DCT
4:23-cv-01145
Artax LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Artax LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York); Samsung Research America (California)
- Plaintiff’s Counsel: Key IP Law Group, PLLC
- Case Identification: 4:23-cv-01145, E.D. Tex., 12/28/2023
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung has committed acts of infringement and maintains regular and established places of business in the District, including Samsung Electronics America’s “Flagship North Texas Campus” in Plano and a Samsung Research America office in Plano.
- Core Dispute: Plaintiff alleges that Defendant’s smartphone features, specifically the “Emergency SOS” location sharing function and the “Bixby Vision” image analysis tool, infringe three patents related to location sharing over telecommunication networks and the contextual analysis of visual media.
- Technical Context: The technologies at issue involve real-time, dynamic location sharing between mobile devices and the extraction of contextual data from images, both of which are central features in the modern smartphone market.
- Key Procedural History: The complaint notes that U.S. Patent No. 8,509,412 is a continuation of the application that led to U.S. Patent No. 8,107,608, indicating a direct familial relationship between two of the three patents-in-suit. No other significant procedural history is mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2001-07-17 | Priority Date for ’608 & ’412 Patents |
| 2012-01-31 | ’608 Patent Issue Date |
| 2013-08-13 | ’412 Patent Issue Date |
| 2014-11-14 | Priority Date for ’368 Patent |
| 2016-12-06 | ’368 Patent Issue Date |
| 2023-12-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,107,608 - System And Method For Providing Routing, Mapping, And Relative Position Information to Users of A Communication Network
- Patent Identification: U.S. Patent No. 8,107,608, titled “System And Method For Providing Routing, Mapping, And Relative Position Information to Users of A Communication Network,” issued on January 31, 2012.
The Invention Explained
- Problem Addressed: The patent describes prior art navigation systems as reliant on static, locally-stored data (e.g., on CD-ROMs) that quickly becomes outdated and requires users to manually register device network addresses, making them "incapable of obtaining position information over dynamically-configured connections" (Compl. ¶¶20-21; ’608 Patent, col. 2:17-43).
- The Patented Solution: The invention proposes a networked system that overcomes these limitations by using an "online database and/or networked authentication and authorization connection server" to provide real-time position, mapping, and routing information between different users on a communication network (’608 Patent, col. 4:3-14). This allows for dynamic, ad-hoc sharing of location data without pre-configured, static databases on the user device.
- Technical Importance: The technology enabled a shift from static, self-contained navigation to dynamic, interconnected location-based services between devices on a network (Compl. ¶23).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶44).
- Claim 1 is a method claim with the following essential elements:
- Receiving device and phone number information for a first user device.
- Receiving device and phone number information for a second user device.
- Receiving real-time location information for the first user device.
- Accessing a "privacy setting" on the first user device that indicates a "duration of time" for which location transmission is permitted.
- Determining if the current time is within that duration.
- If it is, transmitting the first user's location information to the second user device.
- The complaint reserves the right to assert additional claims during the litigation (Compl. ¶44).
U.S. Patent No. 8,509,412 - System and Method For Providing Routing, Mapping, And Relative Position Information to Users of A Communication Network
- Patent Identification: U.S. Patent No. 8,509,412, titled “System and Method For Providing Routing, Mapping, And Relative Position Information to Users of A Communication Network,” issued on August 13, 2013.
The Invention Explained
- Problem Addressed: As a continuation of the ’608 patent, the ’412 Patent addresses the same problems of static, outdated local data and the inability of prior systems to share position information over dynamic connections (Compl. ¶¶30-31; ’412 Patent, col. 2:23-49).
- The Patented Solution: The invention describes a similar networked system for real-time position sharing. The specification further details that the position information provided can include "address information, GPS position information, and nearby fixed location information" to overcome the drawbacks of prior art (’412 Patent, col. 3:52-57).
- Technical Importance: The invention provides a method for providing "real-time position information of one party to another party," facilitating modern location-aware applications (Compl. ¶33).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶55).
- Claim 1 is a method claim with the following essential elements:
- Receiving first phone number information for a first wireless user device.
- Receiving second phone number information for a second wireless user device.
- Receiving real-time location information for the first wireless user device.
- Transmitting "call-related information," which includes the first device's position information, to the second wireless user device.
- The complaint reserves the right to assert additional claims (Compl. ¶55).
U.S. Patent No. 9,514,368 - Contextual Information of Visual Media
- Patent Identification: U.S. Patent No. 9,514,368, titled “Contextual Information of Visual Media,” issued on December 6, 2016.
- Technology Synopsis: The patent addresses the challenge of interpreting the "continuous cacophony of information" from the "multi-directional exchange" of digital media (Compl. ¶38). The patented solution is a system that extracts information from visual media (e.g., text from an image), queries external information sources to obtain "extrapolated information" based on the extracted data, and then generates a "contextual document" combining the visual media with the new information to enhance a viewer's understanding (Compl. ¶40; ’368 Patent, col. 2:57-3:5).
- Asserted Claims: The complaint asserts independent claim 16, which is a system claim (Compl. ¶64).
- Accused Features: The complaint alleges that Samsung’s “Bixby Vision” feature infringes the ’368 Patent. This feature is alleged to recognize objects in images from the device's camera and provide related contextual information, such as shopping links or landmark names (Compl. ¶65).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are a wide range of Samsung Galaxy smartphones, including the Galaxy S, Note, A, Z, F, and M series, which are alleged to incorporate infringing functionality (Compl. ¶¶43, 54, 63).
Functionality and Market Context
- The complaint focuses on two core functionalities. The first is the "Emergency SOS" or "Emergency sharing" feature, which allows a user to send an alert message containing their real-time location, photos, and an audio clip to designated emergency contacts (Compl. ¶¶45, 51). Figure 1-3 in the complaint depicts a message received by an emergency contact, showing a map link with the user's location (Compl. p. 12).
- The second functionality is "Bixby Vision," described as an artificial intelligence assistant that can analyze visual media from the phone's camera to recognize objects, text, and images, and then provide related information such as translations, shopping results, or landmark details (Compl. ¶65). Figure 3-2 shows Bixby Vision analyzing a champagne bottle label (Compl. p. 34).
- The complaint lists dozens of popular smartphone models as accused products, suggesting their widespread commercial availability and importance in the market.
IV. Analysis of Infringement Allegations
'608 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of providing position information of a first user to a second user of a telecommunication network. | The accused products provide an "Emergency SOS" function that enables a user to share their location with other users on a network. | ¶45 | col. 4:3-14 |
| receiving first user device information including at least one of a first user device identification information and a phone number... | Samsung's Privacy Policy states it obtains device information (e.g., IMEI, serial number) and contact information (e.g., phone number) from the user and their device. | ¶46 | col. 11:13-24 |
| receiving second user information including at least one of a second user device identification information and a phone number... | The accused products allow a user to add and edit emergency contacts, which include the contact's name and telephone number. Figure 1-6 shows the interface for selecting contacts (Compl. p. 15). | ¶47 | col. 4:4-12 |
| receiving first user device position information indicating a real-time location of said first user device. | Samsung's Privacy Policy states that it obtains the "precise geolocation" of the user's device, and the Emergency SOS app accesses this information with user consent. | ¶48 | col. 10:18-21 |
| accessing first user privacy information indicating a privacy setting...indicating a duration of time during which permission is given... | The Emergency SOS app has a default sharing duration of 24 hours, which the user can stop earlier. This is presented as a "privacy setting" that defines a duration. Figure 1-4 shows the permissions screen for the SOS feature (Compl. p. 13). | ¶49 | col. 5:3-6 |
| determining whether a current time is within the duration of time indicated by said privacy setting... | The app is alleged to determine whether the current time is within the 24-hour duration, as it ceases transmission after that period. | ¶50 | col. 13:49-54 |
| if said current time is within said duration of time indicated by the privacy setting, transmitting said first user device position information... | If sharing is active, the Emergency SOS app transmits the user's location information to the designated emergency contacts. Figure 1-10 shows a depiction of the message being received, containing location information (Compl. p. 19). | ¶51 | col. 10:46-51 |
'412 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of providing position information of a first wireless user device to a second wireless user device of a communication network. | The accused wireless devices include an "Emergency SOS" function allowing a user to share their location with other users. | ¶56 | col. 4:3-14 |
| receiving first wireless user device information including first phone number information associated with a first wireless user device; | Samsung's Privacy Policy states it obtains the user's phone number and other device and contact information. | ¶57 | col. 11:13-24 |
| receiving second user information including second phone number information associated with a second wireless user device. | The accused products allow a user to designate an emergency contact, which includes the second user's phone number. | ¶58 | col. 4:4-12 |
| receiving first wireless user device position information indicating a real-time location of said first wireless user device. | The Emergency SOS feature accesses the device's precise geolocation with user consent, as disclosed in Samsung's Privacy Policy. | ¶59 | col. 3:52-57 |
| transmitting call-related information including said first wireless user device position information to said second wireless user device. | The Emergency SOS app sends a message to emergency contacts that includes the user's location information. The complaint alleges this message constitutes "call-related information." | ¶60 | col. 9:55-10:2 |
Identified Points of Contention
- Scope Questions: A central question for the ’412 Patent will be whether an SMS-based "SOS message" constitutes "call-related information" as required by claim 1. The patent specification frequently discusses voice telephone "calls," which may provide a basis for arguing a narrower scope that does not cover text or data messages. For the ’608 Patent, a question is whether a default 24-hour sharing period that a user can terminate, but not pre-configure, meets the limitation of a "privacy setting... indicating a duration of time."
- Technical Questions: The patent specifications for both the ’608 and ’412 patents describe a system architecture centered on an "online database and application server" that correlates data and facilitates information transfer. A key technical question will be whether Samsung's accused system, which appears to utilize device-native functions like GPS and SMS to transmit data directly between end-user devices, operates in the manner claimed by the patents or if there is a fundamental architectural mismatch.
V. Key Claim Terms for Construction
For U.S. Patent No. 8,107,608
- The Term: "privacy setting... indicating a duration of time" (Claim 1)
- Context and Importance: The infringement allegation for this element relies on the Emergency SOS feature's default 24-hour sharing period (Compl. ¶49). The viability of the infringement claim will depend on whether this default behavior, which a user can interrupt but not pre-set, is construed as the claimed "privacy setting."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the "period setting can be set for the duration of the call or for a predetermined length of time" (’608 Patent, col. 5:4-6). Plaintiff may argue that a 24-hour default is a "predetermined length of time" and thus falls within the scope.
- Evidence for a Narrower Interpretation: The context of "privacy settings" throughout the specification often implies active user configuration to "prevent or limit other calling devices from obtaining position information" (’608 Patent, col. 5:30-32). A defendant may argue this requires a user-configurable setting, not a fixed default.
For U.S. Patent No. 8,509,412
- The Term: "call-related information" (Claim 1)
- Context and Importance: The complaint alleges that the SOS message containing location data satisfies this limitation (Compl. ¶60). The dispute will likely center on whether an SMS/data message is "call-related" or if the term is limited to information associated with a traditional voice or video call.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent is set in the broad context of a "telecommunication network" and providing information to "users of a communication network" (’412 Patent, Title, Abstract). This could support an interpretation where any communication, including a data message, is "call-related."
- Evidence for a Narrower Interpretation: The detailed description repeatedly uses the term "telephone call" in the context of landline and mobile voice connections (e.g., '412 Patent, col. 9:22-26, col. 10:36-39). This may support a narrower construction limited to information ancillary to a voice communication event.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Samsung knowingly and intentionally encouraged infringement by providing instructions and advertisements on its publicly available websites that explain how to use the accused "Emergency SOS" and "Bixby Vision" features in an infringing manner (Compl. ¶¶71-74).
Willful Infringement
Willfulness is alleged based on Samsung’s purported knowledge of the patents. The complaint claims, "upon information and belief," that Samsung was aware of the patents-in-suit prior to the lawsuit and made no effort to cease infringement or seek a license. It further alleges knowledge from the date of service of the complaint (Compl. ¶71).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: Can the term "call-related information" in the ’412 patent, which is described in a specification focused on telephone calls, be construed to cover an SMS-based SOS data message? Similarly, does a default, non-configurable 24-hour sharing period in the ’608 patent constitute a "privacy setting... indicating a duration of time"?
A key technical question will be one of architectural congruence: Do Samsung's accused features, which appear to leverage standard operating system services (GPS, SMS) for peer-to-peer data sharing, practice the methods claimed in the ’608 and ’412 patents, which describe an architecture centered on an "online database and application server" to mediate the exchange of position information?
Regarding the ’368 patent, the central question will be one of functional mapping: Does the Bixby Vision feature—which identifies an object and links to external web content—perform the functions of the claimed system, specifically the generation of a "contextual document" based on "extrapolated information," or is there a material difference in the technical operations performed?