DCT

2:25-cv-01259

Neolayer 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-01259, E.D. Tex., 12/31/2025
  • Venue Allegations: Plaintiff alleges venue is proper based on Defendant Samsung Electronics America, Inc.'s regular and established place of business in the district, specifically a "flagship campus" in Plano, Texas, and Defendant Samsung Electronics Co., Ltd.'s status as a foreign corporation. The complaint also notes Samsung's history of availing itself of the forum in prior patent litigation.
  • Core Dispute: Plaintiff alleges that Defendant’s display panels and the end-user products incorporating them (e.g., smartphones, TVs, monitors) infringe six patents related to the structure, fabrication methods, and pixel architecture of semiconductor displays.
  • Technical Context: The technology at issue involves the intricate design and manufacturing of thin-film transistors (TFTs) and pixel structures for high-resolution displays, such as Active-Matrix Organic Light Emitting Diode (AMOLED) panels, a cornerstone of the modern consumer electronics market.
  • Key Procedural History: The complaint alleges that Defendant had knowledge of the asserted patents due to a prior business relationship and cross-licensing agreements between Defendant and AUO Corporation, the original assignee of the patents-in-suit. This history forms the basis for Plaintiff's allegations of willful infringement.

Case Timeline

Date Event
2007-03-15 ’583 Patent Priority Date
2008-07-25 ’592 Patent Priority Date
2010-01-19 ’583 Patent Issue Date
2010-10-29 ’358 Patent Priority Date
2010-12-24 ’712 Patent Priority Date
2011-12-22 ’365 Patent Priority Date
2012-01-10 ’592 Patent Issue Date
2012-12-11 ’358 Patent Issue Date
2014-03-18 ’365 Patent Issue Date
2014-04-15 ’712 Patent Issue Date
2019-03-28 ’129 Patent Priority Date
2019-01-01 Alleged Infringement Begins (approx.)
2021-08-10 ’129 Patent Issue Date
2025-07-01 Patents Assigned to NeoLayer LLC
2025-12-31 Complaint Filing Date

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

U.S. Patent No. 7,649,583 - "Semiconductor Structure and Fabricating Method Thereof for Liquid Crystal Display Device," issued January 19, 2010 (’583 Patent)

The Invention Explained

  • Problem Addressed: The patent's background describes conventional methods for fabricating Low-Temperature Poly-Silicon (LTPS) Thin-Film Transistors (TFTs) as requiring a large number of expensive photomasks, increasing manufacturing costs. It also notes that conventional storage capacitor designs provide insufficient capacitance, which can lead to poor display quality (’583 Patent, col. 1:15-2:32).
  • The Patented Solution: The invention proposes a method for fabricating a semiconductor structure that integrates a multi-layer storage capacitor. This is achieved through a specific sequence of forming and patterning a semiconductor layer, multiple inter-layer dielectric layers, and multiple conductive layers to create both the TFT's active elements (gate, source, drain) and a stacked capacitor structure that increases capacitance without requiring additional masks (’583 Patent, Abstract; col. 2:35-47).
  • Technical Importance: The claimed method seeks to simultaneously reduce manufacturing costs by optimizing the fabrication process and improve display performance by increasing pixel storage capacitance.

Key Claims at a Glance

  • The complaint asserts independent method claim 1 (Compl. ¶37).
  • Essential elements of Claim 1 include a sequence of steps:
    • forming a semiconductor layer on a substrate.
    • forming a first inter-layer dielectric layer.
    • forming a gate and a first electrode.
    • performing a doping process to form a source and drain.
    • forming a second inter-layer dielectric layer.
    • forming a patterned conductive layer (pixel electrode).
    • forming a third inter-layer dielectric layer.
    • patterning the dielectric layers to form contact windows.
    • forming a second electrode and a source/drain conductive line.
  • The complaint reserves the right to assert additional claims (Compl. ¶34).

U.S. Patent No. 8,093,592 - "Thin Film Transistor Substrate, Electronic Apparatus, and Methods For Fabricating The Same," issued January 10, 2012 (’592 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the issue of non-uniform electrical characteristics in polysilicon TFTs. Carrier mobility is highly dependent on the orientation of crystalline grain boundaries. In conventional rectangular TFT layouts, this "anisotropic" property can cause performance to vary depending on the TFT's orientation on the display, leading to visual defects known as "mura" (’592 Patent, col. 1:44-2:43).
  • The Patented Solution: The invention discloses a TFT design where the channel region, the path between the source and drain, is "extended along a curve." By forcing carriers to travel along a curved path of substantially constant width, the design ensures that they cross a multitude of sub-grain boundaries at various angles. This has an averaging effect that makes the transistor's performance less dependent on its orientation, thereby improving uniformity across the display panel (’592 Patent, Abstract; col. 3:10-18; Fig. 7A).
  • Technical Importance: The design aims to mitigate a fundamental source of non-uniformity in LTPS displays, enabling higher quality and potentially higher manufacturing yields.

Key Claims at a Glance

  • The complaint asserts independent apparatus claim 1 (Compl. ¶58).
  • Essential elements of Claim 1 include:
    • a substrate.
    • at least a thin film transistor, comprising:
      • a semiconductor island with sub-grain boundaries, a source, a drain, and a channel region.
      • wherein the length of the channel region is extended along a curve, and its width remains substantially the same.
    • a gate corresponding to the channel region.
  • The complaint reserves the right to assert additional claims (Compl. ¶34).

U.S. Patent No. 8,698,712 - "Pixel Structure of Active Matrix Organic Electroluminescent Display Panel and Method of Making the Same," issued April 15, 2014 (’712 Patent)

  • Technology Synopsis: The ’712 Patent describes a pixel structure for an AMOLED display that includes at least two separate light-emitting devices and their associated driving and addressing switching devices. The architecture allows for switching between different display modes, such as a single-sided or double-sided display, by controlling the different light-emitting devices within the same pixel structure (’712 Patent, Abstract; col. 1:10-17).
  • Asserted Claims: Independent claim 10 is asserted (Compl. ¶70).
  • Accused Features: The complaint alleges the pixel structure of the Samsung Galaxy S24 infringes by incorporating a first and second light-emitting device, each with its own driving switching device, and at least one addressing switching device connected to them (Compl. ¶¶71-76).

U.S. Patent No. 8,330,358 - "OLED Illumination Device with Improved Aperture Ratio," issued December 11, 2012 (’358 Patent)

  • Technology Synopsis: The ’358 Patent addresses the problem of opaque metal signal lines reducing the light-emitting area ("aperture ratio") in OLED devices. The proposed solution is a specific layout where a "first metal line" is designed to overlap with a "second metal line" in vertical projection, and one first metal line passes through a sub-emitting area connected to a different first metal line. This overlapping and routing scheme aims to minimize the non-emissive area on the substrate (’358 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶81).
  • Accused Features: The accused functionality in the Samsung Galaxy S24 is the device's layout of "first metal lines" and "second metal lines" within its sub-emitting areas, including the alleged vertical overlap and the routing of one line through an adjacent area (Compl. ¶¶82-90).

U.S. Patent No. 8,674,365 - "Array Substrate and Manufacturing Method Thereof," issued March 18, 2014 (’365 Patent)

  • Technology Synopsis: The ’365 Patent describes a specific layered structure for a thin-film transistor and a simplified manufacturing method. The claimed structure involves a precise stack-up, including a gate electrode on the substrate, followed by a patterned gate insulating layer, a patterned semiconductor layer, a patterned etching stop layer, and a protective layer with contact openings for the source and drain electrodes (’365 Patent, Abstract). The simplified process is a key aspect of the invention.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶95).
  • Accused Features: The complaint alleges the array substrate in the Samsung Galaxy S24 embodies the claimed TFT structure, identifying each of the specific layers in the prescribed order, from the gate electrode on the substrate to the source/drain electrodes connected via contact openings (Compl. ¶¶96-105).

U.S. Patent No. 11,088,129 - "Display Apparatus," issued August 10, 2021 (’129 Patent)

  • Technology Synopsis: The ’129 Patent discloses a display apparatus with a stacked structure comprising multiple circuit and adhesive layers. A key feature is the electrical connection between different layers, where a "first conductive element" on a "second circuit layer" connects down to a "first circuit layer" through a "first via" in an intervening "first adhesive layer." This architecture facilitates complex, multi-layered circuit designs, which can be relevant for flexible or advanced display structures (’129 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶110).
  • Accused Features: The complaint accuses the multi-layered construction of the Samsung Galaxy S24 display, alleging it contains the claimed substrate, first and second circuit layers, first adhesive layer, and a first conductive element that connects through a via in the adhesive layer (Compl. ¶¶111-119).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as a broad range of Samsung devices incorporating OLED displays, including TVs, smartphones, laptops, tablets, monitors, smart watches, and VR headsets (Compl. ¶¶30-31). The Samsung Galaxy S24 smartphone is used as a representative example for detailed infringement allegations (e.g., Compl. ¶37).

Functionality and Market Context

The Accused Products are alleged to utilize various advanced display technologies, including traditional AMOLED, Super AMOLED, Dynamic AMOLED, and quantum dot OLED (QD-OLED) panels (Compl. ¶29). These displays function by using a backplane of thin-film transistors to control the light emission from millions of individual OLED pixels (Compl. ¶¶24-25). The complaint supports its technical allegations with numerous visual exhibits, including scanning electron microscope (SEM) cross-section images and top-down microscope views of the accused phone's internal display structure (Compl. ¶¶39-50). A top-down view of the semiconductor structure alleges to show the source, drain, and channel of a transistor (Compl. ¶42; p. 13). The complaint asserts that Samsung is a dominant force in the display panel market, holding a leading share in the global OLED monitor and TV markets (Compl. ¶28).

IV. Analysis of Infringement Allegations

’583 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for fabricating a semiconductor structure, comprising: forming a semiconductor layer on a substrate... Samsung's process of manufacturing the Accused Phone includes forming a semiconductor layer on a substrate in active element and storage capacitor areas. ¶39 col. 6:49-53
forming a first inter-layer dielectric layer to cover the semiconductor layer; The manufacturing process includes forming a first inter-layer dielectric that covers the semiconductor layer. ¶40 col. 6:54-55
forming a gate on the first inter-layer dielectric layer in the active element area and a first electrode on the first inter-layer dielectric layer in a storage capacitor area; The process includes forming a gate and a first electrode on the first inter-layer dielectric layer. ¶41 col. 6:56-59
performing a doping process to form a source and a drain in the semiconductor layer in the active element area...; A doping process is used to form the source, drain, and channel in the semiconductor layer. ¶42 col. 7:1-6
forming a second inter-layer dielectric layer to cover the gate and the first electrode; A second inter-layer dielectric layer is formed to cover the gate and first electrode. ¶43 col. 7:7-9
forming a patterned conductive layer on the second inter-layer dielectric layer as a pixel electrode; A patterned conductive layer, serving as a pixel electrode, is formed on the second inter-layer dielectric layer. ¶44 col. 7:10-12
forming a third inter-layer dielectric layer to cover the patterned conductive layer; A third inter-layer dielectric layer is formed, covering the patterned conductive layer. ¶45 col. 7:13-15
patterning the third inter-layer dielectric layer to expose the patterned conductive layer and forming a plurality of contact windows in the first, second and third inter-layer dielectric layers to expose the source, the drain, a portion of the patterned conductive layer and the first electrode; The dielectric layers are patterned to form contact windows that expose the underlying source, drain, patterned conductive layer, and first electrode. The complaint provides a top-down view purporting to show these exposed elements through the windows (Compl. ¶48; p. 16). ¶¶46-48 col. 7:16-24
forming a second electrode on the third inter-layer dielectric layer...and electrically connected to the first electrode, and a source/drain conductive line electrically connecting the semiconductor layer with the patterned conductive layer. A second electrode is formed over and connected to the first electrode, and a source/drain conductive line is formed to connect the semiconductor layer to the patterned conductive layer. ¶¶49-50 col. 7:25-31

Identified Points of Contention (’583 Patent)

  • Evidentiary Questions: The asserted claim is for a method of fabrication, but the complaint's evidence consists of images of the final product's structure. A central question for the court will be whether this structural evidence is sufficient to infer that Samsung necessarily uses the claimed sequence of manufacturing steps, or if an alternative process could yield a similar final structure.

’592 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A thin film transistor substrate, comprising: a substrate; The Accused Phone includes a substrate as part of its thin-film transistor substrate. ¶60 col. 3:51-52
at least a thin film transistor, disposed on the substrate and comprising: a semiconductor island, comprising a plurality of sub-grain boundaries... The Accused Phone contains a thin film transistor on the substrate, which includes a semiconductor island with sub-grain boundaries. ¶¶61-62 col. 3:9-10; col. 5:10-12
a source region, a drain region, and a channel region disposed between the source region and the drain region... The transistor's semiconductor island comprises a source, drain, and channel region. ¶63 col. 5:9-10
wherein a length of the channel region projected in the substrate is extended along a curve, and the width of the channel region projected in the substrate remains substantially the same in an extending direction of the curve; The complaint alleges that the channel region's length extends along a curve while maintaining a substantially constant width, illustrated with a top-down microscope image with annotations (Compl. ¶64; p. 22). ¶64 col. 3:13-18
and a gate, corresponding to the channel region. The transistor includes a gate that corresponds to the channel region. ¶65 col. 3:18-19

Identified Points of Contention (’592 Patent)

  • Scope Questions: The infringement analysis will likely focus on the claim term "extended along a curve." The key question will be whether the shape of the channel region in the accused device—depicted in the complaint as bent or angled (Compl. ¶64)—falls within the scope of "curve" as defined by the patent.
  • Technical Questions: A related factual question is whether the width of this channel "remains substantially the same" along its path. The parties may present conflicting measurements and expert testimony on the geometry of the accused transistors.

V. Key Claim Terms for Construction

For the ’592 Patent

  • The Term: "extended along a curve"
  • Context and Importance: This term is the central inventive concept of the ’592 Patent, intended to distinguish the claimed transistor from prior art devices with linear channels. The entire infringement case for this patent may hinge on whether the accused channel geometry meets this definition. Practitioners may focus on this term because the visual evidence provided (Compl. ¶64) shows a path with distinct bends rather than a smooth arc, raising an immediate question of definitional scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary and background state the goal is to have the carrier migration path cross "a plurality of SGBs" to solve the problem of anisotropic electrical properties (e.g., ’592 Patent, col. 3:41-49). This purpose may support an argument that "curve" should be construed broadly to include any non-linear path that achieves this functional goal, including bent or segmented paths.
    • Evidence for a Narrower Interpretation: The patent's figures, such as the exemplary curve "C2" in Figure 7A, depict a smooth, continuous arc. A defendant could argue that the term "curve" should be limited to such smooth geometries and does not read on paths with sharp angles, which may be argued to be structurally and functionally different.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement for each asserted patent, stating that Samsung intentionally encouraged third parties like vendors and customers to use and sell the Accused Products, knowing they would infringe (e.g., Compl. ¶¶52, 66, 77, 91, 106, 120).

Willful Infringement

The complaint alleges willful infringement for all asserted patents. The basis for this allegation is Defendant's purported knowledge of the patent portfolio through prior business dealings with the original patent owner, AUO Corporation. These dealings allegedly included patent cross-license agreements covering TFT-LCD and OLED technologies and related litigation, which Plaintiff claims put Samsung on notice of the patents or led to willful blindness (e.g., Compl. ¶¶54, 68, 79, 93, 108, 122).

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

  • A core issue will be one of definitional scope: can the term "extended along a curve" in the ’592 Patent, which is rooted in the context of creating a non-linear path to average grain boundary effects, be construed to cover the bent or angled channel geometry allegedly found in Samsung's transistors?
  • A key evidentiary question will be one of process-from-product inference: for the ’583 method patent, can the Plaintiff prove, based solely on structural analysis of the finished Accused Products, that Samsung's manufacturing process necessarily includes the specific sequence of layering, patterning, and etching steps required by the claims?
  • A central factual question will concern scienter and willfulness: will the alleged history of cross-licensing and litigation between Samsung and the original patent assignee, AUO, be sufficient to establish that Samsung had pre-suit knowledge of the patents and acted with deliberate or reckless disregard of NeoLayer's patent rights?