DCT
2:25-cv-01041
Tactual Labs IP LLC v. Samsung Electronics Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Tactual Labs IP LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Daignault Iyer LLP
- Case Identification: 2:25-cv-01041, E.D. Tex., 10/10/2025
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics America, Inc. based on a regular and established place of business in Plano, Texas, and for Samsung Electronics Co., Ltd. as a foreign entity for which venue is proper in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s Galaxy smartphones and tablets equipped with the S Pen stylus infringe patents related to low-latency processing of user input.
- Technical Context: The technology addresses the perceptible lag between a user's physical input (e.g., a stylus stroke) and the corresponding digital feedback (e.g., the appearance of a digital ink line), which is a critical factor in creating a natural user experience.
- Key Procedural History: The complaint alleges an extensive pre-suit history between Plaintiff’s predecessor-in-interest and Samsung, beginning in 2014. This history includes multiple non-disclosure agreements, joint testing of Plaintiff's "Reflex™" low-latency software on Samsung prototype devices, and licensing discussions during which Plaintiff allegedly disclosed its patent portfolio. Plaintiff alleges that after gaining a deep understanding of the technology, Samsung abruptly terminated licensing discussions and subsequently incorporated the patented technology into its products.
Case Timeline
| Date | Event |
|---|---|
| 2012-10-05 | Earliest Priority Date for '500 and '952 Patents |
| 2013-07-12 | Earliest Priority Date for '615 Patent |
| 2014-06-01 | Samsung invites Tactual Labs Co. to present technology at a workshop |
| 2015-11-01 | Parties enter into a Non-Disclosure Agreement |
| 2016-02-01 | Tactual presents "Tactual Reflex Testing Report on Samsung Galaxy Note" |
| 2016-04-01 | Tactual presents technology to Samsung Display in Asia |
| 2016-06-01 | Tactual presents technology to Samsung Mobile Senior Leadership |
| 2016-06-30 | Samsung's R&D and Strategy teams hold executive evaluation of technology |
| 2016-11-29 | U.S. Patent No. 9,507,500 Issues |
| 2017-03-01 | Tactual provides licensing presentation to Samsung, including patent portfolio details |
| 2017-04-25 | U.S. Patent No. 9,632,615 Issues |
| 2017-06-01 | Tactual loans Samsung a touch unit with Reflex™ software for analysis |
| 2017-11-01 | Samsung returns the loaned touch unit after several months |
| 2019-01-01 | Samsung allegedly begins releasing infringing products |
| 2019-03-05 | U.S. Patent No. 10,222,952 Issues |
| 2025-10-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,507,500 - Hybrid Systems and Methods for Low-Latency User Input Processing and Feedback
- Issued: November 29, 2016
The Invention Explained
- Problem Addressed: The patent addresses the problem of latency in direct manipulation user interfaces—the time delay between a user's physical action, such as moving a finger or stylus on a screen, and the system's visual response ('500 Patent, col. 3:17-21). This delay, or "lag," can make digital interactions feel disconnected and unnatural compared to interactions with physical objects (Compl. ¶30).
- The Patented Solution: The patent describes a "hybrid feedback" architecture that processes user input along two parallel paths. A dedicated "low-latency subsystem," often implemented in hardware, generates an immediate, potentially simplified, visual response (e.g., a basic outline). Simultaneously, the conventional "high-latency subsystem" (e.g., the main CPU and software stack) processes the input to generate the full-featured, application-aware response. The system then combines or overlays these two visual outputs on the display, giving the user instant feedback to bridge the perceptual gap while the main system completes its more complex processing ('500 Patent, Abstract; Fig. 9).
- Technical Importance: This dual-path approach aims to create the perception of instantaneous system response, which is critical for precision tasks like digital inking and makes user interfaces feel more intuitive and physically realistic ('500 Patent, col. 3:10-16).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶39).
- Essential elements of claim 1 include:
- A display, a user input device, and an input processing system that emits signals based on user input.
- A "first graphical processing and output system" (high-latency) comprising software that receives the signals and generates high-latency data.
- A "second graphical processing and output system" (low-latency), implemented at least partially in hardware, that substantially simultaneously receives the signals and generates low-latency data.
- The second system outputs its low-latency data with lower latency relative to the first system's high-latency data.
- The display is configured to show both the low-latency data and the high-latency data.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,632,615 - Reducing Control Response Latency with Defined Cross-Control Behavior
- Issued: April 25, 2017
The Invention Explained
- Problem Addressed: Traditional user interfaces handle interactions where one control element affects another (e.g., a button that closes a window) through the main application logic, which introduces perceptible latency ('615 Patent, col. 18:50-58). This patent extends the low-latency concept to accelerate these more complex "cross-control behaviors."
- The Patented Solution: The invention proposes a system where the low-latency hardware subsystem is not only aware of direct manipulation but is also configured to implement predefined interactions between different controls. Input signals received by the low-latency subsystem include an "identification of a cross-control behavior," and the hardware is configured to execute this behavior and generate an immediate low-latency output that reflects the interaction, without waiting for the high-latency application logic ('615 Patent, Abstract; col. 20:44-59).
- Technical Importance: This approach allows for the acceleration of more complex user interface logic beyond simple object manipulation, contributing to a more holistically responsive user experience ('615 Patent, col. 20:3-10).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶58).
- Claim 1 is structurally similar to claim 1 of the '500 patent but adds requirements specific to cross-control behavior:
- It includes the same elements of a display, input device, input processor, a first (high-latency) system, and a second (low-latency) system.
- It further requires that the signals received by the second (low-latency) system "comprise an identification of a cross-control behavior."
- It requires the second system to comprise "hardware configured to implement the cross-control behavior."
- It requires the generated "low-latency data comprises data reflecting the cross-control behavior."
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,222,952 - Hybrid Systems and Methods for Low-Latency User Input Processing and Feedback
- Issued: March 5, 2019
Technology Synopsis
This patent, related to the '500 patent, describes a dual-path input processing system to reduce latency. It specifically claims a low-latency subsystem that generates a "programmable output" that is based, at least in part, on "state information" maintained by the high-latency subsystem ('952 Patent, Abstract; col. 22:7-21). This allows the immediate, low-latency feedback to be context-aware based on the broader state of the application.
Asserted Claims
The complaint asserts independent claim 16 (Compl. ¶77).
Accused Features
The complaint alleges that when a user writes with the S Pen, the GPU (low-latency subsystem) immediately renders handwriting strokes. This rendering is allegedly based on state information from the NPU (high-latency subsystem), which is maintaining the state of the handwriting event in preparation for converting the strokes to text (Compl. ¶¶80-81).
III. The Accused Instrumentality
Product Identification
- Samsung Galaxy S and Note series smartphones and tablets, the Samsung S Pen stylus, and related applications such as PENUP (Compl. ¶5). The complaint uses the Samsung Galaxy S25 Ultra as a representative example.
Functionality and Market Context
- The accused functionality centers on the S Pen's handwriting and drawing capabilities, particularly the handwriting-to-text conversion feature (Compl. ¶45). The complaint alleges that this functionality is implemented using a dual-path processing architecture. It claims a Graphics Processing Unit (GPU) serves as a low-latency system to immediately render digital ink strokes on the screen, while a Neural Processing Unit (NPU) acts as a high-latency system to perform handwriting recognition and convert those strokes into digital text (Compl. ¶¶44, 46). A diagram from a Samsung source illustrates the interaction between the S Pen and the device's digitizer to recognize pen location and pressure (Compl. p. 13).
- The complaint alleges that Samsung has marketed the "greatly reduced latency" of its S Pen as a key feature, positioning it as a tool for precise and fluid digital writing (Compl. ¶24).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,507,500 - Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display comprising a visualization of a user interface | The Dynamic AMOLED 2X display showing Samsung's One UI. | ¶41 | col. 4:51-53 |
| a user input device... adapted to output signals corresponding to user input | The S Pen and the embedded touch screen digitizer that detects the S Pen's movement. | ¶42 | col. 4:47-50 |
| an input processing system... adapted to receive the signals... and to emit signals | The device's digitizer, which receives Electromagnetic Resonance signals from the S Pen and emits digital signals indicating pen position. | ¶43 | col. 13:6-10 |
| a first graphical processing and output system comprising software... adapted to... generate high-latency data | The Snapdragon Neural Processing Unit (NPU) running a handwriting recognition algorithm, which processes pen position signals to generate high-latency text data. | ¶¶44-45 | col. 4:14-17 |
| a second graphical processing and output system implemented at least partially in hardware... adapted to substantially simultaneously receive... signals and to generate low-latency data | The Adreno GPU within the Snapdragon chipset, which simultaneously receives pen position signals and generates low-latency data representing handwriting strokes. | ¶¶46-47 | col. 4:9-13 |
| wherein... the second graphical processing and output system is adapted to output the generated low-latency data with low latency relative to the output of the high-latency data | The handwriting strokes (low-latency) are displayed first, and are then converted into text (high-latency). A screenshot from a Samsung video shows the handwritten phrase "Call Joel!" being converted to text "in real time" (Compl. p. 15). | ¶48 | col. 4:1-8 |
| the display being configured to display at least some of the low-latency data and at least some of the high-latency data | The display shows both the initial handwriting strokes (low-latency) and the final converted text (high-latency), as depicted in screenshots (Compl. p. 18). | ¶49 | col. 8:51-58 |
Identified Points of Contention
- Scope Questions: A potential dispute may arise over whether the NPU and GPU, as components of an integrated System-on-Chip (SoC), constitute distinct "first" and "second" graphical processing and output "subsystems" as contemplated by the patent's architecture, or if they are more accurately viewed as different functional units within a single, unified system.
- Technical Questions: The claim requires the low-latency and high-latency systems to "substantially simultaneously receive" the input signals. The evidentiary basis for this timing relationship between the GPU and NPU in the accused devices will likely be a point of factual contention.
U.S. Patent No. 9,632,615 - Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [Elements regarding display, input device, input processor, first system, and second system] | The complaint incorporates by reference its allegations for the '500 patent, mapping these elements to the display, S Pen, digitizer, NPU, and GPU. | ¶¶60-64 | col. 4:18-38 |
| wherein the at least some of the emitted signals received by the second graphical processing and output system comprise an identification of a cross-control behavior | The complaint alleges that the S Pen handwriting strokes trigger the "cross-control behavior," which it identifies as the conversion of the handwriting to text by a separate processing unit. | ¶66 | col. 1:1-6 |
| the second graphical processing and output system comprises hardware configured to implement the cross-control behavior | The Qualcomm Snapdragon 8 Elite chipset, which contains the GPU and NPU, is identified as the hardware configured to implement the behavior. | ¶65 | col. 20:53-56 |
| and the generated low-latency data comprises data reflecting the cross-control behavior | The process where the initial handwriting strokes (low-latency data) disappear after the handwriting stops is alleged to reflect the completion of the cross-control behavior. | ¶66 | col. 20:57-59 |
Identified Points of Contention
- Scope Questions: The central dispute for this patent will likely be the definition of "cross-control behavior." The question is whether the conversion of handwriting data into text data by different processing units falls within a scope that the patent specification appears to exemplify with interactions between discrete UI controls (e.g., a button affecting a window).
- Technical Questions: It may be contested whether the S Pen input signals inherently "comprise an identification of a cross-control behavior," or if this identification is a result of subsequent logic that falls outside the scope of the claim.
V. Key Claim Terms for Construction
"substantially simultaneously receive" ('500 Patent, Claim 1)
- Context and Importance: This term is critical for establishing the parallel processing architecture central to the patent. The infringement theory depends on showing that the alleged high-latency (NPU) and low-latency (GPU) paths receive the same input signals at roughly the same time.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's description of a system where "UI events are then processed in parallel by two subsystems" could support an interpretation that does not require receipt in the exact same clock cycle, but rather a general parallel availability of the data stream ('500 Patent, col. 13:9-12).
- Evidence for a Narrower Interpretation: The depiction in Figure 9, where a single Input Processing Unit (IPU) emits events to both subsystems, could be used to argue for a tighter temporal coupling, suggesting the signals are dispatched from a single point at the same moment.
"cross-control behavior" ('615 Patent, Claim 1)
- Context and Importance: This term defines the core inventive concept of the '615 patent. The viability of the infringement allegation depends on whether the handwriting-to-text conversion process is considered a "cross-control behavior."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent title, "Reducing Control Response Latency with Defined Cross-Control Behavior," could support a reading where any defined interaction between different processing components in response to a control input qualifies. The complaint's theory suggests the "handwriting" acts as a control that triggers a behavior in the text-processing system.
- Evidence for a Narrower Interpretation: The patent's detailed description provides examples such as a button closing a parent window or a checkbox enabling other controls ('615 Patent, col. 21:11-25; col. 22:48-54). This may support a narrower construction limited to interactions between discrete, user-facing graphical UI elements, rather than an internal data transformation process like handwriting recognition.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Samsung publishes marketing materials, user manuals, and online support resources that instruct and encourage customers to use the accused S-Pen features, including handwriting-to-text conversion (Compl. ¶¶52, 71, 84). It also alleges contributory infringement on the basis that the S Pen and associated hardware/software components are a material part of the invention and are not staple articles suitable for substantial non-infringing use (Compl. ¶¶54, 73, 86).
- Willful Infringement: The complaint alleges willful infringement based on Samsung’s purported pre-suit knowledge of the patents-in-suit. It specifies that Samsung was made aware of Tactual's patent portfolio during licensing discussions in March 2017 and alleges that Samsung intentionally copied the technology after gaining a deep understanding of it through joint testing and analysis of a loaned device (Compl. ¶¶21, 50, 69, 82).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: does Samsung’s use of a GPU for ink rendering and an NPU for text recognition functionally map onto the claimed architecture of two distinct, parallel "subsystems," one for low-latency and one for high-latency feedback? The analysis may hinge on whether these units, integrated within a single SoC, operate with the independence and specific roles contemplated by the patents.
- A second core issue will be one of definitional scope: can the term "cross-control behavior," exemplified in the '615 patent through interactions between discrete GUI elements like buttons and windows, be construed to cover the internal data processing function of converting handwritten strokes into digital text?
- A key factual question for willfulness and damages will be the extent of pre-suit knowledge: given the detailed allegations of a multi-year technical and business relationship, the case will likely involve a deep inquiry into what specific knowledge Samsung personnel had of Tactual's patented technology, and when, based on the alleged technology demonstrations, NDAs, and licensing presentations.