Pinn Audio LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pinn Audio, LLC (Delaware)
  • Defendant: Samsung Electronics Co. Ltd. (Republic of Korea); Samsung Electronics America Ltd. (New York)
  • Plaintiff’s Counsel: Folio Law Group PLLC; Cherry Johnson Siegmund James
• Case Identification: 2:26-cv-00077, E.D. Tex., 01/29/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America Ltd. maintains regular and established places of business in the district, including corporate offices and an innovation center in Plano and Richardson, Texas. For Defendant Samsung Electronics Co. Ltd., a foreign entity, venue is alleged to be proper in any U.S. judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s Galaxy Buds series of wireless headphones infringes six U.S. patents related to mobile systems comprising a base station and a detachable wireless earbud.
• Technical Context: The technology at issue involves the functional relationship between wireless earbuds and their charging cases, particularly concerning pairing, charging, and communication management with a smartphone, a highly competitive segment of the consumer electronics market.
• Key Procedural History: The complaint alleges that a predecessor-in-interest to the Plaintiff, Pinn, Inc., previously sued Samsung Electronics America, Inc. in the Central District of California in 2019 over related patents. That litigation, which was dismissed pursuant to a settlement in 2020, allegedly provided Samsung with actual notice of at least two of the patents-in-suit ('066 and '198 patents), forming the basis for the current complaint’s allegations of willful infringement.

Case Timeline

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

U.S. Patent No. 10,455,066 - "Mobile System with Wireless Earbud"

• Patent Identification: U.S. Patent No. 10,455,066, titled "Mobile System with Wireless Earbud," issued October 22, 2019. Compl. ¶18

The Invention Explained

• Problem Addressed: The patent's background describes the inconvenience of accessing functions on a primary mobile device, such as a smartphone, when it is stored away in a pocket or bag. ’066 Patent, col. 1:12-21
• The Patented Solution: The invention proposes a "personal wireless media station" comprising a base station and a detachable wireless earbud. ’066 Patent, Abstract The system is designed to play sound through a speaker on the base station when the earbud is docked and automatically redirect sound to the earbud's speaker when it is undocked, providing a seamless user experience for accessing media. ’066 Patent, col. 2:32-44
• Technical Importance: This integrated approach sought to enhance user convenience by combining charging, storage, and audio output control into a single, portable accessory that could be clipped to clothing. ’066 Patent, col. 1:18-21

Key Claims at a Glance

• The complaint asserts infringement of one or more claims, including at least independent claim 1. Compl. ¶31
• The essential elements of independent claim 1 include:
  • A "mobile system" comprising a "base station" and a "wireless earbud."
  • The base station includes a "connection hole," a "user input button," a processor, memory, and circuitry.
  • The earbud is configured to plug into the connection hole to form an "integrated body."
  • The system is capable of wirelessly pairing with a smartphone.
  • Pressing the user input button initiates processing for the wireless pairing.
  • Plugging the earbud into the connection hole initiates charging of the earbud's battery.
  • When plugged in, the earbud electrically connects with the base station's circuitry and performs "wired data communication" with the base station. Compl. ¶32

U.S. Patent No. 10,609,198 - "Personal Media System Including Base Station and Wireless Earbud"

• Patent Identification: U.S. Patent No. 10,609,198, titled "Personal Media System Including Base Station and Wireless Earbud," issued March 31, 2020. Compl. ¶20

The Invention Explained

• Problem Addressed: Similar to the ’066 Patent, the technology addresses the need for more convenient interaction with a paired mobile device. ’198 Patent, col. 1:12-24
• The Patented Solution: The patent discloses a similar mobile system of a base station and a dockable wireless earbud. This patent adds claims for specific functionalities, such as the system being configured to generate a sound when a mobile application on the smartphone is searching for it. ’198 Patent, col. 2:25-29 It also introduces a negative limitation, claiming that the wireless earbud "is not capable of wirelessly sending data to the mobile base station." ’198 Patent, col. 2:54-56
• Technical Importance: This patent refines the system's architecture by defining specific communication pathways and adding a "find my device" audio alert feature, addressing the common user problem of misplacing small electronic devices.

Key Claims at a Glance

• The complaint asserts infringement of one or more claims, including at least independent claim 1. Compl. ¶73
• In addition to elements similar to those in the '066 Patent's Claim 1, the essential elements of independent claim 1 of the '198 Patent include:
  • While plugged in, the base station circuitry is configured to "obtain characteristics of the wireless earbud."
  • The system is configured to "generate sound" when a mobile application is searching for it.
  • A negative limitation: "the wireless earbud is not capable of wirelessly sending data to the mobile base station." Compl. ¶74

U.S. Patent No. 10,701,197 - "Mobile System with Wireless Earbud"

• Patent Identification: U.S. Patent No. 10,701,197, titled "Mobile System with Wireless Earbud," issued June 30, 2020. Compl. ¶22
• Technology Synopsis: This patent describes a mobile system where the base station uses a "sensor for receiving user input" rather than a button. A key aspect is the claimed architecture of a "first communications module" in the base station and a "second communications module" in the earbud, which communicate via wired connection when docked, while only the second module (in the earbud) communicates wirelessly with the smartphone. Compl. ¶131
• Asserted Claims: Independent claim 1. Compl. ¶130
• Accused Features: The complaint accuses the Galaxy Buds3 Pro charging case's "Connect button" of being the claimed "sensor" and alleges that the system's communication architecture infringes the two-module claim structure. Compl. ¶¶141, 170-175

U.S. Patent No. 11,102,340 - "Mobile System with Wireless Earbud"

• Patent Identification: U.S. Patent No. 11,102,340, titled "Mobile System with Wireless Earbud," issued August 24, 2021. Compl. ¶24
• Technology Synopsis: This patent claims a mobile system that establishes a wireless pairing using "two-way wireless communication" between a smartphone and the earbud. The claim combines elements from prior patents, focusing on the complete communication loop initiated by a button press on the mobile base station that results in audio playback. Compl. ¶183
• Asserted Claims: Independent claim 1. Compl. ¶182
• Accused Features: The complaint targets the Galaxy Buds3 Pro's use of Bluetooth for two-way wireless communication with a smartphone, which is allegedly initiated via the "Connect button" on the charging case. Compl. ¶¶200-202

U.S. Patent No. 11,616,871 - "Mobile System with Wireless Earbud"

• Patent Identification: U.S. Patent No. 11,616,871, titled "Mobile System with Wireless Earbud," issued March 28, 2023. Compl. ¶26
• Technology Synopsis: This patent focuses on power and connection management. It claims a system where, in response to plugging the earbud into the base station, the processor is configured not only to initiate charging but also "to turn off the Bluetooth communication between the wireless earbud and the smartphone." Compl. ¶229
• Asserted Claims: Independent claim 1. Compl. ¶228
• Accused Features: The complaint alleges that the Galaxy Buds3 Pro infringes by disconnecting the Bluetooth link to the smartphone when the earbuds are placed in the charging case. Compl. ¶¶261-262, 264

U.S. Patent No. 11,849,061 - "Mobile System with Wireless Earbud"

• Patent Identification: U.S. Patent No. 11,849,061, titled "Mobile System with Wireless Earbud," issued December 19, 2023. Compl. ¶28
• Technology Synopsis: This patent recasts some of the system's components, referring to a "docking bay" instead of a "connection hole" and explicitly claiming a "rechargeable base station battery." It further claims that while the earbud is docked, the processor is configured to initiate "cessation of wireless communication" between the earbud and smartphone. Compl. ¶278
• Asserted Claims: Independent claim 1. Compl. ¶277
• Accused Features: The Galaxy Buds3 Pro charging case is accused of being a "mobile base station" with a "docking bay" and a rechargeable battery. The alleged function of terminating the Bluetooth connection upon docking is also targeted. Compl. ¶¶285, 287, 296, 323

III. The Accused Instrumentality

Product Identification

The complaint names the Samsung Galaxy Buds3 Pro, Buds3, and Buds3 FE as the "Accused Products," using the Galaxy Buds3 Pro as a representative example for its infringement analysis. Compl. ¶31

Functionality and Market Context

The Accused Products are described as a system comprising a pair of wireless earbuds and a corresponding charging case. The complaint alleges the charging case functions as the claimed "base station," containing a "Connect Button," processor, memory, circuitry, and charging contacts. (Compl. ¶¶38-42). According to the allegations, placing the earbuds in the case initiates charging and triggers wired communication of battery status. (Compl. ¶¶59, 64). Pressing the "Connect button" for several seconds is alleged to initiate Bluetooth pairing mode. (Compl. ¶53). The complaint also points to a "Samsung Find" application that can be used to generate sound from the earbuds to locate them. (Compl. ¶¶113-114). The complaint identifies Samsung as a "leading manufacturer" of wearables, positioning the Accused Products as commercially significant. (Compl. ¶3). The complaint provides an annotated teardown photograph of the accused charging case, identifying the alleged processor, memory, and circuitry on its internal printed circuit board. Compl. p. 10, ¶41

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,455,066 Infringement Allegations

U.S. Patent No. 10,609,198 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether a consumer "charging case" meets the definition of a "base station" or "mobile base station" as contemplated by the patents. The patent specifications describe the base station as part of a "personal wireless media station" that may include its own speaker for audio playback and an information display, functionalities absent from the accused charging case. ’066 Patent, col. 2:23-44
  • Technical Questions: The nature and sufficiency of the alleged "wired data communication" may be a point of contention. The complaint alleges this element is met by the communication of battery voltage levels and the signals for initiating pairing mode. (Compl. ¶¶64-65). A defendant could argue that such low-level signaling does not constitute "data communication" as taught by the patent, but rather simple control or status signals.
  • Evidentiary Questions: For the ’198 Patent, the complaint’s support for the negative limitation ("not capable of wirelessly sending data to the mobile base station") rests on an alleged absence of instructions and "information and belief." (Compl. ¶122). This raises the question of whether the plaintiff can produce sufficient technical evidence to prove this negative requirement.

V. Key Claim Terms for Construction

• The Term: "base station" / "mobile base station"

• Context and Importance: This term is foundational to infringement for all asserted patents. If the accused charging case is not construed as a "base station," the infringement theory may fail. Practitioners may focus on this term because the accused product's primary function is charging, whereas the patent specification describes a device with broader media functionalities.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims define the "base station" by its components (e.g., connection hole, user input button, processor) rather than its functions. Compl. ¶32 Plaintiff will likely argue that because the charging case allegedly contains these structural components, it meets the claim definition, regardless of other functions described in the specification.
  • Evidence for a Narrower Interpretation: The patent's abstract and summary repeatedly describe the invention as a "personal wireless media station" where the base station itself has a speaker for playing sound. ’066 Patent, Abstract; col. 2:35-44 A defendant may argue this context limits the scope of "base station" to a device capable of media playback, not merely charging.

• The Term: "wired data communication"

• Context and Importance: This term appears in claims across multiple patents and is critical to defining the interaction between the earbud and the case when docked. The dispute may turn on whether simple electrical signaling for status or control qualifies as "data communication."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent mentions the possibility of "two-way wired data communication" when the earbud is connected to the base station connector, without specifying the type or complexity of the data. ’066 Patent, col. 2:58-63 This could support an argument that any transfer of information, including battery status, qualifies.
  • Evidence for a Narrower Interpretation: The term "data communication" may be argued to imply a more substantial exchange of information than what is alleged (battery level and pairing initiation). A defendant may argue that these are better characterized as control or status signals, distinct from the "data" (e.g., audio data) otherwise discussed in the patents.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain separate counts for indirect infringement, but the factual allegations support a potential claim for inducement. It alleges that Samsung's documentation instructs users on how to operate the accused products in an infringing manner, such as by pressing the "Connect button" to initiate pairing and by placing the earbuds in the case to charge and disconnect from a paired device. (Compl. ¶¶53, 79, 261-262).
• Willful Infringement: Willfulness is alleged for all six patents. For the ’066 and ’198 patents, the claim is based on alleged pre-suit knowledge stemming from prior litigation filed in 2019 that expressly identified these patents and the accused technology. (Compl. ¶¶11-17, 69, 126). For the other four patents, which issued after the prior litigation settled, willfulness is alleged from at least the date the current complaint was filed. (Compl. ¶¶178, 224, 273, 333).

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

• A core issue will be one of definitional scope: can the term "base station," described in the patents as a component of a "personal wireless media station" with potential media playback functions, be construed to cover a consumer product whose primary purpose is to serve as a charging case?
• A key technical question will be one of functional characterization: does the electrical signaling for battery status and pairing initiation in the accused products constitute "wired data communication" as required by the claims, or does this represent a fundamental mismatch in technical operation compared to the functionality disclosed in the patents?
• An important evidentiary question will concern willfulness: given the history of prior litigation and settlement, the court will need to evaluate what Samsung knew about the patents and when, and whether its continued conduct after receiving notice met the standard for willful, deliberate infringement, potentially exposing it to enhanced damages.