DCT

2:25-cv-01101

Fingon LLC v. Samsung Electronics Co Ltd

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-1101, E.D. Tex., 11/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Samsung Electronics America, Inc. maintains a regular and established place of business in Plano, Texas, within the district, and has committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and other electronic devices utilizing secure processing environments infringe five patents related to the use of an isolated "secure zone" for executing sensitive tasks.
  • Technical Context: The technology concerns hardware-based security in microprocessors, often called a Trusted Execution Environment (TEE), which creates a secure, isolated area to protect sensitive operations like mobile payments and digital rights management from a potentially compromised main operating system.
  • Key Procedural History: For each asserted patent family, the complaint alleges that Defendant had pre-suit knowledge of the patent based on prior "interactions between the parties concerning a foreign patent arising from the same application(s)," which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2012-04-13 Earliest Priority Date for ’735 and ’338 Patents
2012-04-20 Earliest Priority Date for ’348, ’776, and ’869 Patents
2016-08-30 U.S. Patent No. 9,432,348 Issues
2017-08-22 U.S. Patent No. 9,742,735 Issues
2019-04-23 U.S. Patent No. 10,270,776 Issues
2019-11-19 U.S. Patent No. 10,484,338 Issues
2021-12-14 U.S. Patent No. 11,201,869 Issues
2025-11-05 Complaint Filed

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

U.S. Patent No. 9,432,348 - “Secure Zone for Secure Purchases”

The Invention Explained

  • Problem Addressed: The patent background describes that network-based activities like internet shopping and online banking are susceptible to security breaches from malware such as viruses, keyloggers, and Trojan horses that exploit vulnerabilities in a device's main operating system (’348 Patent, col. 1:21-31).
  • The Patented Solution: The invention proposes an apparatus with a hardware-based "secure zone" that is isolated from the potentially insecure main operating system. This secure zone is configured to execute a primary "task" (e.g., a merchant's checkout code) which can then call a "subtask" (e.g., a bank's payment verification code). Both the task and subtask are digitally signed, and the secure zone applies distinct sets of permissions to each, based on information in their respective digital certificates, to ensure secure execution and controlled interaction (’348 Patent, Abstract; col. 9:1-12).
  • Technical Importance: This architecture provides a method for executing multi-party secure transactions on a single device by isolating them from the main OS and enforcing different, cryptographically verified permissions for each party's code.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶48).
  • Claim 1 requires an apparatus with:
    • A secure zone comprising an interface to a non-secure zone.
    • The secure zone is configured to execute a task having one or more subtasks, where the task and subtasks have executable code for secure transactions, are digitally signed by respective code providers, and execution is switched between them.
    • The secure zone is further configured to apply respective sets of permissions for the task and subtasks during their execution, with permissions for each being based on information associated with the signed code and information in the digital certificate of its provider.

U.S. Patent No. 9,742,735 - “Secure Zone for Digital Communication”

The Invention Explained

  • Problem Addressed: Similar to the ’348 Patent, this patent addresses security vulnerabilities in a device's primary operating system that can compromise sensitive data transactions (’735 Patent, col. 1:20-30).
  • The Patented Solution: The invention describes an apparatus with a secure zone that can assume control over the device's screen to create a trusted user interface. It defines distinct operational modes, including a "partial screen secure mode" where a portion of the screen is controlled by the secure task while another portion displays trusted information (e.g., the task's identity), and a "full screen secure mode." A supervisor controls an "indicator" to inform the user when the device is operating in a secure mode, thereby preventing spoofing attacks (’735 Patent, Abstract; Fig. 1). The complaint includes a reproduction of the patent's Figure 1, a block diagram showing the relationship between a non-secure zone (152) and a secure zone (150) that includes a supervisor (160) and can control a screen (123) (Compl. p. 9).
  • Technical Importance: This technology provides a verifiable trusted path for user interaction, allowing a user to confirm they are interacting with a legitimate secure application and not a malicious program mimicking its interface.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶72).
  • Claim 1 requires an apparatus with a screen, a non-secure zone, and a secure zone, where the secure zone comprises:
    • Memory inaccessible to the non-secure zone.
    • Non-volatile storage for at least one digital certificate (representing a task signer) and an encryption key.
    • A secure processor to execute a task associated with the certificate.
    • A supervisor and an indicator controlled by the supervisor.
    • The supervisor is configured to operate in different modes: a partial screen mode (delegating a first portion of the screen to the task, displaying the task signer information in a second portion, and activating the indicator), a full screen mode (delegating the entire screen to the task and deactivating the indicator), and a non-secure mode (transferring screen control to the non-secure zone).

Multi-Patent Capsule: U.S. Patent No. 10,270,776

  • Patent Identification: U.S. Patent No. 10,270,776, “Secure Zone for Secure Transactions,” issued April 23, 2019 (’776 Patent).
  • Technology Synopsis: This patent describes an apparatus where a secure zone executes a task that involves a network-communicating subtask. The secure zone leverages the network capabilities of the non-secure zone to transmit data packets for the subtask and is configured to clear memory related to the subtask after its execution to prevent data leakage (’776 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶118).
  • Accused Features: The complaint alleges that Samsung's Key Provisioning Module (SKPM) Trusted Application, which communicates over the internet using the non-secure zone's network capabilities and clears memory after execution, infringes the ’776 Patent (Compl. ¶129, ¶131, ¶135).

Multi-Patent Capsule: U.S. Patent No. 10,484,338

  • Patent Identification: U.S. Patent No. 10,484,338, “Secure Zone for Digital Communications,” issued November 19, 2019 (’338 Patent).
  • Technology Synopsis: This patent describes an apparatus with a secure zone, a screen, and an indicator. A supervisor in the secure zone assumes control of the screen output when operating in a secure mode and controls the indicator, activating it in secure mode and deactivating it in non-secure mode, to provide a trusted user interface (’338 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶152).
  • Accused Features: The complaint alleges that Samsung's Trusted User Interface (TUI) components, which take control of the screen and display a "Secured by Knox" message and "Secure mode" shield icon (the "indicator"), infringe the ’338 Patent (Compl. ¶173, ¶175).

Multi-Patent Capsule: U.S. Patent No. 11,201,869

  • Patent Identification: U.S. Patent No. 11,201,869, “Secure Zone for Secure Purchases,” issued December 14, 2021 (’869 Patent).
  • Technology Synopsis: This patent describes a secure zone with a processor configured to execute a task and a subtask. The invention focuses on state management, where the processor stores the state of the task, switches to the subtask, and after executing the subtask, clears memory related to it and switches back to the task based on its stored state (’869 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶190).
  • Accused Features: The complaint alleges that Samsung's secure processor executes tasks like the SKPM Trusted Application, which stores state data related to subtasks it calls, clears memory after subtask execution, and switches execution back to the main task, infringing the ’869 Patent (Compl. ¶205, ¶207).

III. The Accused Instrumentality

Product Identification

  • The accused products are Samsung electronic devices, such as the Samsung Galaxy S25 smartphone, that contain Systems-on-Chip (SoCs) or microprocessors utilizing security architectures like Qualcomm's TrustZone Trusted Execution Environment (TEE) and hypervisor, or functionally similar technologies (Compl. ¶45, ¶48).

Functionality and Market Context

  • The complaint alleges that the accused products implement a dual-world architecture: a "Normal World" running a standard operating system like Android in a virtual machine (VM), and an isolated "Secure World" (TEE World) that can run its own "Trusted VM" (Compl. ¶53, ¶81). This secure world is used to execute vetted "Trusted Applications" (TAs) for sensitive operations, such as the Visa Pay TA for payments or the Widevine TA for protected video playback (Compl. ¶55, ¶93). Communication between the worlds is allegedly managed via a Secure Monitor Call (SMC) interface (Compl. ¶53). The complaint presents a "Qualcomm Type-1 Hypervisor" diagram illustrating this separation between the "Normal World" and the "TEE World" (Compl. p. 15).

IV. Analysis of Infringement Allegations

’348 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus, comprising: a secure zone comprising an interface to a non-secure zone... The Samsung Galaxy S25 contains a secure zone (TEE World and Trusted VM) isolated from the non-secure zone (Android VM in the Normal World), with communication occurring through an SMC interface. ¶51, ¶53 col. 2:41-44
execute a task having one or more subtasks, wherein the task and the subtasks have respective executable code for one more secure transactions, the task and the subtasks are digitally signed by respective code providers, and execution is switched between the task and the subtasks The Visa Pay Trusted Application (TA), the "task," calls other TAs like the Keymaster TA and ICCC TA, the "subtasks." Each TA has executable code, includes signed metadata containing identity information, and execution is switched between the calling TA and the called TAs. ¶55 col. 9:1-12
apply respective sets of permissions describing access to certain portions of the secure zone while the respective executable code of the task and subtasks are executed, wherein the respective set of permissions for the task are based on at least one of information associated with the signed task and information in a digital certificate of the respective code provider for the task, and wherein the respective set of permissions for the subtasks are based on at least one of information associated with the signed subtasks and information in a digital certificate of the respective code provider for the subtasks. The device's Secure OS enforces permissions for each TA derived from its signed metadata and certificate information. The permissions for the "subtask" TAs (e.g., ICCC TA, Keymaster TA) are set forth in their own separate executable files and metadata, distinct from the calling "task" TA. ¶57 col. 9:36-50
  • Identified Points of Contention:
    • Scope Questions: A potential issue is whether the architecture of peer Trusted Applications (TAs) calling each other fits the patent's hierarchical model of a "task" having "subtasks." The court may need to determine if a called TA functions as a "subtask" in the manner contemplated by the patent. A further question is whether the "signed metadata" alleged to be part of each TA's executable file constitutes "information in a digital certificate" as required by the claim.

’735 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus, comprising: a screen; a non-secure zone; a secure zone comprising: a memory inaccessible to the non-secure zone; a non-volatile storage configured to store at least one digital certificate and at least one encryption key...; a secure processor...; a supervisor...; an indicator... The Galaxy S25 includes a display screen; a non-secure Android VM; a secure TEE World/Trusted VM with inaccessible memory; non-volatile storage (SFS, FTS, Knox Vault) for certificates and keys; a secure processor; a supervisor (Secure OS, TUI components); and an indicator ("Secure mode" shield icon/message). Screenshots of documentation for SFS and Knox Vault are provided as evidence of non-volatile storage (Compl. p. 23). ¶77, ¶79, ¶81, ¶83, ¶85, ¶87, ¶89, ¶97 col. 2:41-44
wherein the supervisor is configured when the apparatus operates in the partial screen secure mode to: delegate control of a first portion of the screen to the task...; display in a second portion of the screen the information representing the task signer...; and activate the indicator The Trusted User Interface (TUI) for secure PIN input operates in a first portion of the display, while a "Secure mode" shield icon and "Secured by Knox" message (the indicator and task signer information) are displayed in a second portion. The complaint provides a screenshot of the Samsung Wallet PIN entry screen showing this split-screen functionality (Compl. p. 26). ¶99 col. 7:11-24
wherein the supervisor is configured when the apparatus operates in a full screen secure mode to: delegate control of the entire screen to the task...; deactivate the indicator... During playback of DRM-protected video via the Widevine Trusted Application, control of the entire screen is delegated to the task, and no security indicator is displayed. ¶101 col. 7:5-10
wherein the supervisor is configured when the apparatus operates in a non-secure mode to transfer control over the output of the screen to the non-secure zone. When the TUI or Widevine secure sessions end, control of the display output returns to the non-secure Android VM. ¶103 col. 8:27-32
  • Identified Points of Contention:
    • Scope Questions: A key question will be whether a software-rendered icon and message (the "Secure mode" shield and "Secured by Knox" text) meet the claim limitation of an "indicator," which the patent specification also contemplates could be a physical hardware element like an LED (’735 Patent, col. 5:1-4).
    • Technical Questions: The infringement theory for "full screen secure mode" relies on the absence of an indicator during DRM video playback to meet the "deactivate the indicator" limitation. It may be disputed whether simply not displaying an icon is equivalent to the affirmative step of "deactivating" it as required by the claim.

V. Key Claim Terms for Construction

  • The Term: "task" and "subtask" (’348 Patent, Claim 1)

  • Context and Importance: The plaintiff's infringement theory maps the accused device's architecture of Trusted Applications (TAs) to the patent's "task/subtask" structure. The construction of these terms is therefore foundational to the infringement analysis.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes tasks in general terms as "executable code" received by the supervisor, suggesting any executable unit could be a task (’348 Patent, col. 3:1-13).
    • Evidence for a Narrower Interpretation: The patent provides a specific embodiment of a secure purchase where "code1" belongs to a merchant ("task") and "code2" belongs to the merchant's bank ("subtask"), suggesting a specific, hierarchical, multi-party relationship that may be narrower than any two communicating software modules (’348 Patent, col. 11:49-67).

  • The Term: "supervisor" (’735 Patent, Claim 1)

  • Context and Importance: The complaint identifies the "supervisor" as a collection of software components, including the Secure OS and TUI components (Compl. ¶89). The defendant may argue for a narrower construction, potentially requiring a single, discrete component.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the supervisor functionally, as a component that enforces operational rules, receives code, and controls peripherals, which could support a distributed or multi-component implementation (’735 Patent, col. 2:60-64).
    • Evidence for a Narrower Interpretation: Figure 1 of the patent depicts the "Supervisor 160" as a single, discrete block within the secure zone architecture, which may support an argument that it must be a monolithic entity rather than a collection of disparate software modules (’735 Patent, Fig. 1).

  • The Term: "indicator" (’735 Patent, Claim 1)

  • Context and Importance: Practitioners may focus on this term because the infringement allegation relies on a software icon displayed on the screen meeting this limitation (Compl. ¶97). Its construction will determine whether a non-hardware element falls within the claim's scope.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent describes the indicator's function as "indicating when the device...is operating in a secure mode," without strictly limiting its form (’735 Patent, col. 4:65-67).
    • Evidence for a Narrower Interpretation: An exemplary embodiment in the specification explicitly describes the indicator as "a green LED which is placed on an outside case of the device," which could be used to argue that the term requires a physical component separate from the main display screen (’735 Patent, col. 5:1-4).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement on the basis that Samsung supplies the accused products to consumers in the United States and instructs and encourages them to use the devices in their ordinary and intended manner, which allegedly constitutes direct infringement (Compl. ¶60, ¶106).
  • Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint claims Samsung had pre-suit knowledge of the patents due to "interactions between the parties concerning a foreign patent arising from the same application(s)" and, at a minimum, has knowledge as of the filing of the complaint (Compl. ¶58, ¶104).

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

  • A core issue will be one of architectural mapping: does the accused architecture of a secure operating system running multiple, distinct "Trusted Applications" that can call one another correspond to the patents' more hierarchical model of a "task" that executes "subtasks"?
  • A central question of claim scope will be whether software-based user interface elements, such as the "Secure mode" shield icon displayed on a screen, can satisfy the term "indicator," which the patent specifications also describe as a physical hardware component like an LED.
  • The infringement analysis may turn on an evidentiary question of functional operation: does the accused system's alleged "deactivation" of the indicator during full-screen DRM playback—by simply not displaying it—perform the same function as the affirmative "deactivate" step recited in Claim 1 of the ’735 patent?