DCT

2:25-cv-01074

Biosonics Technology LLC v. Samsung Electronics Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01074, E.D. Tex., 10/28/2025
  • Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics America, Inc. (SEA) because it maintains a regular and established place of business in the district (Plano, TX) where business operations related to the accused mobile devices occur. Venue for the foreign parent, Samsung Electronics Co., Ltd. (SEC), is alleged to be proper in any U.S. judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile phones and tablets equipped with in-display fingerprint sensors infringe four patents related to integrated biometric sensing technology.
  • Technical Context: The technology involves embedding optical or ultrasonic fingerprint sensors underneath a device's display, enabling secure biometric authentication while maximizing screen-to-body ratio, a key feature in modern consumer electronics.
  • Key Procedural History: The complaint alleges that Samsung had knowledge of patent family members related to the Asserted Patents no later than 2015–2018 due to disclosures during the prosecution of Samsung’s own patent applications and that Plaintiff engaged in licensing outreach in 2024. No prior litigation or post-grant proceedings involving the Asserted Patents are mentioned in the complaint.

Case Timeline

Date Event
2012-09-07 Earliest Priority Date for all Asserted Patents ('776, '915, '893, '966)
2013-01-01 Application leading to the '893 Patent was filed
2014-01-01 First Samsung phone with a fingerprint sensor (Galaxy S5) launched
2015-06-23 '893 Patent Issued
2015-09-01 '966 Patent Issued
2017-01-01 Samsung launched Galaxy S8 with rear-mounted fingerprint sensor
2019-01-01 Samsung launched Galaxy S10 with under-display ultrasonic sensor
2023-02-28 '776 Patent Issued
2025-05-27 '915 Patent Issued
2025-10-28 Complaint Filed

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

U.S. Patent No. 11,593,776 - "Communication Device to Sense One or More Biometric Characteristics of a User," issued February 28, 2023

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of integrating biometric authentication into portable electronic devices without consuming valuable surface area with physical buttons or sensors, which constrains display size (Compl. ¶45). At the time of the invention, users carried multiple physical cards for transactions, and emerging tap-to-pay technology relied on insecure PINs, creating a need for a more secure and consolidated on-device solution (Compl. ¶46; ’776 Patent, col. 1:45-53).
  • The Patented Solution: The invention proposes a communication device, such as a smartphone, with biometric sensors integrated directly into the display stack (Compl. ¶51). The solution comprises a layered structure with a display layer positioned below an exterior surface, and pluralities of "biometric output pixel elements" (e.g., piezoelectric transmitters) and "biometric input pixel elements" (e.g., piezoelectric receivers) that are also positioned below the exterior surface and overlap with the display pixels to send and receive signals (like ultrasonic waves) through the screen to read a user's fingerprint ('776 Patent, Abstract; Compl. ¶49). Figure 7B of the patent illustrates an exemplary stacked arrangement of these different pixel layers ('776 Patent, Fig. 7B).
  • Technical Importance: This integrated approach allows for the creation of devices with nearly bezel-free, "all-screen" fronts while retaining the convenience of front-facing fingerprint authentication (Compl. ¶30, ¶52).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '776 Patent (Compl. ¶63).
  • Independent Claim 1 requires:
    • A communication device configured to sense biometric characteristics.
    • A cover structure with an exterior surface.
    • A layer of display light emitting output pixel elements below the exterior surface.
    • A plurality of biometric output pixel elements (e.g., light emitting or piezoelectric-out) positioned below the exterior surface and overlapping with the display pixels.
    • A plurality of biometric input pixel elements (e.g., light detecting or piezoelectric-in) positioned below the exterior surface, overlapping with the other layers, and configured to receive a reflected biometric input from the user.
    • A processor connected to the input pixel elements to process the reflected input.

U.S. Patent No. 12,314,915 - "Communication Device To Sense One or More Biometric Characteristics of a User," issued May 27, 2025

The Invention Explained

  • Problem Addressed: As a continuation of the same patent family, the '915 Patent addresses the same problems of limited screen real estate due to physical sensors and the need for a secure, integrated authentication method on mobile devices ('915 Patent, col. 1:21-46; Compl. ¶45-46).
  • The Patented Solution: The solution is materially similar to that of the '776 Patent, describing a layered device structure where biometric input and output elements are integrated with display elements under a cover structure ('915 Patent, Abstract). The complaint asserts that the Asserted Patents all include similar features (Compl. ¶49). The key distinction in the asserted claim appears to be the path of the reflected input signal.
  • Technical Importance: The technology enables the consolidation of authentication and display functions, supporting the market trend toward larger, bezel-less screens (Compl. ¶30, ¶52).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '915 Patent (Compl. ¶75).
  • Independent Claim 1 requires:
    • A communication device configured to sense biometric characteristics.
    • A cover structure with an exterior surface.
    • A layer of display light emitting output pixel elements below the exterior surface.
    • A plurality of output pixel elements (e.g., light emitting or piezoelectric-out) configured to provide an output through the display layer and exterior surface to be reflected from the user.
    • A plurality of biometric input pixel elements configured to receive the reflected output, which is transmitted back through the exterior surface and the display layer.

Multi-Patent Capsule: U.S. Patent No. 9,065,893 - "Credit Card Form Factor Secure Mobile Computer and Method," issued June 23, 2015

  • Technology Synopsis: The '893 Patent, an earlier patent in the same family, discloses a communication device with a "multilayer stack" of pixel elements on a substrate (Compl. ¶88). The stack includes pixel elements configured to provide an output away from the substrate and pixel elements configured to receive an input that passes through at least one layer of the stack, establishing the foundational concept of integrated, multi-function pixel layers ('893 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶87).
  • Accused Features: The complaint alleges that the ultrasonic and optical in-display fingerprint sensors in the Accused Products infringe by virtue of their multilayer sensor and display stack architecture (Compl. ¶89).

Multi-Patent Capsule: U.S. Patent No. 9,122,966 - "Communication Device," issued September 1, 2015

  • Technology Synopsis: The '966 Patent builds on the multilayer stack concept of the '893 patent. It claims a communication device with a plurality of stacked pixel elements, each stack including output and input elements, and adds the requirement of "a near field communication device positioned on the communication device" (Compl. ¶100). This suggests an invention that combines the integrated display/sensor technology with other standard mobile device communication hardware like NFC.
  • Asserted Claims: At least Claim 1 (Compl. ¶99).
  • Accused Features: The complaint accuses Samsung's devices, which contain both in-display fingerprint sensors and NFC technology, of infringing the '966 patent (Compl. ¶101).

III. The Accused Instrumentality

Product Identification

The Accused Products are various Samsung mobile devices, including flagship S-series and Note-series smartphones (e.g., Galaxy S10, S20-S25, Note 10, Note 20), "Fan Edition" phones, A-series phones, and Galaxy Tab S-series tablets (Compl. ¶34, ¶53).

Functionality and Market Context

The Accused Products incorporate either ultrasonic or optical in-display fingerprint sensors for biometric authentication (Compl. ¶53). This technology allows a user to unlock the device by placing their finger on a designated area of the screen (Compl. ¶29). The complaint alleges that Samsung adopted this feature, starting with the 2019 Galaxy S10, to meet consumer demand for larger displays with minimal bezels, which was a feature its competitors had already begun to introduce (Compl. ¶33, ¶34, ¶41). An image in the complaint from a Samsung publication shows an exploded view of a smartphone, highlighting the placement of the ultrasonic sensor module beneath the display panel (Compl. ¶31). The complaint also contrasts this with prior Samsung models, like the Galaxy S8, that used a rear-mounted sensor which received widespread criticism for its awkward placement (Compl. ¶39-40).

IV. Analysis of Infringement Allegations

The complaint references infringement claim charts in exhibits that were not provided with the filing; therefore, the narrative infringement theory is summarized below in prose.

U.S. Patent No. 11,593,776 Infringement Allegations

  • The complaint alleges that the Accused Products, which include both ultrasonic and optical sensors, meet all limitations of at least Claim 1 (Compl. ¶63, ¶65, ¶69). The narrative theory is that the devices' glass screen is the "cover structure," the OLED panel is the "layer of display light emitting output pixel elements," and the under-display sensor module provides the "biometric output pixel elements" and "biometric input pixel elements." The complaint further alleges these elements are positioned and overlap as required by the claim, and that the device's processor processes the reflected biometric input to authenticate the user (Compl. ¶49, ¶64). The use of "at least one of" language in the claim (e.g., "piezoelectric" or "light emitting" elements) suggests the claim was drafted to cover both ultrasonic and optical technologies, which the complaint accuses (Compl. ¶34, ¶53).
  • Identified Points of Contention: A central question may be whether the structure of Samsung's discrete sensor module, which is placed under a specific area of the display, satisfies the claim limitation requiring a "plurality of biometric... pixel elements positioned below the exterior surface and overlapping with the display light emitting output pixel elements in a direction perpendicular to the exterior surface." The complaint includes an image of a Samsung device with an awkwardly placed rear fingerprint sensor, illustrating the problem the patent claims to solve (Compl. p. 14, ¶39). The litigation may focus on whether Samsung's move to an under-display module, while solving the ergonomic problem, adopts the specific layered and overlapping architecture required by the claims.

U.S. Patent No. 12,314,915 Infringement Allegations

  • The infringement theory for the ’915 Patent is substantially similar to that for the '776 Patent, focusing on the stacked architecture of the display and sensor components (Compl. ¶75, ¶77, ¶81). Claim 1 of the '915 Patent requires that the reflected biometric input be "transmitted through the exterior surface and through the layer of display light emitting output pixel elements" to reach the input sensor (Compl. ¶76).
  • Identified Points of Contention: The dispute may turn on the technical path of the reflected signal. A question for the court will be whether evidence shows that in Samsung's devices, the reflected ultrasonic pulse or light wave travels back through the OLED display pixel layer itself to reach the sensor, as specified in the claim. The complaint provides a schematic from the asserted patents showing the device's main components, including a processor, memory, and communication unit, which will be mapped to the accused device's hardware (Compl. p. 18, ¶47).

V. Key Claim Terms for Construction

The Term: "overlapping with the display light emitting output pixel elements in a direction perpendicular to the exterior surface" (from '776 Patent, Claim 1)

  • Context and Importance: This term defines the required physical and geometric relationship between the biometric sensor elements and the display pixels. Its construction will be critical because the Accused Products use a discrete sensor module placed under the display, and not a fully integrated sensor array coextensive with the entire display. Practitioners may focus on whether "overlapping" requires pixel-for-pixel alignment across the entire display layer or if placing a smaller module underneath a portion of the display layer is sufficient.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the invention in general terms of layers, stating the biometric input pixel elements are "positioned below the exterior surface and overlapping with the display light emitting input pixel elements" ('776 Patent, col. 2:7-10). This could support a reading that does not require perfect alignment or co-extensiveness.
    • Evidence for a Narrower Interpretation: Figure 7B, referenced in the complaint (Compl. ¶51), depicts a highly integrated "multilayer stack" where different functional pixel layers (light-emitting, piezoelectric, light-detecting) are vertically stacked on top of one another ('776 Patent, Fig. 7B). This figure could support a narrower construction requiring a more integrated, pixel-level interleaving of display and sensor functions rather than simply placing a separate module underneath.

The Term: "biometric... pixel elements" (from '776 Patent, Claim 1)

  • Context and Importance: This term defines the nature of the sensor components themselves. The dispute may involve whether the individual transducers in an ultrasonic sensor or photosites in an optical sensor qualify as "pixel elements." Practitioners may focus on this term because if "pixel elements" is construed to require features of display pixels (e.g., being arranged in a similar grid, integration with display drivers), it could create a mismatch with the architecture of a dedicated sensor module.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes "light detecting pixel elements" as potentially being a "CCD or another technology, such as CMOS" ('776 Patent, Abstract), which are standard image sensor technologies. This suggests the term is meant to encompass conventional sensor components.
    • Evidence for a Narrower Interpretation: The repeated use of "pixel elements" for both the display and the biometric components, combined with figures like 7B showing intermixed pixel layers, may suggest that the claimed "biometric pixel elements" are not just any sensor components, but components that are structured and integrated in a pixel-like manner with the display itself ('776 Patent, Fig. 7B).

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Samsung provides instructions, documentation, online technical support, and product manuals that instruct and encourage customers to use the in-display fingerprint sensors in an infringing manner (Compl. ¶66-67, ¶78). The complaint cites a Samsung support webpage with instructions on using the feature (Compl. ¶67).

Willful Infringement

Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges pre-suit knowledge based on Samsung's purported monitoring of the asserted patent family during its own patent prosecution activities between 2015-2018 (Compl. ¶54), as well as through licensing outreach in 2024 (Compl. ¶55). The complaint also pleads willful blindness, alleging Samsung deliberately avoided learning of infringement despite a high probability that its products infringed (Compl. ¶57).

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

  • A core issue will be one of structural scope: Does the architecture of Samsung’s discrete under-display sensor modules satisfy claim limitations requiring a "plurality" of "biometric pixel elements" that are "overlapping with the display light emitting output pixel elements"? The case may turn on whether the patent claims cover a device where a smaller, separate sensor is placed under a portion of a display, or if they require a more deeply integrated, co-extensive structure.
  • A key evidentiary question will be one of technical operation: For claims like Claim 1 of the '915 Patent, what is the actual path of the reflected biometric signal (light or ultrasound) inside the accused Samsung devices? A central factual dispute may be whether that signal travels back through the light-emitting display layer itself to reach the sensor, as the claim language appears to require.
  • A final question will be one of timing and knowledge: If infringement is found, the willfulness inquiry will focus on what Samsung knew about the patent portfolio and when. The allegation that Samsung was aware of the patent family as early as 2015-2018 through its own R&D and patenting activities, years before it launched the first accused product in 2019, will be a central point of contention in determining the extent of damages.