ProudLion IP LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ProudLion IP, LLC (Texas)
  • Defendant: Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Ramey, LLP
• Case Identification: 1:23-cv-00620, W.D. Tex., 06/01/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts substantial business in the district, has committed alleged acts of infringement there, and maintains a regular and established place of business in Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy Smartwatch infringes a patent related to methods for selectively altering the appearance and operational mode of a portable computing device.
• Technical Context: The technology at issue concerns user-configurable "skins" or modes for portable electronics, allowing users to adjust settings like screen brightness, fonts, and notification types to suit different environments.
• Key Procedural History: A Certificate of Correction was issued for the patent-in-suit on May 21, 2019, which replaced an erroneous abstract describing network data routing with a corrected abstract describing personalized device appearance. This correction significantly clarifies the subject matter of the invention.

Case Timeline

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

U.S. Patent No. 9,967,389 - "System And Method For Selectable Alteration Of Operation And Appearance Of A Portable Computing Device"

The Invention Explained

• Problem Addressed: The patent describes how the use of portable computing devices can be "obtrusive" in certain situations, such as a "darkened environment" or where "silence is expected," due to screen lighting and other factors (’389 Patent, col. 1:39-42). It further identifies a need for users to personalize device profiles for specific requirements without needing network connectivity or an external prompt (’389 Patent, col. 1:50-55).
• The Patented Solution: The invention is an on-device software application that allows a user to create a custom operational mode or "skin" by simultaneously altering multiple device characteristics and aggregating notifications from various applications. Through a series of on-screen selections, a user can change the font, backlight level, and notification type (e.g., audio, haptic, silent) and can also group email, messaging, and social media applications into a single, user-prioritized view (’389 Patent, col. 1:26-40; col. 2:4-23). This altered mode can then be saved and implemented through distinct user actions on the device’s touchscreen.
• Technical Importance: The technology provides a method for granular, user-initiated customization of a device's user interface that is independent of pre-loaded profiles and does not require an active network connection for configuration.

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’389 Patent (Compl. ¶11). Independent claim 1 is central to the system allegations.
• Independent Claim 1 recites a system for altering a portable computing device’s operation and appearance, requiring the processor to be configured to perform steps including:
  • Receiving a first mode alteration request via a "first actuation object".
  • "Selectably aggregating" a plurality of email, messaging, and social network applications.
  • "Selectably altering" the backlight level, font, and "frequency mode" (e.g., audio vs. haptic).
  • Accepting alterations and aggregations via a "second actuation object".
  • Implementing the altered mode via a "third actuation object".
• The complaint reserves the right to assert other claims, which would likely include dependent claims that add further specificity to the elements of claim 1.

III. The Accused Instrumentality

Product Identification

• The "Samsung Galaxy Smartwatch" (Compl. ¶12).

Functionality and Market Context

• The complaint alleges that the Accused Instrumentality includes "systems and methods that selectably alter the operation and appearance of a portable computing device" (Compl. ¶11). However, the complaint does not provide specific details about the technical operation of the accused smartwatch features. The allegations are framed generally, without describing how the Samsung Galaxy Smartwatch specifically allows users to aggregate applications or alter device settings in a manner that corresponds to the patent's claims.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations is contained in a "preliminary table attached as Exhibit B" (Compl. ¶12). As this exhibit was not provided with the complaint filing, a detailed element-by-element analysis based on the complaint's direct allegations is not possible. No probative visual evidence provided in complaint.

In the absence of the claim chart, the infringement theory must be inferred from the general allegations. The plaintiff’s theory appears to be that the user interface on the Samsung Galaxy Smartwatch for customizing settings and notifications constitutes a system that practices the method of claim 1 of the ’389 patent.

• Identified Points of Contention:
  • Evidentiary Questions: The primary point of contention will be factual and evidentiary. The complaint lacks specific factual allegations tying the functionality of the Samsung Galaxy Smartwatch to the limitations of the asserted claims. The case may turn on whether discovery shows that the accused device performs the claimed steps of aggregating disparate application types (email, messaging, social media) and altering device characteristics (font, backlight, frequency) through a sequence of operations that maps to the claimed "first", "second", and "third" actuation objects.
  • Scope Questions: A likely area of dispute is the scope of the term "selectably aggregate." The court may need to determine if this requires creating a new, unified interface for the selected applications, as suggested by figures in the patent (’389 Patent, Fig. 3), or if it is met by standard operating system features that allow users to manage notifications from different apps within a general settings menu.
  • Technical Questions: A key technical question is whether the accused device’s UI customization process involves three distinct "actuation objects" as required by the claim structure. The infringement argument depends on mapping the user’s actions—such as opening a settings menu, making selections, and applying them—to this specific three-part sequence.

V. Key Claim Terms for Construction

• The Term: "actuation object" (first, second, and third)

  • Context and Importance: Claim 1 requires a sequence of three distinct "actuation objects" to request, accept, and implement the altered mode. The viability of the infringement claim hinges on whether the user interaction flow of the Samsung Galaxy Smartwatch can be mapped to this specific three-step framework. Practitioners may focus on this term because its definition will determine whether a standard settings menu (e.g., open menu -> change settings -> exit/save) meets the claim's structural requirements.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the "term 'object' should be generally understood as meaning content presented on a display," including "user-interface elements (e.g., launcher icons), clickable links," and other content (’389 Patent, col. 5:12-18). This could support reading the term broadly to cover any clickable UI element.
    • Evidence for a Narrower Interpretation: The patent’s figures and detailed description provide a specific example where the first object is an "app launcher 101," the second is a "Settings" button (110) that leads to a sub-menu, and the third is an "Apply" button (120) that implements the changes (’389 Patent, Fig. 1B; col. 4:56-59; col. 5:45-58). A party could argue these specific, sequential examples limit the term to a multi-step process involving distinct launch, configuration, and implementation commands.

• The Term: "selectably aggregate"

  • Context and Importance: Claim 1 requires the system to "selectably aggregate" pluralities of email, messaging, and social network applications. The definition of "aggregate" is central to determining whether the accused device infringes. The dispute will likely focus on whether this requires more than simply allowing notifications from different apps to appear in a list.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself could be interpreted broadly to mean simply gathering or compiling a list of applications to be included in a custom mode. The claim language does not explicitly require a unified display.
    • Evidence for a Narrower Interpretation: The specification describes a process that "can comprise displaying object(s) corresponding to each email application, each messaging system, and each social network application on the touch-screen display in a single screen with selectable order for each aggregated application" (’389 Patent, col. 5:30-37). Figure 3 further illustrates a single screen where different messaging apps are listed together and can be re-ordered, suggesting a function more advanced than a simple notification center.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others... on how to use its products and services" to infringe (Compl. ¶13). It does not, however, point to specific evidence such as user manuals or marketing materials that contain such instructions.
• Willful Infringement: The complaint pleads willfulness based on knowledge of the patent "from at least the filing date of the lawsuit" (Compl. ¶13, ¶14). The prayer for relief requests a finding of willfulness and treble damages, positioning the claim as one of post-filing willfulness (Compl. ¶V.e).

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

1. Pleading Sufficiency: A threshold procedural question is whether the complaint, which relies entirely on a non-proffered exhibit for its factual support of infringement, meets the plausibility standard required to survive a motion to dismiss.
2. Process Mapping: A core substantive issue will be one of claim scope and mapping: can the user interface flow for customizing the Samsung Galaxy Smartwatch be persuasively mapped onto the patent’s specific three-step structure defined by the "first", "second", and "third" "actuation objects," or is there a fundamental mismatch in the operational sequence?
3. Functional Equivalence: A key technical question will be whether the accused product’s features for managing applications and notifications perform "aggregation" as claimed—implying a function that unifies different application types into a single, configurable view—or if they are merely conventional OS-level settings that do not meet this specific claim limitation.