Koyo Licensing LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Koyo Licensing LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: DEMATTEO LAW LLC
• Case Identification: 2:25-cv-01212, E.D. Tex., 12/12/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics is a foreign corporation that may be sued in any judicial district, and because Defendant Samsung Electronics America maintains a regular and established place of business within the district. The complaint also asserts that both defendants have committed acts of patent infringement and have sufficient contacts within the district.
• Core Dispute: Plaintiff alleges that Defendant’s S-Pen compatible smartphones and tablets infringe two patents related to user interfaces that respond to a hovering stylus or finger over a sensitive display.
• Technical Context: The patents-in-suit relate to user interface technologies for touch-sensitive and hover-sensitive devices, a critical area of innovation and competition in the global smartphone and tablet markets.
• Key Procedural History: The complaint notes that Samsung has previously filed its own patent infringement lawsuits in the Eastern District of Texas, arguing in those cases that venue was proper for foreign defendants, which Plaintiff cites in support of its own venue contentions in this case.

Case Timeline

Date	Event
2012-01-10	Earliest Priority Date for ’598 and ’930 Patents
2015-08-25	U.S. Patent No. 9,116,598 Issues
2021-04-06	U.S. Patent No. 10,969,930 Issues
2025-12-12	Complaint Filed

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

U.S. Patent No. 9,116,598 - "USER INTERFACE FOR USE IN COMPUTING DEVICE WITH SENSITIVE DISPLAY"

• Patent Identification: U.S. Patent No. 9,116,598, "USER INTERFACE FOR USE IN COMPUTING DEVICE WITH SENSITIVE DISPLAY," issued August 25, 2015 (’598 Patent). (Compl. ¶11).

The Invention Explained

• Problem Addressed: The patent describes the challenge of using a small handheld device, like a smartphone, to interact with content on a much larger, separate display. The user may find it difficult to control a cursor on the large screen while looking at the small screen of the handheld device. (’598 Patent, col. 1:43-56).
• The Patented Solution: The invention proposes a method where the handheld device's sensitive display acts as a remote control. When a user hovers a finger or stylus over the handheld's screen, the device detects the hover position and sends a signal to an external display to show a graphical indicator (like a cursor) at that corresponding location. Crucially, this indicator is shown only on the external display, not on the handheld device's screen, allowing the user to focus their attention on the large screen while controlling the pointer. (’598 Patent, Abstract; col. 2:16-28).
• Technical Importance: This technology sought to improve the usability of smartphones as remote controls for external displays, making activities like presentations, media browsing, or gaming more intuitive. (Compl. ¶15).

Key Claims at a Glance

• The complaint asserts infringement of Claim 1 of the ’598 Patent. (Compl. ¶19).
• The essential elements of independent Claim 1 include:
  • A method for a computing device having a sensitive display and communication circuitry.
  • Detecting a hover of a physical object over the sensitive display and determining the hover position.
  • In response to the hover, displaying a graphical indicator at a location corresponding to the hover position on an external display device via the communication circuitry.
  • Displaying the indicator on the external display while failing to display the graphical indicator on the sensitive display of the computing device.
  • Detecting a subsequent tap of the physical object and determining if its position corresponds to a tappable user interface element on the computer screen.
  • If so, executing a pre-determined action associated with that element.
• The complaint alleges infringement of "one or more claims," suggesting a reservation of the right to assert additional claims. (Compl. ¶19).

U.S. Patent No. 10,969,930 - "USER INTERFACE FOR USE IN COMPUTING DEVICE WITH SENSITIVE DISPLAY"

• Patent Identification: U.S. Patent No. 10,969,930, "USER INTERFACE FOR USE IN COMPUTING DEVICE WITH SENSITIVE DISPLAY," issued April 6, 2021 (’930 Patent). (Compl. ¶12).

The Invention Explained

• Problem Addressed: The patent’s background discusses the general need for improved usability on computing devices and specifically addresses the problem of "erroneous tapping" on a crowded screen, where a user might accidentally select the wrong icon or button. (’930 Patent, col. 1:33-40; col. 10:50-57).
• The Patented Solution: The invention describes a user interface method to confirm user intent before action. When a user hovers a finger or stylus over a graphical user interface (GUI) object for a predetermined period, the system displays a "graphical assistant object" (e.g., a pop-up, a menu, or an enlarged version of the object). The user then interacts with this new assistant object to execute the command, rather than the original object, which may be small or close to other tappable elements. (’930 Patent, Abstract; col. 44:8-45:17).
• Technical Importance: This hover-to-confirm mechanism can reduce input errors on touchscreens, particularly for devices with dense interfaces or for users who require greater accessibility. (Compl. ¶15).

Key Claims at a Glance

• The complaint asserts infringement of Claim 8 of the ’930 Patent. (Compl. ¶29).
• The essential elements of independent Claim 8 include:
  • A handheld computing device with a sensitive display, processor, and memory.
  • The processor is configured to display a GUI with selectable objects linked to specific content.
  • In response to detecting a hover over a first GUI object for more than a predetermined time, the processor initiates a pop-up display of a "graphical assistant object."
  • This graphical assistant object is linked to the same specific content as the first GUI object.
  • While the assistant object is displayed, the processor initiates the display of the content in response to a touch on the graphical assistant object instead of through a touch on the first GUI object.
• The complaint alleges infringement of "one or more claims," suggesting a reservation of the right to assert additional claims. (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

The Accused Products are a broad range of Samsung's "S-Pen compatible" smartphones and tablets. Specific product lines named include the Galaxy S Ultra series (S21-S25), Galaxy Note Series (Note 8-Note 20), Galaxy Z Fold Series (Z Fold 2-Z Fold 6), and various Galaxy Tab series. (Compl. ¶16).

Functionality and Market Context

The complaint alleges that the Accused Products incorporate user interface technologies that respond to a hovering object, such as a stylus. (Compl. ¶15). These features are allegedly used both for interaction on the device's own display and for controlling content on an external display. (Compl. ¶15). The complaint positions Samsung as a "leading manufacturer and seller" of these devices globally. (Compl. ¶2). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations in its body. Instead, it refers to "preliminary chart[s]" attached as Exhibits C and D, which were not provided with the complaint document. (Compl. ¶¶24, 34). The following is a summary of the apparent infringement theories based on the complaint's general allegations.

’598 Patent Infringement Allegations

The complaint's theory appears to be that the Accused Products infringe Claim 1 when used in a mode that connects them to an external display (e.g., a monitor or television). (Compl. ¶15). In this alleged mode of operation, hovering the S-Pen over the device's screen causes a cursor or pointer to appear on the external display, allowing the user to navigate and select items shown on that external screen. The core of this allegation would depend on evidence that the pointer appears on the external display without a corresponding pointer appearing on the device's own sensitive display, thereby satisfying the claim's negative limitation.

’930 Patent Infringement Allegations

The infringement theory for the ’930 Patent appears to target features in the Accused Products where hovering the S-Pen over an on-screen item (like a hyperlink, photo gallery, or calendar event) for a moment causes a preview bubble or pop-up to appear. (Compl. ¶15). The complaint's theory would require this preview to function as the claimed "graphical assistant object," which then becomes the target for user interaction to access the underlying content.

Identified Points of Contention

• Scope Questions (’598 Patent): A central dispute may arise over the negative limitation "failing to display the graphical indicator on the sensitive display." The case may turn on whether Samsung's devices, in their remote display modes, provide any form of on-device visual feedback corresponding to the hover position and whether such feedback would fall within the scope of "the graphical indicator."
• Technical Questions (’930 Patent): The analysis may focus on whether the accused preview functionality operates "instead of" interaction with the original GUI object, as required by Claim 8. A key question could be whether, after the preview pop-up appears, a user can still tap the original object to trigger the action, or if interaction is exclusively transferred to the pop-up.

V. Key Claim Terms for Construction

Term from the ’598 Patent: "failing to display the graphical indicator on the sensitive display"

• Context and Importance: This negative limitation is critical to distinguishing the claimed invention from conventional remote trackpad interfaces that might show cursors on both screens. Infringement requires a demonstrated absence of the indicator on the controlling device's screen.
• Intrinsic Evidence for a Broader Interpretation: A party could argue that this term means the absence of the specific indicator shown on the external screen. The presence of a different form of visual feedback on the sensitive display (e.g., a subtle highlight) would not constitute "the graphical indicator."
• Intrinsic Evidence for a Narrower Interpretation: A party may argue that the term means the absence of any positional indicator. The specification explains that the invention's usability is improved because the user can "recognize where he/she should tap on" while watching the external display, suggesting the intent is to avoid distracting positional cues on the sensitive display. (’598 Patent, col. 26:45-55).

Term from the ’930 Patent: "graphical assistant object"

• Context and Importance: The definition of this term will determine whether a wide range of UI preview or pop-up features are covered by the patent. The infringement analysis hinges on whether the accused feature is merely informational or serves as an interactive proxy as claimed.
• Intrinsic Evidence for a Broader Interpretation: The patent abstract describes the invention as popping up a "dialog," and the specification provides varied examples, including a menu with "save, edit, option" buttons and an enlarged thumbnail of a picture. (’930 Patent, Abstract; FIG. 34; FIG. 41).
• Intrinsic Evidence for a Narrower Interpretation: The claim requires that the user interacts with the assistant object "instead of" the original object. The specification notes that this approach enhances usability "even in case the tappable objects are displayed too small," suggesting the assistant object is intended to be a larger, easier, and replacement target for the user's tap. (’930 Patent, col. 19:15-25). This could support a narrower construction requiring the object to be an interactive substitute, not just a passive preview.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for both patents-in-suit. The inducement allegations are based on Samsung allegedly providing "instructions, documentation... product manuals, advertisements, and online documentation" that encourage end-users to use the accused features in an infringing manner. (Compl. ¶¶22, 32). The contributory infringement allegations assert that the accused components are not staple articles of commerce and have no substantial non-infringing uses. (Compl. ¶¶23, 33).

Willful Infringement

The complaint alleges that Samsung performs the accused acts with knowledge of the patents-in-suit, "at least as of the date of this Complaint." (Compl. ¶¶22, 32). It further alleges intent or "willful blindness" and requests in the prayer for relief a judgment that the infringement is willful. (Compl. p. 10, ¶b).

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

• A core issue will be one of evidentiary proof for a negative limitation: Can Plaintiff demonstrate that Samsung's devices, when operating in a remote display mode, meet the ’598 Patent's requirement of "failing to display" a hover indicator on the device's own screen while simultaneously displaying it on an external screen?
• A key question of claim scope will be the construction of "graphical assistant object" in the ’930 Patent. The case may turn on whether Samsung's "Air View" or similar preview features function as an interactive substitute for the original UI element, as the claim language "instead of" may require, or if they are merely informational pop-ups that do not alter the primary mode of interaction.
• A final question will relate to damages and scope of accused products: Given the large number of accused product families spanning many years, establishing the specific functionality and sales data for each generation will be a central part of discovery and may significantly influence the potential damages calculation.