DCT
6:22-cv-00844
Omnitek Partners LLC v. Samsung Group
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Omnitek Partners, LLC (New York)
- Defendant: Samsung Electronics America, Inc. (New Jersey)
- Plaintiff’s Counsel: Capshaw DeRieux, LLP; SpencePC
- Case Identification: 6:22-cv-00844, W.D. Tex., 08/09/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a "regular and established place of business" in Austin, employs personnel in the district, and has committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy smartwatches infringe a patent related to using a device's casing as a communication bus for internal electronic components.
- Technical Context: The technology concerns methods for internal data communication within compact electronic devices, aiming to replace traditional, space-consuming, and fragile wiring with more integrated and robust solutions.
- Key Procedural History: The complaint alleges that Defendant had actual notice of the patent-in-suit and its alleged infringement as of April 29, 2020, a date more than two years prior to the filing of the complaint. This allegation forms the basis for the claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2003-08-12 | ’293 Patent Priority / Filing Date |
| 2007-09-18 | ’293 Patent Issue Date |
| 2020-04-29 | Alleged date of Defendant's pre-suit knowledge |
| 2022-08-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,272,293 - "Device having a casing and/or interior acting as a communication bus between electronic components"
- Patent Identification: U.S. Patent No. 7,272,293, "Device having a casing and/or interior acting as a communication bus between electronic components," issued September 18, 2007.
The Invention Explained
- Problem Addressed: The patent addresses disadvantages of conventional internal wiring used to connect electronic components within a device. This wiring is described as being susceptible to noise and brittleness, taking up significant internal space, and being prone to failure from impact or shock, particularly in harsh environments. (’293 Patent, col. 1:32-40).
- The Patented Solution: The invention proposes replacing traditional wiring with the device's casing itself, which is adapted to function as a communication bus. At least a portion of the casing is made to act as a waveguide (e.g., optical or ultrasonic) to transmit signals between the various electronic components housed inside. (’293 Patent, col. 1:47-51, Fig. 1). This integration of the communication bus into the device's structure is intended to save space, increase durability, and simplify manufacturing. (’293 Patent, col. 6:41-54).
- Technical Importance: By eliminating traditional wiring, the invention purports to enable the miniaturization of portable electronic devices or allow for more components to be housed in the same size casing, while also improving the device's robustness. (’293 Patent, col. 6:45-49).
Key Claims at a Glance
- The complaint asserts independent claims 1, 17, and 18, as well as dependent claim 2.
- Independent Claim 1 (Apparatus):
- A device (other than a projectile) comprising:
- a plurality of electronic/electrical components; and
- a casing with at least a portion acting as a communication bus;
- for transmitting a signal in a "point-to-many links manner" between the components;
- wherein the signal is available to each of the plurality of components on the bus.
- Independent Claim 17 (Apparatus):
- A device (other than a projectile) comprising:
- a casing holding a plurality of electronic/electrical components; and
- a communication bus formed at least in part by the casing;
- wherein the components are operatively connected to the bus in a "point-to-many links manner" and are capable of transmitting and detecting a signal on the bus;
- and the signal is available to each of the plurality of components.
- Independent Claim 18 (Method):
- A method of communicating a signal in a device (other than a projectile) comprising:
- providing the casing with at least a portion acting as a communication bus; and
- operatively connecting components to the bus such that a signal transmitted in a "point-to-many links manner" is available to each component.
III. The Accused Instrumentality
Product Identification
- The "Samsung Galaxy smartwatches" are identified as the Accused Instrumentalities. (Compl. ¶20).
Functionality and Market Context
- The complaint alleges that the Samsung Smartwatches contain a plurality of electronic components and a casing. (Compl. ¶23). The infringement theory is based on the allegation that these smartwatches use a portion of their casing as an "optical waveguide" to act as a communication bus between components. (Compl. ¶24). It is alleged that one component acts as a transmitter sending optical signals into this waveguide, while another component acts as a detector of those signals. (Compl. ¶24). The complaint does not specify which internal components or signals are at issue. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’293 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A device other than a projectile, the device comprising: a plurality of electronic/electrical components; | The Samsung Smartwatches are devices that "have a plurality of electronic/electrical components." | ¶23 | col. 1:47-48 |
| and a casing, the casing having at least a portion thereof acting as a communication bus | The Samsung Smartwatches have "a casing, the casing having at least a portion thereof acting as a communication bus." The complaint further alleges this portion is an "optical waveguide." | ¶23, ¶24 | col. 2:1-4 |
| for transmitting a signal in a point-to-many links manner between the plurality of electronic/electrical components, | The casing acts as a communication bus "for transmitting a signal in a point-to-many links manner between the plurality of electronic/electrical components." The complaint alleges one component is a transmitter and another is a detector. | ¶23, ¶24 | col. 1:18-21 |
| wherein the transmitted signal is available to each of the plurality of electronic/electrical components on the communication bus. | The complaint alleges "the transmitted signal is available to each of the plurality of electronic/electrical components on the communication bus." | ¶23 | col. 1:21-23 |
- Identified Points of Contention:
- Scope Questions: The case may turn on whether the internal communication architecture of the accused smartwatches can be properly characterized as a "communication bus" formed by the "casing" as those terms are used in the patent. A central question will be whether a component part identified by the Plaintiff, such as a light pipe for a sensor, constitutes a "portion" of the "casing" that functions as a "communication bus" for inter-component communication, or if it serves a more limited, dedicated function.
- Technical Questions: A key factual dispute will likely concern the "point-to-many links manner" limitation. The complaint asserts this functionality, but provides no detail on how the accused smartwatches achieve it. The court will need to examine whether the accused devices employ a broadcast-style bus where a signal is available to multiple components, or if they use a series of discrete, point-to-point connections that do not meet this claim limitation.
V. Key Claim Terms for Construction
The Term: "communication bus"
Context and Importance: The definition of this term is fundamental, as the core of the invention is the integration of the bus into the device casing. The Plaintiff's infringement theory depends on demonstrating that a feature of the accused smartwatches both constitutes a "communication bus" and is part of the "casing." Practitioners may focus on this term because its scope will determine whether the patent covers only general-purpose broadcast systems or could also read on more specialized data pathways.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification provides a broad definition, stating "a communication bus is anything that transmits one or more signals between two or more components." (’293 Patent, col. 1:15-17). This language could support an argument that any signal-carrying medium between components qualifies.
- Evidence for a Narrower Interpretation: The embodiments primarily describe the bus as an optical or ultrasonic waveguide that replaces the device's general internal wiring system. (’293 Patent, col. 2:1-4, col. 5:12-16). This could support a narrower construction limited to structures that provide a common, multi-node communication pathway, as opposed to dedicated, single-purpose light pipes or sensors.
The Term: "point-to-many links manner"
Context and Importance: This term specifies the topology of the communication. It appears in all asserted independent claims and requires that the signal be broadly available, not just sent from one specific point to another. Infringement will depend on a factual showing that the accused devices operate this way. Practitioners may focus on this term because modern system-on-a-chip (SoC) designs in smartwatches often use complex, switched fabrics and dedicated high-speed serial links, which may not align with the broadcast-style "point-to-many" architecture described in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent clarifies that the "transmission may be such that the transmitted signal(s) are available to any components on the communication bus." (’293 Patent, col. 1:21-23). This could be argued to cover any system where a signal could theoretically be tapped by multiple components, even if not explicitly designed for it.
- Evidence for a Narrower Interpretation: The phrasing implies a broadcast or multicast architecture where a single transmission is intended for, and available to, multiple potential recipients simultaneously. This could be contrasted with a series of point-to-point links, where a signal is directed to only one destination. The patent's goal of replacing general wiring suggests a more versatile, shared medium. (’293 Patent, col. 1:27-32).
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement. (Compl. ¶10). It does not, however, plead specific facts to support the required elements of knowledge and intent, such as citing user manuals or marketing materials that instruct or encourage infringing use.
- Willful Infringement: The claim for willful infringement is based on the allegation that Defendant had "actual notice of the ’293 Patent and the infringement alleged herein at least as early as April 29, 2020." (Compl. ¶27). The complaint alleges that all infringement after this date was willful. (Compl. ¶29).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the court’s determination of the following central questions:
- A core issue will be one of definitional scope and factual application: Can a specific feature within a Samsung smartwatch, potentially a light guide for a health sensor, be simultaneously construed as a "portion" of the device's structural "casing" and a "communication bus" used for general data transmission, as those terms are defined by the patent?
- A key evidentiary question will be one of technical operation: Does the internal communication architecture of the accused smartwatches function in the "point-to-many links manner" required by the claims, or does the complaint's allegation conflate a set of discrete, point-to-point data links with the patented broadcast-style bus architecture?