DCT

6:23-cv-00523

DoDots Licensing Solutions LLC v. Best Buy Stores LP

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00535, W.D. Tex., 09/12/2022
  • Venue Allegations: Venue is alleged against Samsung Electronics Co., Ltd. as a foreign corporation. Venue is alleged against Samsung Electronics America, Inc. based on its regular and established places of business in the district and alleged acts of infringement within the district. Venue is alleged against the Best Buy entities based on their regular and established places of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile devices (e.g., Galaxy series phones and tablets) and associated software (e.g., customized Android OS and app stores) infringe patents related to methods for accessing, displaying, and authoring network content outside of a traditional web browser.
  • Technical Context: The technology relates to "widgets" or standalone applications that retrieve and display internet content in configurable frames, a precursor to the modern mobile app ecosystem.
  • Key Procedural History: The complaint notes that all three patents-in-suit survived validity challenges in inter partes review (IPR) proceedings before the Patent Trial and Appeal Board (PTAB), with the PTAB’s decisions finding the challenged claims not unpatentable affirmed by the U.S. Court of Appeals for the Federal Circuit. This procedural history may influence claim construction and validity arguments in the present litigation.

Case Timeline

Date Event
2000-04-26 Earliest Priority Date for ’545, ’083, and ’407 Patents
2011-04-20 Samsung allegedly aware of the patents-in-suit
2011-09-13 U.S. Patent No. 8,020,083 issues
2013-08-13 U.S. Patent No. 8,510,407 issues
2016-06-14 U.S. Patent No. 9,369,545 issues
2020-09-09 PTAB finds claims of the ’545 Patent not shown to be unpatentable
2021-01-05 PTAB finds claims of the ’407 Patent not shown to be unpatentable
2021-01-19 PTAB finds claims of the ’083 Patent not shown to be unpatentable
2021-12-08 Federal Circuit affirms PTAB decisions for all patents-in-suit
2022-09-12 Complaint Filed

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

U.S. Patent No. 9,369,545 - Accessing and Displaying Network Content (Issued June 14, 2016)

The Invention Explained

  • Problem Addressed: The patent’s background describes a “growing desire for individual users to fully control the aggregation and presentation of content and web applications that appears on a client computer,” distinct from the conventional method of viewing content aggregated by a server within a full-page web browser (Compl. ¶29; ’545 Patent, col. 1:48-54).
  • The Patented Solution: The invention provides a method for a client device to request a “networked information monitor template” from a server. This template defines a graphical user interface (GUI) and references a network location for content. The client device can then present this GUI and its content “separate from and outside of any other graphical user interface” like a traditional web browser, giving content providers more control over the user experience (’545 Patent, Abstract; col. 4:56-60). This process is illustrated in the client-server communication flow of FIG. 11 (’545 Patent, FIG. 11).
  • Technical Importance: This approach provided a framework for delivering lightweight, standalone content modules, or "widgets," an alternative to the monolithic web browser experience prevalent at the time of the invention (Compl. ¶32, 36).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶64, 117).
  • Independent Claim 1 of the ’545 Patent includes the essential elements of:
    • A computer-implemented method on a client device.
    • Transmitting a request for a "networked information monitor template" to a server.
    • Receiving the template, which comprises a definition of a viewer GUI and a definition of a first content element referencing a network location.
    • Presenting the viewer GUI separate from and outside of any other GUI that includes user controls for specifying the network location.
    • Transmitting a content request to that network location.
    • Receiving the first content element.
    • Presenting the received content element in the viewer GUI.
  • The complaint notes assertion of claims 1-2, 9-10, and 12-13 (Compl. ¶117).

U.S. Patent No. 8,020,083 - System and Methods for Creating and Authoring Internet Content Using Application Media Packages (Issued September 13, 2011)

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of web browsers, where content is "trapped within the frame of the browser" and developers have limited control over the user experience (’083 Patent, col. 2:28-32).
  • The Patented Solution: The patent describes a client device storing "networked information monitor templates" that define self-contained graphical user interfaces. A key aspect of this solution is that the GUI definition "lacks controls for manually navigating a network" and includes a frame with defined characteristics (e.g., color, size, position) for displaying content received from a specified network location via TCP/IP protocol (’083 Patent, col. 47:53-61). The system architecture distinguishes between a "Dot Server" for definitions and a "Content Server" for the data that populates the "Dot" (a term for the monitor) (’083 Patent, FIG. 6).
  • Technical Importance: This technology provided a system for creating and deploying portable, browser-independent applications or "Dots" that could be authored and presented with a consistent, developer-defined look and feel (Compl. ¶32).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶83, 126).
  • Independent Claim 1 of the ’083 Patent includes the essential elements of:
    • A client device comprising electronic storage, a display, and one or more processors.
    • The electronic storage having a "networked information monitor template" stored on it.
    • The template comprises a content reference (a network location accessible via TCP/IP).
    • The template also comprises a GUI definition that "lacks controls for manually navigating a network" and includes a frame with defined characteristics (color, size, or position).
    • The template includes instructions to request content from the network location and generate the GUI with the received content inside the frame.
    • Processors are configured to access the template to present the GUI and content on the display.
  • The complaint notes assertion of at least claim 1 (Compl. ¶126).

U.S. Patent No. 8,510,407 - Displaying Time-Varying Internet Based Data Using Application Media (Issued August 13, 2013)

Technology Synopsis

This patent is directed to a client computing device configured to display time-varying content (e.g., stock prices) within the frame of a browser-independent "networked information monitor." The invention focuses on the process of the device transmitting a content request and then receiving and presenting the time-varying content, again in a GUI that "lacks controls for enabling a user to specify a network location" (’407 Patent, col. 42:52-60; Compl. ¶96).

Asserted Claims

At least independent claim 1 is asserted (Compl. ¶96, 133).

Accused Features

The accused features are Samsung devices that execute applications, such as stock tracking apps, which display time-varying data (e.g., stock prices) within a standalone application interface, separate from a general-purpose web browser (Compl. ¶98-101).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Accused Samsung Devices," which include various models of the Galaxy Z, S, Note, A, and M series mobile phones and Galaxy Tab series tablets, along with the "Accused Samsung Software" that runs on them (Compl. ¶58). This software includes Samsung's customized Android operating system ("the Samsung OS") and pre-installed or updated applications such as the Play Store and Galaxy App Store (Compl. ¶59).

Functionality and Market Context

The complaint alleges that the Accused Samsung Software is specifically designed to cause the Accused Samsung Devices to download applications ("Samsung-Supported Apps") from an app store (Compl. ¶60). It alleges that the devices transmit a request for an application package (e.g., an APK file) and receive it in response, and that this package contains the information needed to present the app's GUI and retrieve content for display (Compl. ¶69-71). The complaint provides an image showing various Galaxy S series phones to illustrate the product line at issue (Compl. ¶66, p. 18).

IV. Analysis of Infringement Allegations

’545 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
transmitting a request to the server over the network, the request requesting networked information monitor template; The Accused Samsung Software sends a request to an App Store for an application package (APK file), which is alleged to be the "networked information monitor template." ¶69 col. 6:3-5
receiving the requested networked information monitor template from the server over the internet, the...template comprising: a definition of a viewer graphical user interface...and a definition of a first content element...referencing a first network location... The device receives the APK file, which is alleged to contain data structures defining the app's GUI (e.g., using XML or JSON files) and referencing a network location (e.g., a URL) from which content (e.g., stock price data) is served. ¶70-75 col. 6:6-15
presenting the viewer graphical user interface defined by the networked information monitor on the display of the client computing device separate from and outside of any other graphical user interface that includes user controls for specifying the first network location... The Accused Samsung Software presents the app's GUI (e.g., a stock widget) on the device's display. This presentation is alleged to be separate from a traditional web browser that would have controls (like an address bar) for a user to specify the network location of the content. ¶76-77 col. 6:16-25
transmitting over the network a first content request to the first network location referenced by the definition of the first content element... The software, executing instructions from the APK file, transmits a request to the network location (e.g., a server for market data) to obtain the content. A screenshot shows a Samsung-supported app pulling information for a specific stock watch list (Compl. ¶78, p. 23). ¶78 col. 6:26-31
  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether a modern mobile application package (APK file) constitutes a "networked information monitor template" as that term is used in the patent. The defense may argue that an executable application file is fundamentally different from the "template" described in the patent, which appears to be a data structure interpreted by a separate client parser application.
    • Technical Questions: What evidence does the complaint provide that the presentation of the app is truly "separate from and outside" of any interface with controls for specifying a network location? The functionality of modern mobile operating systems, which manage all application windows, may raise questions about whether any app is truly presented "outside of any other graphical user interface."

’083 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
electronic storage having stored thereon a plurality of networked information monitor templates defining a plurality of networked information monitors... The Accused Samsung Devices have electronic storage (e.g., flash memory) that stores multiple downloaded applications ("Samsung-Supported Apps"), which are alleged to be the "networked information monitor templates." A provided image shows a teardown of a Galaxy S21 with its flash storage highlighted (Compl. ¶85, p. 27). ¶85-86 col. 47:43-48
a content reference that comprises a network location at which content for the first networked information is accessible via a TCP/IP protocol; The application's data structures (in the APK file) are alleged to contain a content reference (e.g., a URL) that points to a network location from which data (e.g., stock prices) is pulled using the internet's TCP/IP protocol. ¶87 col. 47:49-52
a definition of a graphical user interface...that lacks controls for manually navigating a network, and that includes a frame within which content received from the network location can be displayed, and frame characteristics defining one or more color, a size, or a position... The APK file's data structures are alleged to define the app's GUI, which is presented as a standalone application without traditional browser navigation controls (like an address bar or back/forward buttons). The complaint alleges the app's resources define its visual presentation, including its frame characteristics. A screenshot shows a stock app displaying market data within its own frame (Compl. ¶88, p. 29). ¶88-89 col. 47:53-61
instructions configured (i) to cause the first networked information monitor to request content from the network location...and (ii) to cause the...monitor to generate the graphical user interface...with the content received...within the frame; The application's code (the alleged "instructions" in the template) causes the device to request data (e.g., stock prices) from the server and to render that data within the app's GUI frame. ¶90-92 col. 47:62-67
  • Identified Points of Contention:
    • Scope Questions: The negative limitation "lacks controls for manually navigating a network" will likely be a key point of dispute. Defendants may argue that many modern apps include embedded web views or hyperlinks that effectively provide controls for network navigation, even if they lack a traditional address bar.
    • Technical Questions: How does the complaint demonstrate that the template (the APK file) itself includes instructions that "generate the graphical user interface"? The defense may contend that the underlying operating system, not the application package alone, is primarily responsible for generating the GUI framework in which the application's content is displayed.

V. Key Claim Terms for Construction

’545 Patent: "networked information monitor template"

  • The Term: "networked information monitor template"
  • Context and Importance: This term is the central object requested, received, and interpreted by the claimed method. Whether a modern mobile application package (e.g., an APK file) falls within the scope of this term will be critical to the infringement analysis. Practitioners may focus on this term because the patent describes it in the context of a "client parser application" interpreting a data structure, which may differ from how a modern OS installs and executes a compiled APK.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the template as defining "fully configurable frame characteristics, viewer and control characteristics, and NIM content references," which could be argued to generically describe the resource files and manifest within an APK file (’545 Patent, col. 6:49-52).
    • Evidence for a Narrower Interpretation: The patent consistently discusses the template in the context of being processed by a "client parser application" (’545 Patent, col. 5:36-39) and being composed of elements like an XML script (col. 8:21-27), suggesting a data file to be interpreted, rather than a self-contained, compiled executable application.

’083 Patent: "lacks controls for manually navigating a network"

  • The Term: "lacks controls for manually navigating a network"
  • Context and Importance: This negative limitation is used to distinguish the invention from a traditional web browser. The viability of the infringement claim depends on whether the accused apps, which may include hyperlinks or embedded web views, are found to possess such controls.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (i.e., finding fewer things "lack controls"): The patent does not explicitly define "manually navigating a network." A party could argue that any user-initiated action that causes the app to display content from a new network location (e.g., tapping a link) constitutes manual navigation.
    • Evidence for a Narrower Interpretation (i.e., finding more things "lack controls"): The patent’s background distinguishes the invention from browsers with features that allow a user to "view multiple web pages" (’083 Patent, col. 1:53-54). This context suggests "controls for manually navigating" refers to browser-specific tools like an address bar, back/forward buttons, and bookmarks, which are absent in many standalone apps.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement, stating that Samsung manufactured, promoted, and sold the Accused Devices with the intent to cause its customers to use them in an infringing manner (Compl. ¶112). The basis for this allegation includes Samsung's encouragement for users to use apps from its Galaxy Store and selling devices with pre-downloaded apps (Compl. ¶112).
  • Willful Infringement: The complaint alleges willful infringement based on Samsung's purported pre-suit knowledge of the patents-in-suit since at least April 20, 2011, citing an attached email as evidence (Compl. ¶54-56, 113; Ex. 8).

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

  • A core issue will be one of definitional scope: can the term "networked information monitor template," rooted in the technological context of the early 2000s web and describing a data structure interpreted by a parser, be construed to cover modern, compiled mobile application packages (APKs) that are installed and executed by a device's operating system?
  • A key infringement question will be one of negative limitation: do the accused standalone applications, which may contain hyperlinks or embedded web views, functionally possess "controls for manually navigating a network" as understood in the patent, or does this limitation refer more narrowly to the specific controls (e.g., an address bar) of a traditional web browser that the invention sought to replace?
  • A third key aspect will be the impact of prior adjudications: how will the patents' survival of PTAB validity challenges, and the Federal Circuit's affirmation, influence claim construction arguments, discovery focus, and potential settlement leverage in this litigation?