DCT

6:25-cv-00596

Golden v. Samsung Electronics America Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00596, W.D. Tex., 12/22/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Samsung maintains a "regular and established place of business" in Austin, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, smartwatches, CPUs, and operating systems infringe four patents related to mobile communication devices capable of detecting chemical, biological, radiological, nuclear, and explosive (CBRNE-H) threats.
  • Technical Context: The technology concerns the integration of sensor networks with consumer electronics, such as smartphones and smartwatches, to create systems for remote threat detection and control.
  • Key Procedural History: The complaint extensively references prior litigation involving the same patent family against Samsung and Google. Plaintiff acknowledges that previous court rulings determined the accused devices required "modification" to infringe, but argues in this action that Samsung itself performs the necessary modifications pre-sale by designing and integrating its CPUs, cameras, operating systems, and smartwatches to function as a CBRNE-H sensing device. The complaint also references a prior inter partes review (IPR) proceeding, IPR2014-00714, which resulted in a construction for the claim term "built-in, embedded" that Plaintiff relies upon to support infringement allegations.

Case Timeline

Date Event
2006-04-05 Earliest Patent Priority Date ('287, '619, '439, '189 Patents)
2007-10-30 DHS "Cell-All" initiative published
2010-06-01 Samsung Galaxy S launched
2011-09-01 "Cell-All" Demonstrations held in Los Angeles
2014-04-11 Samsung Galaxy S5 launched with fingerprint scanner
2015-08-04 U.S. Patent No. 9,096,189 Issued
2015-10-01 IPR Final Written Decision in IPR2014-00714
2017-03-07 U.S. Patent No. 9,589,439 Issued
2018-12-25 U.S. Patent No. 10,163,287 Issued
2021-04-20 U.S. Patent No. 10,984,619 Issued
2025-12-22 Complaint Filing Date

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

U.S. Patent No. 10,163,287 - *"Multi Sensor Detection, Stall to Stop and Lock Disabling System"*

  • Patent Identification: U.S. Patent No. 10,163,287, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued December 25, 2018 (’287 Patent).

The Invention Explained

  • Problem Addressed: The patent background describes the persistent threat of terrorist activity and the need for security systems that can control access to and monitor assets like shipping containers, vehicles, and lockers to prevent unauthorized entry or the placement of hazardous materials (’287 Patent, col. 2:1-21).
  • The Patented Solution: The invention proposes a modular security system comprising a detector case holding interchangeable sensors for chemical, biological, and radiological agents. This case can be placed on a monitored product and is configured to transmit detection information to a remote monitoring terminal, which can then send a signal to a lock disabler to secure the product and prevent access (’287 Patent, Abstract; Fig. 1). The system architecture integrates detection, communication, and remote-control capabilities.
  • Technical Importance: This technological approach sought to create a networked security system using common communication protocols to monitor assets remotely and enable active, automated intervention upon threat detection, moving beyond simple alarms. (Compl. ¶ 12).

Key Claims at a Glance

The complaint asserts independent claims 4 and 5 (Compl. ¶ 53).

  • Independent Claim 4 Elements (A communication device):
    • At least one central processing unit (CPU).
    • At least one internet or Wi-Fi connection.
    • At least one Bluetooth, cellular, or satellite connection.
    • At least one or more detectors for chemical, biological, radiological, or explosive agents.
    • At least one transmitter or transceiver configured to send signals, enabling the device to communicate, monitor, detect, and control.
  • Independent Claim 5 Elements (A monitoring device):
    • A CPU, various sensors (temperature, motion), a viewing screen, and multiple communication connections (GPS, Wi-Fi, Bluetooth, cellular).
    • A locking mechanism configured to engage, disengage, or disable the device.
    • A biometric sensor for authentication.
    • One or more detectors for chemical, biological, radiological, or explosive agents.
    • A radio-frequency near-field communication (NFC) connection.
    • A transmitter or transceiver configured to send signals for monitoring and control (e.g., locking doors, controlling vehicles).

U.S. Patent No. 10,984,619 - *"Multi Sensor Detection, Stall to Stop, and Lock Disabling System"*

  • Patent Identification: U.S. Patent No. 10,984,619, "Multi Sensor Detection, Stall to Stop, and Lock Disabling System," issued April 20, 2021 (’619 Patent).

The Invention Explained

  • Problem Addressed: The patent addresses the need for anti-terrorist detection and prevention systems that combine a lock-disabling mechanism with a chemical/biological/radiological detection system for a variety of products (’619 Patent, col. 1:55-62).
  • The Patented Solution: The invention is a communication device, such as a smartphone, PC, or laptop, containing a CPU that is capable of processing a range of instructions. These instructions include scanning sensors via NFC, monitoring for chemical, biological, or radiological agents (including weapons of mass destruction), and receiving data through various wireless protocols like Bluetooth, Wi-Fi, and GPS (’619 Patent, Abstract; col. 15:50-67). The solution centralizes the intelligence of a distributed sensor system into a general-purpose computing device.
  • Technical Importance: This technology represents a shift from relying on dedicated, purpose-built detector hardware to leveraging the processing power, connectivity, and ubiquity of consumer devices like smartphones to serve as the command-and-control hub for a sensor network. (Compl. ¶¶ 12-13, 20).

Key Claims at a Glance

The complaint asserts independent claims 1 and 11 (Compl. ¶ 55). The complaint also reserves the right to assert dependent claims 2-10 and 12-20 (Compl. ¶ 55).

  • Independent Claim 1 Elements (A communication device... PC, cellphone, smartphone...):
    • A central processing unit (CPU) capable of:
    • Processing instructions to scan a sensor or tag using NFC.
    • Processing instructions to monitor or detect various sensors (chemical, biological, motion, biometric, etc.).
    • Processing instructions to monitor or detect for WMDs.
    • Processing instructions received via Bluetooth, Wi-Fi, satellite, GPS, or cellular transmission.
  • Independent Claim 11 Elements (A central processing unit):
    • This claim is directed to the CPU itself, reciting the same functional capabilities as the "capable of" limitations in claim 1.

U.S. Patent No. 9,589,439 - *"Multi Sensor Detection, Stall to Stop and Lock Disabling System"*

  • Patent Identification: U.S. Patent No. 9,589,439, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued March 7, 2017 (’439 Patent).
  • Technology Synopsis: This patent discloses a multi-sensor detection system comprising a plurality of sensors for detecting agents (e.g., explosive, chemical, biological), monitoring equipment such as a computer or smartphone, and various communication links (e.g., satellite, Bluetooth, WiFi, cellular) for signal transmission between the system components (’439 Patent, Abstract). The invention focuses on the combination of sensors, a monitoring device, and the communication pathways between them.
  • Asserted Claims: Independent claims 19 and 23 (Compl. ¶ 56).
  • Accused Features: The complaint alleges infringement by Samsung's "modified" cell phones with megapixel cameras, Galaxy Watches, and operating systems, which are alleged to collectively form the claimed detection system (Compl. ¶¶ 56-58).

U.S. Patent No. 9,096,189 - *"Multi Sensor Detection, Stall to Stop and Lock Disabling System"*

  • Patent Identification: U.S. Patent No. 9,096,189, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued August 4, 2015 (’189 Patent).
  • Technology Synopsis: This patent claims a communication device (e.g., cell phone, PDA) that is interconnected to another product for monitoring. The system comprises a CPU, a transmitter, and a receiver, all configured to communicate over a wide range of wireless and wired protocols to form a multi-sensor detection and control network (’189 Patent, Abstract).
  • Asserted Claims: Independent claims 1 and 7 (Compl. ¶ 59).
  • Accused Features: The complaint accuses Samsung's "modified" cell phones, megapixel cameras, Galaxy Watches, and the Android and Tizen operating systems of infringement (Compl. ¶¶ 59-61).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Samsung's electronic devices and the software they run, including Samsung Exynos CPUs, Samsung Galaxy Smartphones (e.g., Galaxy S24/S25 and Z Fold series), Samsung Galaxy Watches, Samsung Megapixel Cameras, Samsung Android Operating Systems with the One UI skin, and the Tizen Operating System for watches (Compl. ¶¶ 2, 53-60).

Functionality and Market Context

The complaint alleges that Samsung "modifies" these standard consumer products into an infringing CBRNE-H detection system. The accused functionality is described as a system where:

  • The Exynos CPU is the "brains" of the device, modified to execute instructions for CBRNE-H detection (Compl. ¶ 20).
  • The Android/One UI and Tizen operating systems act as the "transceiver," managing the hardware and providing the necessary communication links (cellular, Wi-Fi, NFC, Bluetooth) (Compl. ¶¶ 26, 28).
  • The built-in megapixel cameras are alleged to function as "internal" CBRNE-H sensors, capable of performing functions such as reading QR codes on CBRNE equipment, optical biosensing, and radiation detection (Compl. ¶¶ 30-32). An infographic in the complaint alleges that smartphone cameras can be incorporated with CBR sensors (Compl. p. 44, panel 6).
  • Galaxy Watches are alleged to function as "external" detectors, containing sensors for physiological monitoring (e.g., heart rate) and location tracking that can be integrated with software like the Android Tactical Assault Kit (ATAK) ecosystem to provide data relevant to CBRN sensing (Compl. ¶¶ 33-35). A visual in the complaint alleges a "Homeland Security's Smartwatch Will Detect Nuclear Bombs" (Compl. p. 45, panel 6).

IV. Analysis of Infringement Allegations

The complaint does not contain traditional claim charts but provides narrative infringement theories and visual aids that map asserted claim elements to accused functionalities (Compl. ¶ p. 4; pp. 44-45). The following tables summarize these allegations for the lead patents.

’287 Patent Infringement Allegations

Claim Element (from Independent Claim 5) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one central processing unit (CPU) Samsung's Exynos CPUs, described as the "brains" of the mobile device. ¶20; p. 44 col. 17:51-52
at least one global positioning system (GPS) connection in communication with the at least one CPU Samsung phones utilize a combination of GPS, Wi-Fi, and cellular network data to establish location. ¶39 col. 18:1-3
at least one of a Bluetooth connection, a cellular connection, or a satellite connection... The Samsung Android operating system provides and manages these communication connections. ¶28; p. 44 col. 18:6-9
at least one locking mechanism... configured to... disable (make unavailable) the communication device Security features such as "Find My Mobile" or the automatic lockout after multiple failed login attempts. ¶39 col. 18:10-14
at least one biometric sensor... for providing biometric authentication The fingerprint scanner and facial recognition features included in Samsung Galaxy phones. ¶39 col. 18:18-21
one or more detectors... for detecting at least one of chemical, biological, radiological, or explosive agents The phone’s built-in camera (as an "internal sensor") and the connected Galaxy Watch (as an "external detector"). ¶¶30-35; pp. 44-45 col. 18:25-28
at least one radio-frequency near-field communication (NFC) connection... The NFC hardware and software included in Samsung phones for short-range communication. ¶40 col. 18:29-31

’619 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a central processing unit (CPU), capable of: processing instructions to scan a senor or tag using... NFC Samsung's CPU executing instructions for the phone's built-in NFC reader/writer. ¶¶20, 40 col. 15:53-56
processing instructions to monitor or detect at least one of a chemical sensor, a biological sensor, a motion sensor... The CPU processing data from the phone's camera and connected smartwatch, which are alleged to function as sensors. ¶¶30-35 col. 15:57-60
processing instructions to monitor or detect for at least one of chemical agent, biological agent... WMDs The CPU processing data from the camera and watch for the alleged purpose of detecting CBRNE-H agents. ¶¶30-35 col. 15:61-64
processing instructions received through at least one of a Bluetooth, a Wi-Fi, a satellite, a global positioning system (GPS), or a cellular transmission The CPU executing instructions received via the various wireless radios managed by the Android operating system. ¶28; p. 44 col. 15:65-67
  • Identified Points of Contention:
    • Definitional Question: A primary point of contention may be whether a general-purpose smartphone camera or a consumer smartwatch with biometric sensors can meet the claim limitation of a "detector" for "chemical, biological, radiological, or explosive agents." The complaint alleges these components are "modified" for this purpose, but the factual basis for this specific functionality, as opposed to general capability, may be scrutinized.
    • The "Modification" Threshold: The central dispute appears to be the legal and factual definition of "modification." Plaintiff alleges that Samsung's internal development of its Exynos CPUs, One UI software, and integration of its own cameras and watches constitutes the "modification" that prior courts deemed necessary for infringement (Compl. ¶ 3). Samsung may argue that these are ordinary product improvements and that infringement still requires the addition of specialized, third-party software or hardware not sold by Samsung, consistent with prior court rulings cited in the complaint (Compl. ¶ 11).

V. Key Claim Terms for Construction

  • The Term: "detector... for detecting at least one of a chemical, biological, radiological, or explosive agents" (’287 Patent, Claim 5)

  • Context and Importance: The viability of Plaintiff’s infringement theory may depend on construing this term broadly enough to read on a general-purpose camera or a smartwatch's biometric sensors. Practitioners may focus on this term because the complaint's theory hinges on recasting these common hardware components as specialized CBRNE-H detectors.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent claims "one or more detectors" without specifying their structure, suggesting functional language may control (’287 Patent, col. 18:25-28). The complaint argues that if a camera can be used to analyze a biosensor or a watch can detect physiological responses to an agent, they are functioning as detectors within the system (Compl. ¶¶ 31-35).
    • Evidence for a Narrower Interpretation: The abstract describes detectors that "sample for chemical, biological and radiological compounds, agents and elements," which may imply a device performing direct chemical or physical sampling (’287 Patent, Abstract). The specification also depicts detectors as distinct, interchangeable hardware modules (Fig. 1, item 46), which could support a narrower construction limited to purpose-built sensing hardware rather than repurposed consumer electronics components.

  • The Term: "built in, embedded" (referenced from IPR2014-00714)

  • Context and Importance: Plaintiff heavily relies on the PTAB's construction of this term—"something is included within, incorporated into, disposed within, affixed to, connected to, or mounted to another device, such that it is an integral part of the device"—to argue that Samsung’s cameras and CPUs are infringing components of the phone, and that the smartwatch is an infringing component of the overall system (Compl. ¶ 43, 63).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation (supporting Plaintiff's use of the IPR construction): The patent describes detector cases that are "mounted in or upon the crates and containers" (’287 Patent, col. 5:33-35). The "connected to" language from the PTAB construction could be argued to cover a smartwatch paired via Bluetooth, as it becomes an "integral part" of the combined phone-watch detection system alleged in the complaint (Compl. ¶ 43).
    • Evidence for a Narrower Interpretation: A defendant might argue that "integral part of the device" requires a level of integration beyond a standard Bluetooth pairing, especially if the components do not function as a cohesive system for the patented purpose without third-party software. The specification's focus on a dedicated "detector case" could suggest that the "built in, embedded" components must be part of a specifically configured security apparatus, not just present in a general-purpose consumer device.

VI. Other Allegations

  • Indirect Infringement: The complaint makes passing reference to inducement and contributory infringement (Compl. ¶ 6). It alleges Samsung gained the requisite knowledge for such claims from a notice issued by the U.S. Court of Federal Claims in a prior case, Golden v. United States (CFC Case No. 13-307C) (Compl. ¶ 19).
  • Willful Infringement: Willfulness is explicitly alleged (Compl. p. 1). The complaint bases this allegation on Samsung's alleged knowledge of the patents-in-suit from extensive prior litigation history involving the same patent family, including cases before district courts and the U.S. Court of Appeals for the Federal Circuit (Compl. ¶¶ 7-11).

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

  • A core issue will be one of definitional scope: can standard consumer hardware, such as a smartphone’s megapixel camera or a smartwatch’s biometric sensors, be construed to meet the claim requirement of a "detector" for "chemical, biological, radiological, or explosive agents," or does this term require a purpose-built sensing element that performs direct physical or chemical analysis?
  • A central legal and factual question will be the threshold for "modification": does Samsung’s internal design process—developing its own CPUs, software (One UI), and integrated hardware (cameras, watches)—constitute the "modification" that prior courts found necessary for infringement, or is an additional, post-sale action by a user or third party still required to assemble the complete, claimed invention?
  • An underlying evidentiary question will be one of functional performance: what factual support can be presented to demonstrate that the accused Samsung products, as sold, actually perform the specific function of detecting CBRNE-H threats, as opposed to merely possessing a general capability that could be leveraged by external software or hardware to do so?