents).
2020-09-01 Samsung distributes design specifications for Galaxy S21 antenna.
2021-01-01 Samsung begins producing accused products with the Galaxy S21.
2022-04-12 U.S. Patent No. 11,303,011 issues.
2022-11-08 U.S. Patent No. 11,495,875 issues.
2023-08-15 U.S. Patent No. 11,728,564 issues.
2025-10-07 Complaint filed.

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

U.S. Patent No. 11,303,011 - "Smartphone Antenna in Flexible PCB"

The Invention Explained

  • Problem Addressed: The patent's background describes the challenge of incorporating antennas for functions like Near Field Communication (NFC) and Magnetic Secure Transmission (MST) into modern smartphones, where internal space is extremely limited by other components like batteries and cellular antennas (’011 Patent, col. 1:21-40).
  • The Patented Solution: The invention is a thin, flexible antenna module comprising multiple coil patterns formed on both the front and back surfaces of a flexible printed circuit board (FPCB) (’011 Patent, Abstract; col. 1:46-51). The design uses a specific geometric layout of concentric coils, radially aligned gaps breaking the coils, and parallel "extension lines" that run through these gaps to manage different antenna functions in a compact, integrated unit (’011 Patent, col. 7:43-col. 8:67). This structure allows for the co-location of wireless charging and NFC antenna functions.
  • Technical Importance: This integrated approach to antenna design aims to enable multiple wireless functions within the tight confines of a smartphone chassis while maintaining or improving performance characteristics like inductance and charging efficiency (Compl. ¶22).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶31).
  • The essential elements of claim 1 include:
    • A substrate with first and second major surfaces, each divided into central, inner ring, and outer ring portions.
    • A first antenna pattern on the first surface with an inner and outer coil.
    • A second antenna pattern on the second surface with NFC, inner, and outer antenna patterns.
    • The inner and outer patterns on the second surface are formed from "concentric C-shaped lines" that create radially-extending inner and outer gaps.
    • These gaps are "connected and aligned in a radial direction."
    • A specific arrangement of two NFC extension lines, an inner extension line, and an outer extension line running "substantially in parallel" through one or both of these gaps.
    • These extension lines on the second surface overlap the outer coil on the first surface.
    • The inner and outer coils on the first surface are "electrically connected in parallel."
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,495,875 - "Smartphone Antenna in Flexible PCB"

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’011 Patent, the ’875 Patent addresses the same technical problem of fitting multiple antennas into the constrained space of a smartphone (’875 Patent, col. 1:21-40).
  • The Patented Solution: The ’875 Patent also describes a multi-layered antenna module on a flexible PCB (’875 Patent, Abstract). It claims a structure with inner and outer coils on a first surface and corresponding inner and outer antenna patterns on a second surface. A key feature is the requirement that the patterns on the second surface are "connected to the inner coil through vias" and "connected to the outer coil through vias," establishing an electrical connection between the two sides of the substrate (’875 Patent, col. 41:52-col. 42:15).
  • Technical Importance: This design provides a specific method for integrating antenna patterns on opposite sides of a substrate to create a composite antenna structure, aiming for improved electrical performance and compact packaging (Compl. ¶22).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claim 6 (Compl. ¶54).
  • The essential elements of independent claim 1 include:
    • A substrate with first and second major surfaces.
    • A first antenna pattern on the first surface comprising an inner coil and an outer coil.
    • A second antenna pattern on the second surface comprising an inner antenna pattern and an outer antenna pattern.
    • The inner antenna pattern is made of "concentric circular lines," defines a "radially-extending inner gap," and is "connected to the inner coil through vias."
    • The outer antenna pattern is also made of "concentric circular lines," defines a "radially-extending outer gap," and is "connected to the outer coil through vias."
    • The inner and outer gaps are "connected and aligned."
    • A set of four extension lines (inner, outer, and two "additional") are formed on the second surface, extending through the gaps "generally in parallel."
    • Each of these four extension lines overlaps the outer coil on the first surface.
  • Dependent claim 6 adds the limitation that "the inner coil and the outer coil are electrically connected in parallel."
  • The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 11,728,564 - "Smartphone Antenna in Flexible PCB"

  • Technology Synopsis: This patent is a continuation of the applications leading to the '011 and '875 patents and relates to the same field of integrated antenna modules on a flexible PCB. The invention aims to solve space-constraint issues in smartphones by defining a specific layout of inner and outer coils on a first surface and corresponding antenna patterns on a second surface, which are interconnected through vias and separated by defined radial gaps (’564 Patent, col. 1:21-40; col. 41:49-col. 42:21).
  • Asserted Claims: Claims 1 and 8 (Compl. ¶77).
  • Accused Features: The complaint alleges that the wireless charging antennas in Samsung products, with the Samsung Galaxy S25 Edge serving as the exemplar, infringe the ’564 Patent. The infringing features are identified as the inner and outer coils and corresponding antenna patterns, radially-extending gaps, and vias connecting the layers, as shown in X-ray images of the device (Compl. ¶¶76, 80-86).

III. The Accused Instrumentality

Product Identification

The complaint identifies a wide range of Samsung smartphones, including the Galaxy S series (S21 through S25), Galaxy Z Fold series (Fold3 through Fold7), and Galaxy Z Flip series (Flip 4 through Flip 7) (Compl. ¶17). The Samsung Galaxy S21 Ultra is used as the representative accused product for the ’011 and ’875 Patents, while the Galaxy S25 Edge is used for the ’564 Patent (Compl. ¶¶31, 54, 76).

Functionality and Market Context

The accused functionality is the smartphone antenna module used for wireless charging, which the complaint alleges is a thin, flexible component containing antenna patterns on both sides of a flexible printed circuit board ("FPCB") (Compl. ¶¶17, 34). The complaint alleges these modules are optimized for features like Samsung's "Wireless PowerShare," which allows the phone to act as a wireless charger for other devices (Compl. ¶22). The accused products are positioned as flagship smartphone models for a major global manufacturer (Compl. ¶¶17-18). The complaint includes a screenshot from a YouTube teardown video showing the antenna module being removed from a Galaxy S21 Ultra (Compl. ¶34, p. 9).

IV. Analysis of Infringement Allegations

'011 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a substrate having a first major surface and a second major surface... The flexible printed circuit board ("FPCB") within the accused products' smartphone antenna module. ¶34 col. 1:46-49
the first major surface comprising a first central portion, a first inner ring portion..., and a first outer ring portion... The complaint presents an annotated X-ray image of the Galaxy S21 Ultra's antenna, identifying these three concentric regions on one surface of the FPCB. ¶35 col. 41:45-48
the second major surface comprising a second central portion..., a second inner ring portion..., and a second outer ring portion... An annotated X-ray image is used to identify three corresponding concentric regions on the opposing surface of the FPCB. ¶36 col. 41:49-54
a first antenna pattern formed on the first major surface and comprising an inner coil formed on the first inner ring portion and an outer coil on the first outer... An X-ray image with overlays identifies two distinct coils—an "Inner coil" and an "Outer coil"—allegedly formed on the first surface of the FPCB. ¶37 col. 41:55-58
the inner antenna pattern comprising a plurality of concentric C-shaped lines forming a radially-extending inner gap... An annotated X-ray image points to concentric conductive lines on the second surface, broken by a gap, which are alleged to be the claimed "C-shaped lines" forming an "inner gap." ¶39 col. 41:65-col. 42:2
the outer antenna pattern comprising a plurality of concentric C-shaped lines forming a radially-extending outer gap... An annotated X-ray image similarly identifies concentric conductive lines forming a "radially-extending outer gap" on the second surface. ¶40 col. 42:3-6
wherein the radially-extending outer gap... and the radially-extending inner gap... are connected and aligned in a radial direction; An annotated X-ray image shows the identified inner and outer gaps forming a single, continuous radial break in the antenna patterns. ¶41 col. 42:7-11
two NFC antenna extension lines..., an inner extension line..., and an outer extension line... extending along the radial direction through the... gap[s]; A series of annotated X-ray images identifies distinct conductive traces alleged to be the claimed NFC, inner, and outer extension lines running through the aligned gaps. ¶¶42-44 col. 43:6-21
wherein the two NFC antenna extension lines, the inner extension line, and the outer extension lines are extending substantially in parallel; An annotated X-ray image with color-coded overlays alleges that the identified extension lines run substantially parallel to one another within the radial gap. ¶45 col. 43:21-23
wherein each of the... extension lines... overlaps the outer coil formed on the first... major surface; An annotated X-ray image shows the path of the extension lines on the second surface superimposed over the location of the outer coil on the first surface. ¶46 col. 43:24-28
wherein the inner coil and the outer coil are electrically connected in parallel. This is asserted as a factual statement regarding the electrical configuration of the antenna module. ¶47 col. 44:4-6

Identified Points of Contention

  • Scope Questions: A central question may be whether the concentric conductive traces in the accused antenna, which are broken by a single radial gap, meet the claim limitation of a "plurality of concentric C-shaped lines." The interpretation of "C-shaped" will be critical. Additionally, the meaning of "substantially in parallel" will be at issue, as the complaint's own visual evidence appears to show some divergence in the paths of the accused extension lines (Compl. ¶45, p. 17).
  • Technical Questions: The claim requires several distinct "extension lines" (NFC, inner, outer). A technical question for the court will be whether the conductive traces highlighted in the complaint's exhibits function as the separate and distinct lines required by the claim, or if they are merely undifferentiated parts of a single, more complex conductive pattern that does not map cleanly onto the claim's architecture.

'875 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first antenna pattern formed on the first major surface and comprising an inner coil and an outer coil... The complaint presents an annotated X-ray image identifying an "Inner coil" and an "Outer coil" on what is alleged to be the first major surface of the FPCB. ¶58 col. 41:64-66
a second antenna pattern formed on the second major surface and comprising an inner antenna pattern, and an outer antenna pattern; An annotated X-ray image identifies an "Inner antenna pattern" and an "Outer antenna pattern" alleged to be on the second major surface. ¶59 col. 41:67-col. 42:2
the inner antenna pattern comprising a plurality of concentric circular lines and defining a radially-extending inner gap..., wherein at least part... overlaps the inner coil... and is connected to the inner coil through vias; The complaint uses annotated X-ray images to identify the "plurality of concentric circular lines" and the "radially-extending inner gap," and alleges the required overlap and connection via vias. No direct visual evidence of the vias is provided for this product. ¶60 col. 42:3-11
the outer antenna pattern comprising a plurality of concentric circular lines and defining a radially-extending outer gap..., wherein at least part... overlaps the outer coil... and is connected to the outer coil through vias; Using similar annotated X-ray images, the complaint identifies the concentric lines and outer gap of the outer pattern, and alleges the required overlap and connection via vias. No direct visual evidence of the vias is provided for this product. ¶61 col. 42:12-20
wherein at least part of the concentric circular lines of the outer antenna pattern generally surround at least part of the concentric circular lines of the inner antenna pattern, An annotated X-ray image shows the alleged outer antenna pattern traces located radially outside of the inner antenna pattern traces. ¶62 col. 42:21-24
wherein the radially extending outer gap and the radially-extending inner gap are connected and aligned in a direction; An annotated X-ray image shows the two gaps forming a single, continuous radial break in the concentric patterns. ¶63 col. 42:25-27
an inner extension line..., an outer extension line..., [and] two additional extension lines... extending generally in parallel; A series of annotated X-ray images identifies four sets of conductive traces alleged to be the claimed extension lines, with a color-coded image used to show they are "generally in parallel." ¶¶64-67 col. 42:28-42
wherein each of the... extension lines... comprises a portion that overlaps the outer coil formed on the first major surface. An annotated X-ray image shows the path of the four alleged extension lines on the second surface superimposed over the location of the outer coil on the first surface. ¶68 col. 42:43-47

Identified Points of Contention

  • Scope Questions: The term "generally surround" will likely be a point of construction, focusing on how complete the encirclement of the inner pattern by the outer pattern must be. The phrase "generally in parallel" will also be at issue for the same reasons discussed in the '011 Patent analysis.
  • Technical Questions: A key evidentiary question will be whether Plaintiff can prove that the antenna patterns on the two surfaces are "connected... through vias" as required by the claim. The complaint makes this allegation for the Galaxy S21 Ultra but does not provide direct visual evidence of the via structures themselves, relying instead on overlapping X-ray images that show the patterns on both sides simultaneously (Compl. ¶57, p. 20).

V. Key Claim Terms for Construction

"plurality of concentric C-shaped lines" (’011 Patent, Claim 1)

  • Context and Importance: This term defines the fundamental structure of the antenna patterns on the second surface. The infringement reading depends on whether the accused patterns, which appear as nearly complete circles broken by a single radial gap, qualify as "C-shaped."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification's figures, such as Figure 47, depict patterns of concentric circles with a distinct radial gap, which is consistent with the structures shown in the complaint's infringement allegations. This may support an interpretation where any non-closed circular line is considered "C-shaped."
    • Evidence for a Narrower Interpretation: A defendant may argue that the term "C-shaped" implies a more open arc than a nearly-closed circle. If any embodiment in the specification shows a more pronounced "C" geometry, it could be used to argue for a narrower construction that excludes the accused structures.

"connected to the... coil through vias" (’875 Patent, Claim 1)

  • Context and Importance: This limitation requires a specific physical and electrical connection between the patterns on the first and second surfaces of the substrate. Proving infringement of the ’875 Patent hinges on demonstrating the existence of these "vias."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that "vias" should be given its ordinary meaning in the context of PCB fabrication, covering any conductive pathway between layers, and that such connections can be inferred from the operation of the device.
    • Evidence for a Narrower Interpretation: "Vias" is a well-established term of art referring to plated through-holes. Defendant may argue that the term requires a specific structure that must be proven with direct evidence (e.g., from a cross-sectional analysis), which the complaint's X-ray images of the S21 Ultra do not provide. The specification mentions vias in the context of connecting different layers of a flexible PCB (e.g., ’875 Patent, col. 8:50-51), which supports interpreting the term according to its standard meaning in the art.

VI. Other Allegations

Indirect Infringement

The complaint does not include counts for indirect infringement.

Willful Infringement

The complaint alleges willful infringement for all three Asserted Patents (Compl. ¶¶50, 72, 89). The allegations are based on alleged pre-suit knowledge stemming from a history between the parties. Plaintiff alleges it confidentially pitched the patented design to Samsung in November 2019, later informed Samsung that a patent application had been filed, and complained directly to Samsung employees about infringement in the Galaxy S21 antenna before the patents issued, which Samsung allegedly denied (Compl. ¶¶22, 23, 25).

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

  • A core issue will be one of definitional scope: can claim terms describing specific geometries, such as "C-shaped lines," and terms of degree, such as "substantially in parallel," be construed to cover the physical layout of the conductive traces in Samsung's antenna modules?
  • A second central issue will be one of evidentiary proof: does the evidence presented, primarily consisting of two-dimensional X-ray images, sufficiently demonstrate the existence of three-dimensional structures required by some claims, such as the "vias" connecting different layers of the flexible PCB?
  • Finally, the case will present a significant question regarding intent: given the detailed allegations of a confidential disclosure and pre-suit notice, the court will have to examine whether Samsung’s antenna design was independently developed or was derived from Plaintiff’s technology, which will be central to the claim for willful infringement.