DCT

1:19-cv-00903

Neodron Ltd v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-00903, W.D. Tex., 11/17/2020
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants are registered to do business in Texas and maintain regular and established places of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphone, tablet, and notebook products infringe seven patents related to foundational aspects of touchscreen technology, including touch ambiguity resolution, power management, signal processing, force detection, and physical sensor layout.
  • Technical Context: The asserted patents address various technical challenges inherent in modern capacitive touchscreens, which are the primary user interface for a vast range of consumer electronic devices.
  • Key Procedural History: The operative pleading is a Second Amended Complaint, indicating the case has undergone prior amendments to the pleadings. The complaint does not mention any prior litigation, licensing history, or administrative patent challenges such as inter partes review proceedings.

Case Timeline

Date Event
2002-07-12 ’286 Patent Priority Date
2005-07-08 ’502 Patent Priority Date
2006-10-20 ’547 Patent Priority Date
2008-10-22 ’009 Patent Priority Date
2010-10-26 ’502 Patent Issue Date
2010-12-02 ’747 Patent Priority Date
2011-09-07 ’898 Patent Priority Date
2011-11-22 ’106 Patent Priority Date
2012-01-24 ’286 Patent Issue Date
2013-08-06 ’547 Patent Issue Date
2013-12-17 ’009 Patent Issue Date
2014-09-30 ’898 Patent Issue Date
2018-05-08 ’106 Patent Issue Date
2019-07-30 ’747 Patent Issue Date
2020-11-17 Second Amended Complaint Filing Date

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

U.S. Patent No. 8,102,286 - "Capacitive Keyboard with Non-Locking Reduced Keying Ambiguity"

  • Issued: January 24, 2012 (Compl. ¶14)

The Invention Explained

  • Problem Addressed: The patent addresses the problem of "keying ambiguity" in capacitive keyboards with tightly packed keys, where a user’s finger may overlap multiple keys simultaneously, making it difficult to determine the single intended key press (’286 Patent, col. 1:35-42).
  • The Patented Solution: The invention describes an iterative method where the system measures the signal strength from each key, identifies the one with the maximum signal as the user-selected key, and maintains that selection. However, unlike systems that might "lock" onto the first key pressed, this selection can be superseded if another key's signal strength subsequently exceeds the currently selected key's signal, allowing for a smooth "rollover" as a user's finger moves across the keypad (’286 Patent, Abstract; col. 3:5-14).
  • Technical Importance: This "non-locking" approach to ambiguity resolution was designed to improve the usability of small-form-factor keyboards by more accurately interpreting user intent, particularly on mobile devices where finger placement may be less precise.

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-24 (Compl. ¶15).
  • Independent Claim 1 of the ’286 Patent includes the following essential elements:
    • A key panel comprising a plurality of keys
    • Control logic coupled to the keys
    • The control logic is configured to detect a sensor value of an inactive key surpassing a sensor value of an active key by a select amount
    • And assigning the inactive key as the active key
    • Wherein the key assignment is biased in favor of the currently active key by increasing sensor values of the currently active key

U.S. Patent No. 8,610,009 - "Capacitive Touch Sensors"

  • Issued: December 17, 2013 (Compl. ¶22)

The Invention Explained

  • Problem Addressed: The patent background notes that as the size and number of sensing nodes in a touch sensor array increase, the time required to acquire a signal from every node also increases, which can negatively impact responsiveness and requires more powerful, costly microcontrollers (’009 Patent, col. 1:60-67).
  • The Patented Solution: The invention proposes a two-stage scanning method. First, it performs a full scan of all sensing nodes to detect the initial presence and location of a touch. Once a touch is located, the system switches to a more efficient mode, performing subsequent scans on only a "subset" of the nodes—specifically those at and immediately adjacent to the last known touch location—to track movement. The system reverts to a full scan if the touch is no longer detected (’009 Patent, Abstract; col. 2:9-19).
  • Technical Importance: This "partial frame" acquisition method allows for faster touch tracking, reduced data processing, and lower power consumption, which is particularly beneficial for the larger touchscreens on modern smartphones and tablets.

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-17 (Compl. ¶23).
  • Independent Claim 1 of the ’009 Patent includes the following essential method steps:
    • Acquiring, in a first sampling period, a touch data set with signals from all of a plurality of sensing nodes in a capacitive sensor array
    • Determining presence and location of a touch on the array from that data set
    • Acquiring, in subsequent sampling periods while the touch is present, subsequent touch data sets from less than all of the plurality of sensing nodes
    • The subsequent data sets are received from nodes located at the touch location and from nodes adjacent to the touch location

U.S. Patent No. 8,847,898 - "Signal-to-Noise Ratio in Touch Sensors"

  • Issued: September 30, 2014 (Compl. ¶30)
  • Technology Synopsis: This patent addresses the problem of electrical noise interfering with touch detection. The proposed solution is to improve the signal-to-noise ratio (SNR) by driving multiple drive lines of the touch sensor simultaneously with electrical pulses, rather than driving only one line at a time. This increases the total signal strength relative to the background noise level, thereby improving measurement accuracy (’898 Patent, Abstract; col. 6:45-54).
  • Asserted Claims: Claims 1-24 (Compl. ¶31).
  • Accused Features: The complaint alleges that the touchscreens in products like the Samsung Notebook 9 Pro 15 infringe this patent (Compl. ¶31).

U.S. Patent No. 8,502,547 - "Capacitive Sensor"

  • Issued: August 6, 2013 (Compl. ¶38)
  • Technology Synopsis: This patent describes a method for a capacitive sensor to operate in two distinct modes to adjust a parameter. In a first "coarse" mode, a user's initial touch on a sensor path (e.g., a virtual dial) selects an approximate value from a wide range. In a second "fine" mode, subsequent sliding movement adjusts the value with greater precision, potentially from a narrower "zoomed-in" range. The mode switch can be triggered by the duration of the touch or the displacement of the finger (’547 Patent, Abstract; col. 4:1-12).
  • Asserted Claims: Claims 1-17 (Compl. ¶39).
  • Accused Features: The complaint accuses numerous Samsung Galaxy smartphones, such as the Galaxy S9+, of infringing this patent (Compl. ¶39).

U.S. Patent No. 7,821,502 - "Two-Dimensional Position Sensor"

  • Issued: October 26, 2010 (Compl. ¶46)
  • Technology Synopsis: This patent describes a structural innovation for a capacitive touch sensor that enables the row and column electrodes to be placed on a single surface of a substrate. This is achieved by using "wrap-around connections" made outside of the primary sensing area to connect segments of row electrodes, thereby eliminating the need for a second electrode layer and the associated manufacturing complexity of routing crossing conductors (’502 Patent, Abstract; col. 2:57-61).
  • Asserted Claims: Claims 1-24 (Compl. ¶47).
  • Accused Features: The complaint accuses numerous Samsung Galaxy smartphones, such as the Galaxy S9, of infringing this patent (Compl. ¶47).

U.S. Patent No. 10,365,747 - "Touch-Sensing Panel and Force Detection"

  • Issued: July 30, 2019 (Compl. ¶54)
  • Technology Synopsis: This patent discloses a touch sensor that integrates force detection with standard position sensing. The invention combines a capacitive touch-sensing panel with a "resistive force sensitive element," which changes its electrical resistance in relation to applied force. This allows a controller to measure both the location of a touch and the amount of pressure being applied (’747 Patent, Abstract; col. 4:8-14).
  • Asserted Claims: Claims 1-21 (Compl. ¶55).
  • Accused Features: The complaint accuses several Samsung Galaxy smartphones, including the Galaxy S9, of infringing this patent (Compl. ¶55).

U.S. Patent No. 9,965,106 - "Touch Screen with Electrodes Positioned Between Pixels"

  • Issued: May 8, 2018 (Compl. ¶62)
  • Technology Synopsis: This patent addresses optical performance in touch-enabled displays by proposing a specific physical layout for the touch sensor's electrodes. The invention teaches aligning the conductive electrodes of the touch sensor with the non-light-emitting gaps that exist between the pixels of the display panel. This arrangement is intended to minimize obstruction of light from the pixels, thereby improving image quality, brightness, and clarity (’106 Patent, Abstract).
  • Asserted Claims: Claims 1-22 (Compl. ¶63).
  • Accused Features: The complaint accuses numerous Samsung Galaxy smartphones, such as the Galaxy S10, of infringing this patent (Compl. ¶63).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a broad range of Samsung consumer electronics as the "Accused Products," including the Samsung Galaxy Tab S4 10.5, Samsung Notebook 9 Pro 15, Samsung Galaxy Tab A 10.5, and numerous models in the Samsung Galaxy S and Galaxy Note smartphone lines (Compl. ¶¶15, 23, 31, 39, 47, 55, 63).

Functionality and Market Context

  • The accused instrumentalities are electronic devices that utilize capacitive touchscreens as a primary method for user input and interaction (Compl. ¶2). The complaint does not provide detailed technical specifications of the accused products' internal operations. It alleges that these products are commercially significant and incorporate the patented touchscreen improvements to enhance user experience and functionality (Compl. ¶5).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products satisfy all limitations of the asserted claims for each patent-in-suit but refers to claim chart exhibits, which were not provided with the complaint document, for a detailed element-by-element analysis (Compl. ¶¶17, 25, 33, 41, 49, 57, 65). The following summaries are based on the asserted claims and the general allegations of infringement.

No probative visual evidence provided in complaint.

U.S. Patent No. 8,102,286 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a plurality of keys The accused products' on-screen displays feature virtual keyboards with multiple capacitive keys. ¶15 col. 4:45-50
control logic... configured to detect a sensor value of an inactive key surpassing a sensor value of an active key by a select amount and assigning the inactive key as the active key The products' operating system and touch controller logic are alleged to analyze the capacitive signal strength from multiple keys under a user's finger and select the key with the strongest signal as the intended input. ¶¶15, 17 col. 2:9-14
wherein the key assignment is biased in favor of the currently active key by increasing sensor values of the currently active key The products' software is alleged to incorporate logic that prevents unintended, rapid switching between adjacent keys when a touch is ambiguous, effectively favoring the currently selected key to ensure stable input. ¶¶15, 17 col. 5:44-50
  • Identified Points of Contention:
    • Scope Questions: A central question may be the construction of the term "biased in favor of the currently active key." The dispute could focus on whether the accused products' methods for preventing input "chatter" or resolving ambiguity meet the specific definition of "bias" claimed in the patent.
    • Technical Questions: Evidentiary questions may arise regarding the specific algorithm the accused products use to select a key when a touch covers multiple key areas. The analysis will question whether this algorithm performs the iterative signal comparison and assignment process required by the claim.

U.S. Patent No. 8,610,009 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
acquiring, in a first sampling period, a touch data set with signals from all of a plurality of sensing nodes in a capacitive sensor array The accused products' touch controllers are alleged to perform an initial, full-panel scan of all sensor nodes to detect the presence of a new touch event. ¶¶23, 25 col. 12:1-4
determining presence and location of a touch on the capacitive sensor array from the touch data set The controllers are alleged to process the data from the full scan to identify the coordinates of the initial touch. ¶¶23, 25 col. 12:5-7
acquiring... subsequent touch data sets from less than all of the plurality of sensing nodes... located at the location of the touch and from sensing nodes that are located adjacent to the location of the touch After initial touch detection, the controllers are alleged to enter an efficient tracking mode, where they scan only a localized subset of sensor nodes around the last known touch position to reduce power consumption and processing load. ¶¶23, 25 col. 12:8-15
  • Identified Points of Contention:
    • Scope Questions: The interpretation of "less than all of the plurality of sensing nodes" will be critical. The dispute may examine whether any power-saving or performance-optimization modes in the accused products meet this specific structural and functional limitation.
    • Technical Questions: A key factual question will be whether the accused devices' touch controllers actually cease acquiring signals from certain nodes during touch tracking, as claimed, or if they employ alternative power-saving techniques, such as reducing the scan rate for the entire panel.

V. Key Claim Terms for Construction

For the ’286 Patent:

  • The Term: "biased in favor of the currently active key"
  • Context and Importance: This term is central to defining the patent's specific "non-locking" method for ambiguity resolution. The outcome of the infringement analysis for the ’286 Patent may depend heavily on whether the accused devices' key-selection algorithms fall within the scope of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary suggests the invention provides a method that "permits the smooth rollover of key selection as a finger slides from one key to the next, while still reducing key ambiguity" (’286 Patent, col. 3:5-9). This could support a construction covering a range of anti-chatter or hysteresis techniques.
    • Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment where dominance is gained only if a new key's signal exceeds the active key's signal "by a small added amount 'k'" (’286 Patent, col. 8:8-12). This may support a narrower construction requiring a specific algorithmic comparison with an offset.

For the ’009 Patent:

  • The Term: "acquiring... subsequent touch data sets from less than all of the plurality of sensing nodes"
  • Context and Importance: This phrase defines the core "partial frame" scanning feature of the invention. Proving infringement requires showing that the accused devices perform this specific action of selectively ignoring certain nodes after an initial touch.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The summary broadly states that touch data sets "may be limited to a subset of the sensing nodes when presence of a touch is detected" (’009 Patent, col. 2:15-18), which could suggest any form of reduced-node scanning is covered.
    • Evidence for a Narrower Interpretation: An embodiment describes a specific implementation where, if a touch is detected at X-line "X2," the controller "may only drive the X2 line and the immediately adjacent X lines, namely X1 and X3" (’009 Patent, col. 8:30-37). This could be used to argue for a narrower construction limited to scanning only the touch-proximate region.

VI. Other Allegations

  • Indirect Infringement: For each of the seven asserted patents, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The allegations are based on Defendants allegedly having knowledge of the patents (at least from the filing of the complaint) and actively encouraging infringement by providing user manuals and online instructions that guide end-users to operate the accused products in an infringing manner (e.g., Compl. ¶¶16, 24, 32, 40, 48, 56, 64).
  • Willful Infringement: The complaint does not use the term "willful," but alleges that Defendants act "knowingly and intentionally" (e.g., Compl. ¶16). The basis for knowledge is tied to the "filing and service of this Complaint," suggesting the allegations are primarily directed at post-suit conduct. The prayer for relief requests a finding that this is an "exceptional case" under 35 U.S.C. § 285, which may entitle the plaintiff to attorneys' fees (Compl. p. 16, ¶e).

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

This case presents a broad challenge to core aspects of the accused touchscreen products. The litigation will likely center on the following key questions:

  • A central issue will be one of algorithmic correspondence: For the software-driven patents (e.g., ’286, ’009, ’547), does the code and logic within Samsung's touch controllers and operating systems perform the specific, multi-step methods required by the claims, or do they employ alternative, non-infringing algorithms to solve similar technical problems like key ambiguity and power management?
  • A key evidentiary question will be one of operational implementation: For the hardware- and structure-focused patents (e.g., ’502, ’106, ’898, ’747), do the physical layouts and operational modes of the accused touch sensors—such as their electrode placement relative to pixels, single-layer construction, or simultaneous driving of multiple lines—actually map onto the specific structures and functions claimed in the patents?
  • A significant strategic question will be one of portfolio focus: Given the assertion of seven patents covering disparate technologies, the case may turn on whether a few key claims from one or two patents emerge as the primary battleground, or if the dispute will require a parallel analysis of multiple distinct technologies, potentially creating complex claim construction and discovery challenges for the court and the parties.