DCT

2:26-cv-00037

Connectquest LLC v. Samsung Electronics Co Ltd

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Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00037, E.D. Tex., 01/16/2026
  • Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. because it has allegedly committed acts of infringement and maintains a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy smartphones, equipped with features such as SmartThings Find, Quick Share, and Smart Switch, infringe eight U.S. patents related to close proximity notification systems and methods.
  • Technical Context: The technology at issue involves using short-range wireless signals from transmitters to trigger notifications and actions on mobile devices when they enter a specific geographic vicinity, a cornerstone of modern location-based services and advertising.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2010-10-06 Earliest Priority Date (’229 Patent)
2011-08-15 Priority Date (’642, ’979, ’981, ’949, ’688, ’190, ’906 Patents)
2014-09-09 U.S. Patent No. 8,831,642 Issued
2015-12-22 U.S. Patent No. 9,219,979 Issued
2015-12-22 U.S. Patent No. 9,219,981 Issued
2017-04-18 U.S. Patent No. 9,628,949 Issued
2017-06-06 U.S. Patent No. 9,674,688 Issued
2017-06-27 U.S. Patent No. 9,693,190 Issued
2017-08-22 U.S. Patent No. 9,743,229 Issued
2018-06-12 U.S. Patent No. 9,998,906 Issued
2026-01-16 Complaint Filed

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

U.S. Patent No. 8,831,642 - *“Close Proximity Notification System,”* issued September 9, 2014

The Invention Explained

  • Problem Addressed: The patent background describes prior Internet-based marketing services as being "somewhat disconnected from the actual shopping experience" and asynchronous, requiring a consumer to act online before traveling to a physical location. (’642 Patent, col. 2:37-54).
  • The Patented Solution: The invention provides a system where a short-range wireless transmitter at a location, such as a retail store, broadcasts a signal containing a unique identifier. A user's mobile device receives this signal when in "close proximity," uses the identifier to retrieve relevant information (e.g., a coupon) from a server, and displays it to the user, thereby bridging the gap between digital promotion and physical presence. (’642 Patent, Abstract; col. 2:17-27; FIG. 1).
  • Technical Importance: This method aims to increase the efficacy of local advertising by delivering marketing materials at the precise moment a consumer is physically present and able to act, potentially spurring impulse purchases. (’642 Patent, col. 2:12-16).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 5 and 13. (Compl. ¶25).
  • Independent Claim 1 recites a method performed by a mobile device with the essential elements:
    • Receiving a signal from a short-range wireless transmitter at a geographic location, the signal including an identification code.
    • Processing the signal on the mobile device, where the processing is performed "exclusively by a software application located on the mobile device and independently of any networks."
    • The processing includes determining if associated information is already stored on the device and identifying a "retrieval location" for the information.
    • Based on the processing, retrieving the information from the retrieval location.
    • Displaying the information on the mobile device.

U.S. Patent No. 9,219,979 - *“Beacon for Close Proximity Notification System,”* issued December 22, 2015

The Invention Explained

  • Problem Addressed: This patent, related to the ’642 patent, also addresses the "asynchronous nature of many Internet-based marketing schemes" by seeking to deliver information that coincides with a consumer’s physical presence near an establishment. (’979 Patent, col. 2:9-10).
  • The Patented Solution: The invention details a transceiver or "beacon" that discovers nearby mobile devices and initiates communication. A key operational aspect is a "discover-and-cancel" connection process where the beacon transmits its unique identifier during a connection request and then may terminate the process before a full, user-approved pairing is complete, making the interaction faster and less intrusive. (’979 Patent, Abstract; col. 14:60-67; FIG. 8).
  • Technical Importance: By focusing on an efficient, low-overhead method for a beacon to announce its presence to nearby devices, the invention provides a technical foundation for proximity systems that can operate at scale without requiring explicit user action for every interaction. (’979 Patent, col. 15:1-11).

Key Claims at a Glance

  • The complaint asserts independent claim 26 and dependent claims 27, 35, and 36. (Compl. ¶32).
  • Independent Claim 26 recites a method for data exchange at a transceiver with the essential elements:
    • Discovering wireless mobile devices within a proximity range of the transceiver.
    • Initiating communication with one or more of the discovered devices.
    • Exchanging data with the devices, which includes at least one of receiving input data from a device or transmitting output data to a device.
    • The transmitted output data includes a "unique identifier associated with the transceiver."

Other Patents-in-Suit

  • Patent Identification: U.S. Patent No. 9,219,981, “Distributed Data in a Close Proximity Notification System,” issued December 22, 2015. (Compl. ¶¶12-13).

  • Technology Synopsis: This patent describes a transceiver-based system for providing distributed data. The transceiver discovers a mobile device, receives a request for information from it, identifies a "retrieval location" for a subset of that information, and transmits the location (or the information subset itself) back to the device. (’981 Patent, Abstract).

  • Asserted Claims: Independent claim 26. (Compl. ¶39).

  • Accused Features: Samsung Galaxy smartphones with Samsung Quick Share or Samsung Smart Switch. (Compl. ¶39).

  • Patent Identification: U.S. Patent No. 9,628,949, “Distributed Data in a Close Proximity Notification System,” issued April 18, 2017. (Compl. ¶¶14-15).

  • Technology Synopsis: This invention covers a transceiver that discovers, initiates communication with, and exchanges data with nearby mobile devices. The data exchange includes transmitting a unique identifier associated with the transceiver, which a mobile device can then use to access information. (’949 Patent, Abstract).

  • Asserted Claims: Independent claim 19. (Compl. ¶46).

  • Accused Features: Samsung Galaxy smartphones with Samsung Smart Switch or Samsung Quick Share. (Compl. ¶46).

  • Patent Identification: U.S. Patent No. 9,674,688, “Close Proximity Notification System,” issued June 6, 2017. (Compl. ¶¶16-17).

  • Technology Synopsis: This patent claims a method performed on a mobile device. The device receives a signal with an identification code from a short-range transmitter and processes that signal "exclusively by the application... and independently of any networks" to identify a retrieval location for associated information, which is then retrieved and displayed. (’688 Patent, cl. 1).

  • Asserted Claims: Independent claims 1 and 14. (Compl. ¶53).

  • Accused Features: Samsung Galaxy smartphones with SmartThings Find and/or Samsung Quick Share. (Compl. ¶53).

  • Patent Identification: U.S. Patent No. 9,693,190, “Campus Security in a Close Proximity Notification System,” issued June 27, 2017. (Compl. ¶¶18-19).

  • Technology Synopsis: This patent applies proximity notification technology to a campus security context. A mobile device receives a signal from a transmitter, processes it to obtain an address for a security system, monitors for user input (e.g., a security request), and transmits the request to the security system. (’190 Patent, Abstract).

  • Asserted Claims: Independent claim 14. (Compl. ¶60).

  • Accused Features: Samsung Galaxy smartphones with SmartThings Find. (Compl. ¶60).

  • Patent Identification: U.S. Patent No. 9,743,229, “System and Method for Facilitating Interpersonal Contacts and Social and Commercial Networking,” issued August 22, 2017. (Compl. ¶¶20-21).

  • Technology Synopsis: This invention describes a social networking method where a server generates a "pre-qualifying list" of users based on matching criteria and location. A user's mobile device is notified when another user from that list is detected in close proximity via a short-range wireless protocol. (’229 Patent, Abstract).

  • Asserted Claims: Independent claims 1 and 19. (Compl. ¶67).

  • Accused Features: Samsung Galaxy smartphones with SmartThings Find. (Compl. ¶67).

  • Patent Identification: U.S. Patent No. 9,998,906, “Close Proximity Notification System,” issued June 12, 2018. (Compl. ¶¶22-23).

  • Technology Synopsis: Similar to the ’688 patent, this patent claims a method where a mobile device receives a signal from a transmitter and processes it "exclusively by the wireless communication device and independently of any networks" to identify a retrieval location for associated information. (’906 Patent, Abstract).

  • Asserted Claims: Independent claims 1 and 9. (Compl. ¶72).

  • Accused Features: Samsung Galaxy smartphones with SmartThings Find. (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "Samsung Galaxy smartphones" running specific software features, including "Samsung SmartThings Find," "Samsung Quick Share," and "Samsung Smart Switch." (Compl. ¶¶25, 32).

Functionality and Market Context

  • The complaint identifies these products as follows:
    • SmartThings Find: A service for locating Samsung Galaxy devices. (Compl. ¶25).
    • Quick Share and Smart Switch: Features for transferring files and data between mobile devices, respectively. (Compl. ¶32).
  • The complaint alleges these features are integrated into Defendant's smartphones and utilize the patented proximity-based communication methods. The complaint does not provide specific details on the commercial importance of these features, apart from their inclusion in widely sold smartphones. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim chart exhibits for each count but does not attach them; therefore, the infringement allegations are summarized below in prose. (Compl. ¶¶25, 32).

  • ’642 Patent Infringement Allegations: The complaint alleges that Samsung Galaxy smartphones running SmartThings Find infringe at least claim 1 of the ’642 Patent. (Compl. ¶25). The narrative infringement theory suggests that the smartphones receive short-range wireless signals from other devices, and the SmartThings Find application processes these signals locally to identify and retrieve location information, which is then displayed to the user, thereby practicing the claimed method.
  • ’979 Patent Infringement Allegations: The complaint alleges that Samsung Galaxy smartphones running Quick Share or Smart Switch infringe at least claim 26 of the ’979 Patent. (Compl. ¶32). The theory appears to be that the smartphones themselves act as the claimed "transceiver" or "beacon." In this role, they allegedly discover other nearby mobile devices and exchange data, including a unique identifier, to facilitate the data or file transfer process, thereby performing the steps of the claimed method.
  • Identified Points of Contention:
    • Scope Questions: The infringement theory for the ’979 patent raises the question of whether a general-purpose smartphone, acting as both a user device and a discovery beacon, falls within the scope of the term "transceiver," which is depicted in patent figures as a distinct hardware component separate from the user's mobile device. (’979 Patent, FIG. 1).
    • Technical Questions: For the ’642 patent, a central technical question may be whether the accused SmartThings Find system performs the "processing" step "independently of any networks" as required by claim 1. The functionality of modern device-finding networks often involves communication with a cloud-based service, which may create a potential mismatch with this claim limitation.

V. Key Claim Terms for Construction

  • The Term: "processing the signal... exclusively by a software application located on the mobile device and independently of any networks" (’642 Patent, cl. 1).

    • Context and Importance: This limitation is central to the infringement analysis for the ’642 patent (and related patents like ’688 and ’906). Its construction will determine whether any use of a network during the process of converting the received signal into displayed information removes an accused product from the claim's scope. Practitioners may focus on this term because device-finding functionalities like SmartThings Find often rely on a network of devices reporting locations to a central server.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the mobile device contacting an application server after receiving the transceiver's signal. (e.g., ’642 Patent, col. 6:11-24). This may support an interpretation where only the initial step of processing the raw wireless signal to extract its identifier must be network-independent, while subsequent steps to retrieve information can involve a network.
      • Evidence for a Narrower Interpretation: The explicit "exclusively" and "independently of any networks" language is restrictive. The patent’s background distinguishes the invention from "Internet-based marketing services," which could support an argument that the entire claimed process, from signal reception to information retrieval, was intended to be self-contained on the device without network reliance. (’642 Patent, col. 2:37-38).

  • The Term: "transceiver" (’979 Patent, cl. 26).

    • Context and Importance: The complaint accuses a smartphone of being the claimed "transceiver." The definition of this term is critical because the patent specification frequently illustrates the "transceiver" as a dedicated, stationary beacon distinct from the user's "mobile device."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The Abstract defines the transceiver by its components—"an antenna, a processing device, and a memory device"—all of which are present in a modern smartphone. (’979 Patent, Abstract). This may support reading the term on a general-purpose device performing the claimed functions.
      • Evidence for a Narrower Interpretation: Figures 1 and 2 consistently depict "Transceiver 14" as a separate hardware unit from "Mobile Device 12." (’979 Patent, FIG. 1, FIG. 2). This distinction could support an argument that the term was intended to cover a dedicated beacon, not a multi-function device that also serves as the user's primary interface.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all asserted patents. The allegations are based on Defendant’s alleged knowledge of infringement "at least since receiving notice... by service of Plaintiff’s complaint" and its continued sale of accused products along with "product literature or videos inducing end users" to use the accused features. (e.g., Compl. ¶¶27, 34, 41).
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or a request for enhanced damages under 35 U.S.C. § 284.

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

  1. A core issue will be one of definitional scope: can terms like "transceiver" and "beacon," which are often illustrated in the patents as dedicated hardware deployed at a location, be construed to cover general-purpose smartphones performing peer-to-peer functions like file sharing or device finding?
  2. A key evidentiary question will be one of technical operation: does the accused functionality, particularly in a networked service like SmartThings Find, satisfy the claim limitation requiring certain processing steps to be performed "exclusively by a software application... and independently of any networks"?
  3. A central question of technological fit may arise concerning the ’229 patent, which is directed to facilitating "interpersonal contacts and social... networking." The case may turn on whether a utility feature for finding lost devices can be shown to practice the claims of a patent rooted in connecting people.