DCT
2:25-cv-01088
Fec IP LLC v. Samsung Electronics Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fec IP LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 2:25-cv-01088, E.D. Tex., 10/30/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants conduct substantial business and have committed acts of infringement in the district. It is further alleged that as a foreign corporation, Samsung Electronics Co., Ltd. may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s mobile phones, tablets, smart watches, and smart televisions, which incorporate functionalities such as SmartThings, screen mirroring, Quick Share, and Samsung TV Plus, infringe four patents related to secure content sharing, remote device control, and video streaming.
- Technical Context: The patents relate to inter-device communication and content management, a technology area central to the functionality of modern, integrated consumer electronics ecosystems.
- Key Procedural History: The complaint does not allege any pre-suit notification, prior litigation involving the patents-in-suit, or any proceedings before the U.S. Patent and Trademark Office.
Case Timeline
| Date | Event |
|---|---|
| 1999-11-02 | Earliest Priority Date for ’192 Patent |
| 2007-06-19 | Earliest Priority Date for ’187 Patent |
| 2009-12-08 | ’192 Patent Issued |
| 2011-05-02 | Earliest Priority Date for ’106 Patent |
| 2011-11-08 | ’187 Patent Issued |
| 2014-12-09 | ’106 Patent Issued |
| 2015-09-08 | Earliest Priority Date for ’847 Patent |
| 2019-01-01 | ’847 Patent Issued |
| 2025-10-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,631,192 - "Network Apparatus for Accessing Services Over a Network"
The Invention Explained
- Problem Addressed: The patent’s background describes the security risk that arises when private information obtained from a network, such as the content of an electronic mail, is displayed on a large, shared screen (e.g., a television), potentially exposing it to unintended viewers (Compl. ¶14; ’192 Patent, col. 1:10-31).
- The Patented Solution: The invention proposes a system where a portable remote controller sends its unique ID code to a main device when requesting information. The main device retrieves the information, appends the remote controller's ID code to it, and sends the combined data back. The remote controller is configured to display the information only if it recognizes its own ID code, thereby preventing the information from being displayed on an unauthorized device and reducing the risk of unintended disclosure (Compl. ¶14; ’192 Patent, Abstract).
- Technical Importance: This approach provided a method for enhancing user privacy in an environment where network-connected devices were beginning to be controlled by portable terminals in shared spaces.
Key Claims at a Glance
- The complaint asserts independent method claim 17 (Compl. ¶24).
- Essential elements of claim 17 include:
- sending a request for information from a portable remote controller device having a first display to a main device configured to be connected to a second display;
- obtaining the requested information from the network;
- providing the obtained information from the main device to the remote controller device;
- displaying the sent information on the first display of the remote controller device;
- sending a display switching signal from the remote controller device to the main device; and
- determining whether the second display of the main device displays the obtained information based on the display switching signal.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,908,106 - "Mobile Terminal"
The Invention Explained
- Problem Addressed: The patent addresses the delay a user experiences between initiating a control application on a mobile device and the external device (e.g., a TV receiver) being ready for control. This waiting time is the sum of the application start-up time and the external device's power-on time (’106 Patent, col. 1:26-34).
- The Patented Solution: The invention is a mobile terminal that transmits a "turning-on control signal" to the external device before the process of starting the control application is completed. By initiating the power-on sequence of the external device concurrently with the application's launch process on the mobile terminal, the overall waiting time for the user is reduced (Compl. ¶15; ’106 Patent, Abstract).
- Technical Importance: This method aimed to improve the user experience of integrated device ecosystems by reducing latency and making the transition between controlling devices feel more seamless.
Key Claims at a Glance
- The complaint asserts independent apparatus claim 1 (Compl. ¶37).
- Essential elements of claim 1 include:
- a mobile terminal comprising: a signal transmission unit which transmits control signals to an external device;
- an operation unit for a user to perform various actions; and
- a microprocessor that starts a control application for control of the external device, and transmits, to the external device, an operation control signal... in response to a user action;
- wherein when starting the control application, the microprocessor transmits, to the external device, a turning-on control signal to turn on the external device... before the process of starting the control application is completed.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,055,187 - "Communication Terminal and Communication Method for Exchanging Contents"
- Technology Synopsis: The patent describes a method for exchanging digital content between communication terminals. The process involves a handshake protocol where devices exchange request and response information, followed by "determination information" to confirm whether content should be transmitted before the actual content data is sent, stored on the receiving device, and made available for output (Compl. ¶16; '187 Patent, col. 2:37-67). The complaint provides a screenshot from a Samsung website illustrating the user interface for initiating a file transfer with "Quick Share" (Compl. p. 28).
- Asserted Claims: The complaint asserts independent method claim 15 (Compl. ¶49).
- Accused Features: The "Quick Share" functionality on Samsung devices, which allows for peer-to-peer file sharing (Compl. ¶50).
U.S. Patent No. 10,171,847 - "Information Device and Distribution Device"
- Technology Synopsis: The patent discloses an information device and system for downloading video data. The core concept involves a controller that requests video data from an external device in segments ("divided video data"), converts the format, and produces a "playlist file" for playback instruction each time a segment is downloaded (Compl. ¶17; ’847 Patent, Abstract). The complaint includes a technical table detailing Samsung's specifications for adaptive streaming, which recommends video segment durations of 2-6 seconds (Compl. p. 45).
- Asserted Claims: The complaint asserts independent apparatus claim 1 (Compl. ¶65).
- Accused Features: The "Samsung TV Plus" application and the underlying Samsung Global Content Delivery Network ("CDN") infrastructure that delivers streaming video (Compl. ¶¶18, 66).
III. The Accused Instrumentality
Product Identification
The complaint accuses Samsung's mobile phones (e.g., Galaxy S25 Ultra), tablets, smart watches, and smart televisions of infringement (Compl. ¶¶18, 25).
Functionality and Market Context
- The accused functionalities are software features that enable communication and content sharing across Samsung's product ecosystem (Compl. ¶18). These include Samsung SmartThings for device control, screen mirroring for displaying content across devices, Quick Share for file transfer, and Samsung TV Plus for video streaming (Compl. ¶18). The complaint depicts the SmartThings user interface, which allows a user to select "View TV on phone" to stream content from a television to a smartphone (Compl. p. 9).
- The complaint alleges Samsung is a "leading manufacturer and seller" of these products globally and in the United States (Compl. ¶2).
IV. Analysis of Infringement Allegations
’192 Patent Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| sending a request for information from a portable remote controller device having a first display to a main device configured to be connected to a second display | A Samsung Galaxy S25 Ultra (portable remote controller) sends a request (e.g., for streaming data) to a Samsung smart television (main device) connected to a television screen (second display). | ¶25 | col. 2:2-4 |
| obtaining the requested information from the network | The smart television obtains the requested information, such as online content, from the network (e.g., Wi-Fi, internet). | ¶26 | col. 2:5-7 |
| providing the obtained information from the main device to the remote controller device | The smart television provides the information to the Galaxy S25 Ultra via switching stream or screen mirroring. | ¶27 | col. 2:7-8 |
| displaying the sent information on the first display of the remote controller device | The Galaxy S25 Ultra displays the received information on its touch display screen. A visual in the complaint shows a football game being displayed on a phone screen (Compl. p. 11). | ¶27 | col. 2:8-10 |
| sending a display switching signal from the remote controller device to the main device | The Galaxy S25 Ultra sends a signal to the smart television to stream content to the main device or mirror a display on it. | ¶28 | col. 2:10-11 |
| determining whether the second display of the main device displays the obtained information based on the display switching signal sent from the remote controller device | The system determines whether the television screen displays the obtained information (e.g., online content) based on the display switching signal sent from the phone. | ¶29 | col. 2:11-13 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis may focus on whether the general-purpose commands for screen mirroring or streaming in the accused SmartThings feature constitute the "display switching signal" contemplated by the patent. The patent's abstract and summary describe a system for enhancing security, which may suggest the "display switching signal" is part of a specific, secure protocol rather than a generic content sharing command.
- Technical Questions: A factual question may arise regarding the final "determining" step. What evidence does the complaint provide that the system makes a "determination" based on the signal, as opposed to simply executing a command to display content?
’106 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile terminal comprising: a signal transmission unit which transmits control signals to an external device | The Samsung Galaxy S25 Ultra is a mobile terminal with a Wi-Fi/Bluetooth transceiver (signal transmission unit) that sends signals to a smart television (external device). | ¶38 | col. 1:49-51 |
| an operation unit for a user to perform various actions | The Galaxy S25 Ultra has a touch screen and volume buttons (operation unit) allowing user actions like swiping or tapping. A visual in the complaint shows a user tapping a power button icon in the SmartThings app (Compl. p. 21). | ¶39 | col. 1:51-52 |
| a microprocessor that starts a control application... and transmits... an operation control signal... in response to a user action | The Snapdragon 8 Elite chip (microprocessor) starts the SmartThings app and transmits signals (e.g., to change channel) in response to user input on the touch screen. | ¶40 | col. 1:52-58 |
| wherein when starting the control application, the microprocessor transmits... a turning-on control signal to turn on the external device... before the process of starting the control application is completed | When a user enables the "Power On with Mobile" option, the Galaxy S25 Ultra allegedly transmits a wake signal to the smart TV before the SmartThings application start-up process is complete. The complaint cites Samsung developer documentation describing this "Wake on WirelessLAN" (WoW) functionality (Compl. p. 22). | ¶41 | col. 1:58-62 |
- Identified Points of Contention:
- Scope Questions: The central dispute will likely involve the temporal limitation "before the process of starting the control application is completed." The parties may dispute the precise technical event that constitutes the "completion" of the application-starting process (e.g., instantiation of the application object vs. full rendering of the user interface).
- Technical Questions: A key evidentiary question will be whether the accused products, as they actually operate, transmit the "turning-on control signal" at the specific time required by the claim. The complaint's reliance on developer documentation suggests this will be a highly technical, fact-intensive inquiry into the software's execution sequence.
V. Key Claim Terms for Construction
For the ’192 Patent:
- The Term: "display switching signal" (from claim 17)
- Context and Importance: This term is critical because the infringement theory hinges on equating Samsung's general screen mirroring/streaming commands with this claimed signal. Practitioners may focus on whether the term requires a specific security function, given the patent's overall focus on privacy, or if it broadly covers any signal that causes a display to change.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the signal to a security purpose, referring only to its function of causing the main device to determine whether to display information.
- Evidence for a Narrower Interpretation: The patent's Abstract and Summary of the Invention frame the invention as a solution to prevent unauthorized viewing of private information by using an ID code system. A party could argue that this context limits the scope of "display switching signal" to signals that are part of such a secure switching protocol (’192 Patent, col. 1:50-55, Abstract).
For the ’106 Patent:
- The Term: "before the process of starting the control application is completed" (from claim 1)
- Context and Importance: This temporal limitation defines the novel aspect of the invention. The infringement case rests on demonstrating that the accused "Power On with Mobile" feature operates within this specific timing window.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Abstract states the mobile device "transmits the control signals to turn on the TV receiver while performing the process of starting the TV application," which supports the idea that the signal is sent during, and therefore before completion of, the start-up process (’106 Patent, Abstract).
- Evidence for a Narrower Interpretation: A defendant could argue for a very early and technical definition of "completed," such as the moment the application process is created by the operating system, potentially before the signal is sent. The patent specification does not appear to provide a specific technical definition for when the starting process is "completed."
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The allegations are based on Samsung providing the Accused Products along with "instructions, documentation, ... product manuals, advertisements, and online documentation" that allegedly encourage and instruct customers on how to use the products in an infringing manner (Compl. ¶¶30, 42, 58, 71).
- Willful Infringement: The complaint alleges that Samsung has had "actual notice of the Asserted Patents, at least as of the filing date of this Complaint" (Compl. ¶19). It further alleges that Samsung acted with "knowledge of the... Patent and with the intent, or willful blindness, that the induced acts directly infringe," which supports a claim for post-suit willful infringement (Compl. ¶¶31, 43, 59, 72).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of temporal precision: Will factual evidence of the Samsung SmartThings application's boot sequence demonstrate that the "Wake on WirelessLAN" signal is transmitted before the start-up process is technically "completed," as required by the ’106 Patent, or does it occur after a critical technical milestone that could be defined as completion?
- Another core issue will be one of functional scope: Can the term "display switching signal" from the ’192 Patent, which is described in the context of a secure, ID-based protocol for protecting private information, be construed to read on the general-purpose "screen mirroring" and content streaming commands in Samsung's products, or is there a fundamental mismatch in the signal's intended function and operation?
- A key evidentiary question for the ’187 and ’847 patents will be one of architectural mapping: How precisely do the complex, multi-protocol communication methods of modern software like "Quick Share" and the "Samsung TV Plus" CDN map onto the specific, sequential steps recited in the asserted method and apparatus claims, which were drafted based on earlier technological paradigms?