United States CP LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: United States CP, LLC (Delaware)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Williams Simons & Landis PC
• Case Identification: 2:26-cv-00083, E.D. Tex., 02/02/2026
• Venue Allegations: Venue is alleged against Samsung Electronics Co., Ltd., a foreign entity, as proper in any judicial district. Venue is alleged against Samsung Electronics America, Inc. based on its purported "regular and established place of business" in Plano, Texas, within the district, where it allegedly employs personnel and conducts business operations related to the accused mobile devices.
• Core Dispute: Plaintiff alleges that a wide range of Defendant’s smartphones and tablets infringe two patents related to physical finger guides for improving the accuracy and usability of fingerprint sensors.
• Technical Context: The technology addresses the challenge of ensuring consistent finger placement on small, cost-effective fingerprint sensors common in consumer electronics, thereby reducing authentication failures.
• Key Procedural History: The complaint alleges extensive pre-suit history, including that a predecessor-in-interest to the patents, Pen-One Inc., engaged in licensing discussions with Samsung regarding the underlying patent applications between 2012 and 2013. The complaint further alleges that a 2014 Samsung international patent application (PCT/KR2014/007342) received an International Search Report that identified a publication of the patents-in-suit’s parent application as relevant prior art. These allegations are positioned to support a claim of pre-suit knowledge and willful infringement.

Case Timeline

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

U.S. Patent No. 9,760,753 - "Finger Guide Device"

The Invention Explained

• Problem Addressed: The patent’s background section notes that as fingerprint sensors become smaller to reduce cost, particularly in consumer electronics, it becomes difficult for users to place their finger on the same "relevant portion" each time. This inconsistency leads to "false rejects," where an authorized user is denied access, causing user frustration and reducing system effectiveness (’753 Patent, col. 2:7-29).
• The Patented Solution: The invention is a method using a physical finger guide with a specifically shaped recess to intuitively and non-forcibly guide a user's finger to a consistent position over the sensor. The patent describes a "preferred embodiment" where the guide has a recess with a short concave radius at the front (near the fingertip) and a longer, less steep concave radius at the back, creating an ergonomic contour that improves repeatable placement (’753 Patent, Abstract; col. 4:15-30).
• Technical Importance: The claimed method aimed to make smaller, less expensive fingerprint sensors commercially viable by improving their reliability and user experience without requiring costly, large-area sensors (’753 Patent, col. 2:7-15).

Key Claims at a Glance

• The complaint asserts independent claim 1, a method claim Compl. ¶51
• The essential elements of Claim 1 include:
  • An "enrollment step" of scanning several overlapping portions of a finger and assembling them into a "completed template" larger than any single scan.
  • An "identification or authentication step" using a fingerprint scanner located within a "finger guide device."
  • The finger guide device has "side surfaces that form a recess" with a "short concave radius at front end" and a "longer concave radius... at the back end."
  • "slidingly guiding" the finger downward along the side surfaces to a "stable position of global minimum" over the scanner.
  • The guiding causes the finger to touch the sensor "consistently in a same approximate place" for comparison with the completed template.
• The complaint reserves the right to assert other claims Compl. ¶51

U.S. Patent No. 9,830,493 - "Finger Guide Device with Capacitive Sensor"

The Invention Explained

• Problem Addressed: As a divisional of the '753 patent's application, the '493 patent addresses the same underlying problem of inconsistent finger placement on small sensors (’493 Patent, col. 2:15-28).
• The Patented Solution: The invention is a device claim for a finger guide with specific structural and functional features. It claims a "funnel shaped" recess to guide the finger, a "capacitive fingerprint scanner" within that recess, and a "drive ring" to provide an electrical signal. Uniquely, it also claims the finger guide is configured to be used as a "pointing control device" via touch gestures (’493 Patent, Abstract; col. 8:1-12).
• Technical Importance: This patent extends the finger guide concept beyond simple positioning to encompass a multi-functional input device, integrating biometric security with user interface navigation features (’493 Patent, col. 7:56-65).

Key Claims at a Glance

• The complaint asserts independent claim 1, a device claim Compl. ¶69
• The essential elements of Claim 1 include:
  • A "finger guide" with side surfaces forming a "funnel shaped" recess with a "circular, oval, square, or rectangular mouth."
  • A "capacitive fingerprint scanner" aligned within the recess, enabling a relevant portion of the finger to rest in a "stable position."
  • A "drive ring" on the surface of the finger guide device to "provide an electrical signal to illuminate partial portions of the fingerprint."
  • The finger guide is "configured to be utilized as a pointing control device" by applying a touch gesture in an "axial direction, lateral direction, and combinations thereof."
• The complaint reserves the right to assert other claims Compl. ¶69

III. The Accused Instrumentality

Product Identification

• The complaint identifies a broad range of Samsung smartphones and tablets as the "Accused Products," including various models from the Galaxy S, Note, A, M, F, J, Z, and Tab series Compl. ¶31

Functionality and Market Context

• The complaint alleges that the Accused Products incorporate fingerprint sensors for user authentication to unlock the device or access secure features Compl. ¶53 The allegations focus on two types of implementations: sensors integrated into the side-mounted power key (e.g., Galaxy S10e) and under-display sensors Compl. ¶¶12, 14, 52 The complaint describes the user enrollment process, which requires multiple scans to create a full fingerprint template Compl. ¶54 A teardown image in the complaint shows the alleged physical finger guide component separated from a phone's chassis Compl. ¶57, p. 17 The complaint also highlights a "Finger sensor gestures" feature, which allows users to swipe on the sensor to control the notification panel Compl. ¶73

IV. Analysis of Infringement Allegations

'753 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may be whether the physical structure surrounding the sensors in the Accused Products, such as a bezel or chassis opening, meets the specific geometric limitations of the "finger guide device", particularly the "short concave radius at front" and "longer concave radius at the back." The complaint makes a conclusory allegation supported by a teardown photo but offers no analysis of the component's actual geometry Compl. ¶57, p. 17
  • Technical Questions: What evidence will be presented to demonstrate that the accused structure "slidingly guid[es]" the finger to a "stable position of global minimum" as the claim requires, rather than simply defining the boundary of the active sensor area?

'493 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Does the accused "Finger sensor gestures" feature, which allows swiping up or down to open a notification panel, constitute use as a "pointing control device"? The defense may argue this term implies more complex, cursor-like control, whereas the complaint's evidence shows a simple, one-dimensional gesture.
  • Technical Questions: What evidence does the complaint provide that the accused component includes a "drive ring" that performs the claimed function of providing an "electrical signal to illuminate" the fingerprint? The allegation is made, but the visual evidence is not self-explanatory on this point (Compl. ¶72). Further, does the physical shape of the accused component meet the definition of "funnel shaped" as used in the patent?

V. Key Claim Terms for Construction

• The Term: "finger guide device"
• Context and Importance: This term is the central element of both patents. Its construction will determine whether a simple bezel or chassis opening around a sensor can be considered the claimed invention. Practitioners may focus on this term because if it is construed narrowly to require the specific ergonomic contours described in the specification, infringement may be more difficult to prove against devices with flat or uniformly sloped surfaces.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves use general language like "side surfaces that form a recess" (’753 Patent, cl. 1), which could support a construction that covers any structure creating a depression for the finger.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the guide's shape in specific geometric terms (e.g., "short concave radius at the front" and "longer concave radius... at the back") as part of a "preferred embodiment" that enables the guiding function (’753 Patent, col. 4:22-30). A defendant could argue these details are essential to the invention, not merely exemplary.
• The Term: "pointing control device"
• Context and Importance: This limitation is unique to the asserted claim of the '493 patent. The infringement allegation hinges entirely on whether Samsung's "Finger sensor gestures" feature falls within this term's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is broad, requiring only the ability to apply a "touch gesture selected from at least one direction: axial direction, lateral direction, and combinations thereof" (’493 Patent, cl. 1). This could be argued to cover the simple up/down swipe alleged in the complaint Compl. ¶73
  • Evidence for a Narrower Interpretation: The specification discusses the guide serving as a "proportional input device" and facilitating "a variety of input applications" (’493 Patent, col. 7:62-65). A defendant may argue that a simple, non-proportional swipe to open a notification panel does not meet the full scope of a "pointing control device" as contemplated by the patent.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Samsung provides user manuals and customer support that instruct and encourage end-users to perform the infringing methods (e.g., enrolling and using the fingerprint scanner) Compl. ¶¶ 62, 65, 80 It also alleges contributory infringement, arguing that the finger guide and sensor components are special features, not staple articles of commerce, that are specially designed to be used in an infringing way Compl. ¶¶ 66, 81
• Willful Infringement: Willfulness is a central theme of the complaint. It is supported by extensive allegations of pre-suit knowledge, including a detailed history of meetings, emails, and portfolio discussions between Samsung and the patents' predecessor-in-interest from 2012 to 2013 Compl. ¶¶ 35-43 The complaint further alleges that Samsung was put on notice of the parent application via an International Search Report for its own related patent filing in 2014 Compl. ¶¶ 44-46 Knowledge is also alleged from the service of the complaint Compl. ¶¶ 60, 74

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

• A primary issue will be one of definitional scope: does the physical bezel or chassis opening surrounding the fingerprint sensors in Samsung's products meet the specific geometric requirements of a "finger guide device" with differential concave radii as recited in Claim 1 of the '753 patent, or is this an attempt to apply the claim to a conventional design feature?
• A key question of functional interpretation will be whether the "Finger sensor gestures" feature, which enables a simple up/down swipe to control a notification panel, transforms the hardware into a "pointing control device" as required by Claim 1 of the '493 patent, or if that term requires more sophisticated, pointer-like functionality.
• A central factual question will concern willfulness: given the detailed allegations of pre-suit communications with a predecessor-in-interest and notice via a patent office action dating back over a decade before the suit was filed, the determination of whether any infringement was willful, should infringement be found, will likely be a significant focus of the litigation.