DCT

2:25-cv-01093

Light Guide Innovations 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-01093, E.D. Tex., 10/31/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants are foreign companies subject to suit in any U.S. judicial district, and because they maintain a regular and established place of business in the district and have committed acts of infringement there. The complaint also notes that Samsung has not contested venue in the Eastern District of Texas in prior patent litigation.
  • Core Dispute: Plaintiff alleges that Defendant’s televisions and displays, including its LED, Crystal UHD, QLED, and neo QLED product lines, infringe a large portfolio of nineteen U.S. patents related to LED backlight assemblies, lenses, and display components.
  • Technical Context: The technology concerns the design and construction of LED backlight units used to illuminate liquid crystal displays (LCDs) in modern televisions, focusing on electrical connectivity, thermal management, and optical performance.
  • Key Procedural History: The complaint alleges that Defendants have known of the asserted patents at least since they were widely publicized following the sale of a patent portfolio from LG Innotek to Suzhou Lekin Semiconductor, forming the basis for a willfulness allegation.

Case Timeline

Date Event
2006-03-15 Earliest Priority Date for ’411 and ’352 Patents
2006-08-24 Earliest Priority Date for ’415 Patent
2006-12-29 Earliest Priority Date for ’200 and ’537 Patents
2007-11-06 Earliest Priority Date for ’380 Patent
2009-11-19 Earliest Priority Date for ’122, ’307, ’729, ’093, ’744, ’048, ’183, and ’378 Patents
2009-11-20 Earliest Priority Date for ’823 Patent
2010-08-17 Earliest Priority Date for ’447 Patent
2011-04-12 U.S. Patent No. 7,922,380 Issues
2011-05-03 U.S. Patent No. 7,936,415 Issues
2011-11-08 U.S. Patent No. 8,052,307 Issues
2012-07-03 U.S. Patent No. 8,213,093 Issues
2012-08-07 U.S. Patent No. 8,237,352 Issues
2012-09-18 U.S. Patent No. 8,267,537 Issues
2012-10-23 U.S. Patent No. 8,292,447 Issues
2013-03-12 U.S. Patent No. 8,395,183 Issues
2013-08-13 U.S. Patent No. 8,506,122 Issues
2013-10-22 U.S. Patent No. 8,562,200 Issues
2013-12-31 U.S. Patent No. 8,616,729 Issues
2014-05-13 U.S. Patent No. 8,723,411 Issues
2014-09-02 U.S. Patent No. 8,823,048 Issues
2017-01-03 U.S. Patent No. 9,534,744 Issues
2017-05-02 U.S. Patent No. 9,638,378 Issues
2018-07-24 U.S. Patent No. 10,030,823 Issues
2025-10-31 Complaint Filed

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

U.S. Patent No. 7,936,415 - “Light Source Apparatus And Liquid Crystal Display Having The Same”

The Invention Explained

  • Problem Addressed: The patent seeks to improve the mechanical and electrical connection structure for LED modules used in backlight units for displays (’415 Patent, col. 1:26-30).
  • The Patented Solution: The invention describes a modular system for connecting multiple LED circuit boards ("module substrates") in series to form a larger light source (’415 Patent, col. 3:20-25). It uses dedicated "connecting substrates" to link the main module substrates and employs a special "termination connecting substrate" at the end of a chain of modules to create a "closed loop circuit," completing the electrical path (’415 Patent, Abstract; Fig. 2).
  • Technical Importance: This modular approach using distinct connecting substrates is intended to enhance electrical reliability and mechanical strength between the LED modules in a large-scale backlight assembly (’415 Patent, col. 2:1-5).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶44).
  • Essential elements of Claim 1:
    • At least one module substrate with connecting terminals at both side ends.
    • A light emitting diode (LED) on the module substrate.
    • A plurality of connecting substrates connected to the module substrate's terminals.
    • The plurality of connecting substrates includes a "termination connecting substrate" that prepares a connecting terminal on the final module substrate as a "closed loop circuit."
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’415 Patent.

U.S. Patent No. 7,922,380 - “Light Unit And Display Device Having The Same”

The Invention Explained

  • Problem Addressed: The patent aims to provide a light-emitting module with improved heat conduction properties, which is critical for the performance and longevity of LEDs (’380 Patent, col. 1:32-34).
  • The Patented Solution: The invention uses a flexible printed circuit board (PCB) bent into a specific configuration. One part of the board, holding the LEDs, is positioned next to the light guide, while another part is routed elsewhere (’380 Patent, col. 2:60-63). A metal plate is attached to the rear of the board and makes contact with the main housing, allowing the housing to act as a heat sink to dissipate heat generated by the LEDs (’380 Patent, Abstract; Fig. 1).
  • Technical Importance: This design provides a method for thermal management in edge-lit displays by creating a dedicated thermal path from the LEDs to the display's housing via a metal plate integrated with a flexible PCB.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶57).

  • Essential elements of Claim 1:

    • A light unit with a light guide member, a board with LEDs, a reflection sheet, and a housing.
    • A metal plate is attached to the second (rear) side of the board and a first side of the housing.
    • A lower side of the metal plate is contacted with a bottom surface of the housing.
    • The board is a flexible PCB with two distinct portions: a first portion between the metal plate and the light guide member, and a second portion between the reflection sheet and the housing.
    • The second portion includes line patterns connected to the LEDs.

  • The complaint does not explicitly reserve the right to assert dependent claims for the ’380 Patent.
    The complaint asserts seventeen additional patents. These are summarized below.

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8,562,200, "Lighting Module, Backlight Unit, And Display Device Including The Same," issued October 22, 2013.
    • Technology Synopsis: The patent describes a lighting module that includes a "guide protrusion" on the surface of the substrate. This protrusion comprises a pin and a cap, with the pin's height being less than the height of the light emitting diodes, suggesting a feature for aligning or spacing other optical components relative to the LEDs (’200 Patent, Abstract). The complaint alleges this patent relates to providing reliable lighting for LCDs (Compl. ¶30).
    • Asserted Claims: At least Claim 1 (Compl. ¶77).
    • Accused Features: The complaint alleges that lenses on the LED strips in the Samsung UA55KU television series function as the claimed "guide protrusion," comprising a support (pin) and a base portion of the optic (cap) (Compl. ¶¶78, 80-81).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8,506,122, "Lens And Light Emitting Apparatus Having The Same," issued August 13, 2013.
    • Technology Synopsis: The patent describes a specific lens geometry for an LED apparatus, where the lens body has a first recess on its top surface and a second recess on its bottom surface. The lens is held off the substrate by a lens support, spacing the bottom of the lens body from the substrate (’122 Patent, Abstract). The complaint notes this technology provides "superior light emitting characteristics in a lateral direction" (Compl. ¶34).
    • Asserted Claims: At least Claim 1 (Compl. ¶91).
    • Accused Features: Optics disposed over the LED packages in the Samsung UA55KU television are accused of having the claimed lens body structure with top and bottom recesses and a lens support (Compl. ¶¶94-95).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8,052,307, "Lens And Light Emitting Apparatus Having The Same," issued November 8, 2011.
    • Technology Synopsis: The patent relates to a light emitting apparatus that includes a packaged LED (with a package body, phosphor layer, and sealing resin) and a lens supported by the substrate. The lens itself has a specific geometry with a first recess on top, a second recess on the bottom, and a lens support to space it from the substrate (’307 Patent, Abstract).
    • Asserted Claims: At least Claim 1 (Compl. ¶105).
    • Accused Features: The LED packages and associated optics in the Samsung UA55KU series are alleged to embody the claimed structure, including the package components and the lens with dual recesses (Compl. ¶¶107-109).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8,616,729, "Lens And Light Emitting Apparatus Having The Same," issued December 31, 2013.
    • Technology Synopsis: This patent describes a lens with a convex top surface that includes a recessed part at its center and a flat surface at its circumference. The lens has specific dimensional ratios relating the depth of the recess to the thickness of the lens body (’729 Patent, Abstract).
    • Asserted Claims: At least Claim 1 (Compl. ¶119).
    • Accused Features: The lenses on the LED strips of the Samsung UA55KU series are accused of having the claimed convex shape, recessed top part, flat circumference, and specified dimensional ratios (Compl. ¶¶120-122).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8,213,093, "Lens And Light Emitting Apparatus Having The Same," issued July 3, 2012.
    • Technology Synopsis: This patent details a lens with a complex geometry defined by multiple specific ratios, including ratios of the depths of top and bottom recesses to the lens thickness, and ratios of the widths of these recesses to the overall lens width (’093 Patent, Abstract).
    • Asserted Claims: At least Claim 1 (Compl. ¶132).
    • Accused Features: The lenses in the Samsung UA55KU series are accused of meeting the claimed geometric structure and the extensive set of dimensional ratios (Compl. ¶¶133-136).

  • Multi-Patent Capsule: The complaint asserts twelve additional patents: ’744, ’048, ’183, ’378, ’823, ’537, ’411, ’352, and ’447, along with others not assigned a count number. The complaint does not provide sufficient detail for individual analysis of the remaining patents.

III. The Accused Instrumentality

Product Identification

  • The accused products are "all versions and variants of Samsung LED, Crystal UHD, QLED, and neo QLED displays, including commercial displays" (Compl. ¶36). Specific exemplary models identified for certain infringement counts include the UA55KU, Samsung Frame, UE40, and Q65L televisions (Compl. ¶¶43, 56, 228, 272).

Functionality and Market Context

  • The accused products are televisions that utilize LED backlights to illuminate their display screens. The complaint targets the internal construction of these backlight units, including the LED strips (PCBs), the LEDs themselves, the lenses (optics) placed over the LEDs, the electrical connection schemes for the LED strips, the thermal management structures, and photoluminescent films (quantum dot films) used for color enhancement (Compl. ¶¶35-36, 45-47, 58-67, 244-245). The complaint alleges these products are sold through major online and physical retailers in the United States, including within the Eastern District of Texas (Compl. ¶¶37-38). An image from a teardown of a Samsung television shows the internal layout of multiple horizontal LED strips that form the backlight unit (Compl. p. 11).

IV. Analysis of Infringement Allegations

’415 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one module substrate comprising connecting terminals at both side ends thereof; The accused UA55KU model includes multiple LED strips, which are identified as module substrates that comprise connecting terminals at both ends. ¶45 col. 7:2-4
a light emitting diode on the module substrate; Each LED strip includes multiple LED lights, which are identified as the light emitting diodes. ¶46 col. 7:5-6
a plurality of connecting substrates connected to the connecting terminals of the module substrate, The accused televisions allegedly include connecting substrates used to connect one LED strip to another in series. ¶47 col. 7:7-9
wherein the connecting substrate comprises a termination connecting substrate, by which the connecting terminal provided at one end of a final module substrate of the module substrates is prepared as a closed loop circuit. The rows of LED strips are alleged to be connected in series and comprise a closed loop circuit, implicitly containing the termination connecting substrate. ¶47 col. 7:10-14
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the accused product's structure of connecting entire LED strips to each other in series maps onto the patent's language of connecting "module substrates" with separate "connecting substrates." The complaint appears to use the terms "connecting substrates" and "LED strips" interchangeably, which may create a mismatch with the patent's disclosure, where they are depicted as distinct components (Compl. ¶47; ’415 Patent, Fig. 2).
    • Technical Questions: The complaint alleges that "Each row of LED strips comprises a closed loop circuit" but does not specify what component in the accused product functions as the claimed "termination connecting substrate" that creates this loop at the end of the final module (Compl. ¶47). The analysis may turn on whether the product's standard series circuit termination performs the specific function taught by the patent.

’380 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a light guide member outputting surface light upward; A transparent plate is positioned over the LEDs to guide light upward. An image shows this transparent plate next to an LED strip. ¶58 col. 6:49
a board disposed to a first side of the light guide member; An LED strip (identified as the board) is located on one side of (under) the transparent light guide member. ¶59 col. 6:50-51
a plurality of light-emitting devices mounted on a first side of the board; The LED strip includes multiple light-emitting devices mounted on its front side. ¶60 col. 6:52-53
a reflection sheet under the light guide member; A white reflection sheet is included under the light guide plate. ¶61 col. 6:54
a housing receiving the light guide member, the light-emitting devices, the board, and the reflection sheet; The television includes a housing that holds the aforementioned backlight components. An image shows the back of the television housing. ¶62 col. 6:55-57
and a metal plate attached to a second side of the board and a first side of the housing, A metal plate is attached to the rear side of the LED strip and to the plastic housing. An image depicts the television's internal chassis with the metal plate and wiring. ¶63 col. 6:58-59
wherein a lower side of the metal plate is contacted with a bottom surface of the housing, The metal plate is in direct contact with the bottom surface of the housing. ¶65 col. 6:62-63
wherein the board is a flexible PCB that includes a first portion disposed between the metal plate and the first side of the light guide member, and a second portion disposed between the reflection sheet and the housing, The Samsung Frame series is alleged to include an LED strip board that comprises a flexible PCB, which is alleged to have the claimed two-portion structure. ¶66 col. 6:64-67
and wherein the second portion of the board includes line patterns connected to the light-emitting devices. The LED strip includes line patterns that supply power to the LEDs. ¶67 col. 3:1-4
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis may focus on the claim clause requiring the "board is a flexible PCB that includes a first portion... and a second portion..." in specific locations. The complaint makes a conclusory allegation for this element without providing visual or descriptive evidence showing this specific two-part physical arrangement (Compl. ¶66). The patent specification and figures describe a distinct bent structure for the flexible PCB, and it raises the question of whether a simple flat flexible strip meets this limitation ('380 Patent, col. 2:60-63; Fig. 1).
    • Technical Questions: Does the "metal plate" in the accused product that "wraps around and contacts the plastic housing" meet the limitation of being "attached to a second side of the board"? (Compl. ¶63). Evidence may be required to show the nature and purpose of this attachment, particularly as it relates to the patent's goal of thermal conduction.

V. Key Claim Terms for Construction

  • For the ’415 Patent:

    • The Term: "termination connecting substrate"
    • Context and Importance: This term is critical because it defines how the series of LED modules is completed to form the claimed "closed loop circuit." The infringement analysis depends on whether the accused product's wiring scheme includes a component that can be defined as such a substrate, or if a standard wire or trace is sufficient.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may suggest the term should be given its plain and ordinary meaning to one of skill in the art, potentially covering any component that terminates a circuit.
      • Evidence for a Narrower Interpretation: The specification describes it as a physical "substrate" that is "mounted on the end portion of a third module substrate" and has a "closed loop pattern" on it to connect terminals ('415 Patent, col. 4:36-42; Fig. 8). This suggests it is a specific, separate component, not just a wire or a trace on the final module board itself.

  • For the ’380 Patent:

    • The Term: "flexible PCB that includes a first portion... and a second portion..."
    • Context and Importance: This structural limitation is the core of claim 1, describing the unique physical arrangement of the flexible board to achieve thermal transfer. Practitioners may focus on this term because the complaint's allegation is conclusory, and the patent's embodiment shows a specific bent shape that may not be present in a standard flat LED strip.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not explicitly require the board to be "bent." An argument could be made that any flexible PCB can be conceptually divided into portions that fall within the recited locations relative to other components.
      • Evidence for a Narrower Interpretation: The specification explicitly states that the board "may be divided into an upper portion 154A and a lower portion 154B which are bent at a predetermined angle" ('380 Patent, col. 2:60-63). Figure 1 clearly depicts this bent structure, which may be argued as essential to the invention's function of routing part of the board under the reflection sheet.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement based on Defendants' affirmative acts of providing "instructions, documentation, ... technical support, marketing, product manuals, advertisements, and online documentation" that allegedly instruct customers on infringing uses (Compl. ¶¶48, 68). Contributory infringement is alleged on the basis that accused components are material to the inventions, not staple articles of commerce, and are known by Defendants to be especially adapted for infringement (Compl. ¶¶49, 69).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The basis is the allegation that Defendants have known of the patents "at least since they were widely publicized during and after LG Innotek's sale to Suzhou Lekin Semiconductor" (Compl. ¶¶50, 70). This allegation of pre-suit knowledge is supported by a citation to an online news article.

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

  • A core issue will be one of definitional scope: can the term "connecting substrate" from the ’415 Patent, which the patent depicts as a discrete flexible connector, be construed to read on the serial connection of entire LED strips as alleged in the complaint? A similar question arises for whether the accused product contains a "termination connecting substrate" or merely a standard circuit termination.
  • A key evidentiary question will be one of structural correspondence: does the accused flexible PCB in Samsung’s Frame TV embody the specific two-portion, bent physical arrangement required by claim 1 of the ’380 Patent, or is there a fundamental mismatch between the accused product’s flat LED strip design and the patent’s disclosed structure for heat dissipation?
  • A central procedural question will be the viability of asserting nineteen patents in a single complaint. The breadth of the assertion, combined with infringement allegations that rely heavily on third-party teardown photos and conclusory statements, suggests the case may face early challenges regarding the sufficiency of pre-suit investigation and the specificity of the pleadings under federal rules.