DCT
4:21-cv-00089
R2 Solutions LLC v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: R2 Solutions LLC (Texas)
- Defendant: Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Nelson Bumgardner Albritton PC
- Case Identification: 4:21-cv-00089, E.D. Tex., 01/29/2021
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business in the District, specifically a large corporate office in Plano, and has committed alleged acts of infringement within the District.
- Core Dispute: Plaintiff alleges that Defendant’s Samsung SmartThings and Samsung Bixby systems infringe three patents, originally filed by Yahoo!, related to conditional message delivery, search query reconstruction, and user interface methods for launching searches.
- Technical Context: The technologies at issue concern methods for improving how users interact with networked services, particularly in making communications more context-aware and making search functions more accessible on devices with limited input capabilities.
- Key Procedural History: The complaint notes that the patents-in-suit were originally filed by Yahoo! Inc. between 2006 and 2009. It also states that U.S. Patent No. 8,209,317 is a continuation of two earlier patent applications, which establishes an earlier priority date for that patent family.
Case Timeline
| Date | Event |
|---|---|
| 2006-08-10 | Priority Date for U.S. Patent No. 8,209,317 |
| 2007-03-29 | Priority Date for U.S. Patent No. 7,610,277 |
| 2007-12-10 | Priority Date for U.S. Patent No. 8,307,029 |
| 2009-10-27 | U.S. Patent No. 7,610,277 Issued |
| 2012-06-26 | U.S. Patent No. 8,209,317 Issued |
| 2012-11-06 | U.S. Patent No. 8,307,029 Issued |
| 2021-01-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,307,029 - "System and Method for Conditional Delivery of Messages"
- Patent Identification: U.S. Patent No. 8,307,029, "System and Method for Conditional Delivery of Messages," issued November 6, 2012. (Compl. ¶13).
The Invention Explained
- Problem Addressed: The patent describes a deficiency in how electronic devices handle the "great deal of information" they generate, noting that most of this contextual information is "effectively abandoned" or unused. (’029 Patent, col. 1:6-20; Compl. ¶18).
- The Patented Solution: The invention proposes a communication network ("W4 COMN") that uses various types of data—social, spatial, temporal, and logical ("W4 COMN data")—associated with "Real World Entities" (RWEs) like users and devices, and "Information Objects" (IOs). (’029 Patent, col. 3:34-44; Compl. ¶19). A central "W4 engine" analyzes this data to determine if user-defined delivery conditions are met, and if so, delivers a message, thereby making communications context-aware. ('029 Patent, col. 8:24-40; Compl. ¶19).
- Technical Importance: The technology aimed to improve the efficiency and effectiveness of distributed systems by leveraging ambient, multi-source data to make message delivery more intelligent and responsive to real-world situations. (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶35).
- The essential elements of independent claim 1 include:
- receiving from a sender, at a computing device, a request to deliver a first message to a recipient, the request identifying at least one delivery condition set by the sender;
- identifying, via the computing device, at least one real world entity (RWE) and information object (IO) associated with the at least one delivery condition;
- retrieving, at the computing device, W4 COMN data associated with each of the identified at least one RWE and IO, the W4 COMN data comprising social data, spatial data, temporal data and logical data;
- monitoring, via the computing device, the W4 COMN data for current information... to determine that the at least one delivery condition is met; and
- delivering, over a network, the first message when the at least one delivery condition is met. (Compl. ¶20).
- The complaint also asserts dependent claims 4-6 and 10. (Compl. ¶35).
U.S. Patent No. 8,209,317 - "Method and Apparatus for Reconstructing a Search Query"
- Patent Identification: U.S. Patent No. 8,209,317, "Method and Apparatus for Reconstructing a Search Query," issued June 26, 2012. (Compl. ¶14).
The Invention Explained
- Problem Addressed: The patent notes that traditional search engine interfaces "may be rigid and require uses to submit full queries," which is a barrier on portable devices like cell phones that have limited input capabilities and may lack a full keyboard. (’317 Patent, Abstract, col. 1:44-53; Compl. ¶22).
- The Patented Solution: The invention discloses a system that receives a "partial query," defined as an "abbreviated or incomplete search query." (’317 Patent, Claim 1). The system's "query reconstruction server" then determines a "full query" by using both the received partial query and "information stored in the database about queries previously-submitted by users." ('317 Patent, col. 4:1-13; Compl. ¶23).
- Technical Importance: The technology sought to make internet search more accessible and efficient on a growing variety of mobile devices by lowering the barrier to query entry. ('317 Patent, col. 1:43-56; Compl. ¶24).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶44).
- The essential elements of independent claim 1 include:
- a database configured to store information about events in the computer database system; and
- a query reconstruction server that receives a partial query submitted by a user and, in response, determines a full query based on (i) the received partial query, and (ii) information stored in the database about previously-submitted queries;
- wherein the partial query is abbreviated or incomplete, and the full query is a better representation of the user's desired search. (Compl. ¶23).
- The complaint also asserts dependent claims 2, 8-10, and 12. (Compl. ¶44).
U.S. Patent No. 7,610,277 - "Method and System for Launching a Browser"
- Patent Identification: U.S. Patent No. 7,610,277, "Method and System for Launching a Browser," issued October 27, 2009. (Compl. ¶15).
Technology Synopsis
The patent addresses the problem of "crowded" graphical user interfaces that can impede a user's tasks. (’277 Patent, col. 1:9-13; Compl. ¶25). It discloses a system that, upon detecting a keyboard message, displays an "interim graphical user interface" for search input, then constructs a search string and launches a different browser program to perform the search, thereby improving usability and saving time. (’277 Patent, Abstract; Compl. ¶¶27-28).
Asserted Claims
The complaint asserts independent claim 14. (Compl. ¶53).
Accused Features
The complaint alleges that Samsung devices equipped with the Samsung Bixby assistant, including numerous models in the Galaxy S and Note series, infringe the ’277 patent. (Compl. ¶53).
III. The Accused Instrumentality
Product Identification
The complaint identifies two sets of accused instrumentalities: (1) the "Samsung SmartThings system," which includes the SmartThings Hub and SmartThings Cloud, and (2) "Samsung Bixby," a virtual assistant integrated into numerous Samsung devices. (Compl. ¶7). These are collectively referred to as the "Samsung Systems."
Functionality and Market Context
- The complaint alleges the Samsung SmartThings system infringes the ’029 patent. (Compl. ¶35). This system is described as a platform for connecting and managing various smart home devices, implying a network of interacting entities and data sources.
- The complaint alleges Samsung Bixby infringes the ’317 and ’277 patents. (Compl. ¶¶44, 53). Bixby is identified as a feature on a wide range of Samsung's flagship mobile devices, including the Galaxy S and Note series, that allows users to perform searches and other tasks. (Compl. ¶53). The allegations suggest Bixby's functionality involves receiving user input (including text and voice), processing it on backend servers, and providing results.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references but does not include claim chart exhibits detailing its infringement theories (Compl. ¶¶36, 45, 54). The analysis below is constructed from the complaint's narrative allegations.
'029 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving from a sender, at a computing device, a request to deliver a first message [to] a recipient, the request identifying at least one delivery condition set by the sender; | The complaint alleges that the Samsung SmartThings system, comprising the SmartThings Hub and Cloud, is capable of receiving requests (e.g., user-configured automations) to perform actions based on specified delivery conditions (e.g., a sensor detecting motion). | ¶¶7, 18-20, 35 | col. 15:23-28 |
| identifying, via the computing device, at least one real world entity (RWE) and information object (IO) associated with the at least one delivery condition; | The SmartThings system is alleged to operate by identifying real-world entities (e.g., users, smart lights, sensors) and information objects (e.g., device status, sensor data) that are associated with a configured automation or condition. | ¶¶19, 35 | col. 15:29-32 |
| retrieving... W4 COMN data comprising social data, spatial data, temporal data and logical data available to the network...; | The SmartThings Cloud is alleged to retrieve and process various data points from its network of connected devices, which corresponds to the patent's "W4 COMN data" comprising spatial (e.g., device location), temporal (e.g., time of day), and logical (e.g., device state) information. | ¶¶19, 35 | col. 15:33-39 |
| monitoring, via the computing device, the W4 COMN data... to determine that the at least one delivery condition is met; and | The SmartThings Hub and Cloud are alleged to monitor the data from connected devices and the environment to determine when a pre-configured condition (e.g., "if front door opens after sunset") is met. | ¶¶19, 35 | col. 15:40-45 |
| delivering, over a network, the first message when the at least one delivery condition is met. | Upon a determination that a condition is met, the SmartThings system is alleged to deliver a message (e.g., a command to turn on a light, a notification to a user's phone) over the network. | ¶¶19, 35 | col. 15:46-49 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the "Samsung SmartThings" home automation platform constitutes the "conditional delivery of messages" as contemplated by the patent. The definition of "message" may be a point of dispute—whether it is broad enough to cover commands between IoT devices.
- Technical Questions: The infringement analysis will likely focus on whether the data architecture of the SmartThings Cloud and Hub is equivalent to the specific "W4 COMN" data model (social, spatial, temporal, logical) described in the patent, or if there is a technical mismatch.
'317 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer database system for providing search results to a user... comprising: a database configured to store information about events in the computer database system; and | The complaint alleges that Samsung operates databases and servers for the Bixby infrastructure, which provides search results to users. These databases are alleged to store information about system events, including prior user queries. | ¶¶23, 44 | col. 5:21-24 |
| a query reconstruction server... operative to receive a partial query submitted at a remote user client system... | Samsung's servers hosting the Bixby infrastructure are alleged to function as a "query reconstruction server" that receives user input, characterized as a "partial query," from devices like Samsung smartphones. | ¶¶23, 44 | col. 5:25-30 |
| and, in response to the received partial query, determine a full query based on (i) the received partial query, and (ii) information stored in the database about queries previously-submitted by users, | Bixby is alleged to determine a user's intended "full query" by processing the user's "partial query" (e.g., an abbreviated or incomplete phrase) in the context of information from its database, which includes data on previously submitted queries. | ¶¶23, 24, 44 | col. 5:30-36 |
| wherein the submitted partial query comprises an abbreviated or incomplete search query... and the full query is better representative of the entire search query desired by the user. | The complaint alleges that Bixby is designed to handle abbreviated or incomplete user inputs and transform them into a "full query" that better represents the user's intent, such as correcting a misspelling or completing a phrase. | ¶¶23, 24, 44 | col. 5:37-43 |
- Identified Points of Contention:
- Scope Questions: The case may turn on whether Bixby's natural language processing and query suggestion features fall under the patent's definition of "reconstruct[ing] a search query" from a "partial query." The scope of "partial query" will be critical.
- Technical Questions: An evidentiary question will be whether Bixby's method for determining a user's intent relies on "information stored in the database about queries previously-submitted by users" in the manner required by the claim.
V. Key Claim Terms for Construction
'029 Patent
- The Term: "W4 COMN data"
- Context and Importance: This term appears to be a neologism created by the patentee and is central to defining the invention of the ’029 patent. The entire method of claim 1 depends on retrieving and monitoring this specific type of data. The patent's scope will be significantly influenced by whether this term is construed broadly to mean any contextual data or narrowly to mean the specific categories and architecture described in the specification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself defines the term with a list: "comprising social data, spatial data, temporal data and logical data." (Compl. ¶20; ’029 Patent, col. 35:36-37). The use of "comprising" suggests this list may be non-exhaustive.
- Evidence for a Narrower Interpretation: The specification provides a detailed conceptual model of the "W4 COMN" as a set of four "clouds" (Who, Where, What, When) and describes a layered architecture for processing this data. (’029 Patent, Fig. 3, Fig. 4, col. 7:60-col. 8:24). A defendant may argue that "W4 COMN data" is limited to data organized and processed within this specific, disclosed framework.
'317 Patent
- The Term: "partial query"
- Context and Importance: This term is the input to the claimed system and is fundamental to the infringement analysis for the ’317 patent. Practitioners may focus on this term because its construction will determine what types of user input (e.g., simple abbreviations, misspellings, complex voice commands) can be considered to meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim defines the term as an "abbreviated or incomplete search query which is not fully representative of an entire search query desired by the user." (’317 Patent, col. 5:37-41). This functional language could be argued to cover any input that requires interpretation or completion by the system.
- Evidence for a Narrower Interpretation: The specification provides a specific example: "‘auto ins’ may be a partial query for the full search query ‘auto insurance.’" (’317 Patent, col. 3:20-23). A defendant could argue this limits the term to user-created shorthand or abbreviations, as opposed to system-interpreted natural language or simple typographical errors.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for the ’277 patent. Inducement is alleged based on Samsung's "instructional materials that specifically teach and encourage" users to operate Bixby in an infringing manner (Compl. ¶58). Contributory infringement is alleged on the basis that devices with Bixby are not "staple articles of commerce suitable for substantial non-infringing uses" because they contain proprietary hardware and specifically programmed software to perform the allegedly infringing functions (Compl. ¶59).
- Willful Infringement: While the complaint does not contain a separate count for willful infringement, it alleges for the ’277 patent that "Samsung has knowledge of the '277 patent at least based on the filing and service of this Complaint." (Compl. ¶56). This allegation establishes a basis for potential post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can terms coined for an earlier technological context, such as the "W4 COMN data" architecture in the ’029 patent and the "partial query" reconstruction in the ’317 patent, be construed to cover the operations of modern, AI-driven platforms like Samsung’s SmartThings and Bixby? The outcome will likely depend on whether the court views these claims as being tied to their specific disclosed embodiments or as covering a broader functional concept.
- A second key question will be one of technological equivalence: Does the accused Bixby system, which processes natural language, operate in a manner that is technically equivalent to the ’317 patent's method of reconstructing a full query from an "abbreviated or incomplete" one based on a database of prior queries? Similarly, does the SmartThings IoT ecosystem function as a "conditional message delivery" system as claimed in the ’029 patent, or is there a fundamental mismatch in their respective technical operations and architectures?