DCT

7:25-cv-00537

Faunus IP Holdings LLC v. LG Electronics Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00537, W.D. Tex., 11/19/2025
  • Venue Allegations: Plaintiff alleges venue is proper for LG Electronics, Inc. as a foreign corporation and for LG Electronics U.S.A., Inc. based on its alleged commission of infringing acts and maintenance of regular and established places of business, including service repair locations, within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless earbuds infringe two patents related to personalized audio adjustment based on user hearing profiles and multi-sensor noise reduction for enhancing speech clarity.
  • Technical Context: The technologies at issue concern advanced audio processing in personal listening devices, aiming to customize the listening experience and improve functionality in noisy environments, which are key features in the competitive consumer electronics market.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patents-in-suit.

Case Timeline

Date Event
2010-07-27 U.S. Patent No. 9,172,345 Priority Date
2011-09-19 U.S. Patent No. 10,347,232 Priority Date
2015-10-27 U.S. Patent No. 9,172,345 Issued
2019-07-09 U.S. Patent No. 10,347,232 Issued
2025-11-19 Complaint Filed

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

U.S. Patent No. 9,172,345 - “Personalized adjustment of an audio device”

  • Patent Identification: U.S. Patent No. 9,172,345, entitled “Personalized adjustment of an audio device,” issued October 27, 2015.

The Invention Explained

  • Problem Addressed: The patent’s background section states that different individuals have unique hearing sensitivities that are not adequately addressed by conventional audio devices with standard equalizers or volume controls, which can introduce distortion without improving clarity for sounds a user cannot perceive (’345 Patent, col. 1:26-61).
  • The Patented Solution: The invention describes a system where a user engages in a “tuning mode” to establish a personal “minimum perceptible level” of hearing across various audio frequency bands. This personalized profile is then stored and used by the device to automatically monitor environmental noise and adjust the signal level in each frequency band, ensuring the audio remains perceptible to that specific user regardless of the listening environment (’345 Patent, col. 2:15-33).
  • Technical Importance: This technology represents a shift from generic audio enhancement to a user-specific approach, aiming to create a listening experience customized to an individual's unique auditory profile (Compl. ¶14).

Key Claims at a Glance

The complaint asserts infringement of at least independent claim 1 (Compl. ¶21, 25). The essential elements of claim 1 include:

  • A memory configured to store "tuning data" from a user-specific tuning process and "other tuning data" not associated with the user (e.g., a predetermined default profile).
  • A processor configured to:
    • select an audio signal from a plurality of signals based on speech data;
    • repeatedly monitor the level of environmental noise;
    • adjust the selected audio signal if the noise exceeds a threshold;
    • wherein the adjustment is performed according to a plurality of filter bands and is based on both the user-specific "tuning data" and the "other tuning data".

U.S. Patent No. 10,347,232 - “Multi-sensor signal optimization for speech communication”

  • Patent Identification: U.S. Patent No. 10,347,232, entitled “Multi-sensor signal optimization for speech communication,” issued July 9, 2019.

The Invention Explained

  • Problem Addressed: The patent’s background section explains that conventional speech processing systems, particularly those using directional microphones, are “extremely susceptible to environmental noise such as wind noise,” which can degrade performance and render the devices unusable (’232 Patent, col. 1:48-54).
  • The Patented Solution: The invention proposes a multi-sensor system where an audio processing component receives sound information from multiple acoustic sensors. It uses this information with a spatial filter (e.g., a beamformer) to generate a filtered audio stream. The system then determines the noise levels for the original, unfiltered streams as well as the filtered stream, and generates a final output by selecting the optimal stream or creating a weighted combination of them (’232 Patent, col. 2:25-39; FIG. 6).
  • Technical Importance: The invention provides an adaptive method for improving speech clarity by dynamically evaluating and selecting the optimal audio signal from multiple available sources, which may offer an improvement over static filtering techniques (Compl. ¶18).

Key Claims at a Glance

The complaint asserts infringement of at least independent claim 1 (Compl. ¶30, 33). The essential elements of claim 1 include:

  • A sensor component with acoustic sensors that generate "respective sound information" corresponding to "respective microphones".
  • An audio processing component configured to:
    • generate "filtered sound information" based on the "respective sound information" and a "spatial filter";
    • generate "output sound information" based on a determination of "respective noise levels" for both the "respective sound information" (unfiltered) and the "filtered sound information".

III. The Accused Instrumentality

Product Identification

The complaint identifies the LG T90S Wireless Earbuds and other "substantially similar products" as the accused instrumentalities (Compl. ¶20, ¶29).

Functionality and Market Context

The complaint alleges these products are "earbuds and hearing devices" that incorporate technologies for personalized audio and noise reduction (Compl. ¶10). The complaint alleges these products perform the functions described in the patents-in-suit but does not provide specific technical details about their operation. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references but does not attach exemplary claim charts for its infringement allegations (Compl. ¶21, ¶30). The narrative infringement theory is summarized below.

  • '345 Patent Infringement Allegations: The complaint alleges that the '345 Accused Products, including the LG T90S Wireless Earbuds, infringe at least claim 1 of the ’345 Patent by implementing a system for personalized audio adjustment (Compl. ¶14, ¶20). The narrative suggests these products enable users to establish a personalized hearing profile that is then used to dynamically adjust audio output in response to changing environmental noise (Compl. ¶14).
  • '232 Patent Infringement Allegations: The complaint alleges that the '232 Accused Products infringe at least claim 1 of the ’232 Patent by employing a multi-sensor architecture to improve speech clarity (Compl. ¶18, ¶29). The alleged infringement is based on the products processing audio signals from multiple sensor sources, using filtering techniques, and generating a superior output by evaluating and selecting or combining the audio streams (Compl. ¶18).
  • Identified Points of Contention:
    • Evidentiary Questions ('345 Patent): A central question may be evidentiary: What specific functionality in the accused products constitutes the claimed "tuning process" for establishing a user-specific "defined hearing level"? The dispute may focus on whether the accused products actually store and use both user-specific "tuning data" and generic "other tuning data" to perform the claimed audio adjustments.
    • Technical Questions ('232 Patent): A key technical question may be whether the accused products' audio processing architecture performs the specific function recited in claim 1. The analysis could turn on whether the system makes a "determination of respective noise levels for the respective sound information and the filtered sound information"—that is, for both the raw microphone inputs and the beamformed output—and then uses that comparative determination to generate the final audio output.

V. Key Claim Terms for Construction

U.S. Patent No. 9,172,345 (Claim 1)

  • The Term: "tuning data associated with a tuning process for a user identity"
  • Context and Importance: This term is central to defining the personalization aspect of the invention. Its construction will determine the required level of sophistication for the user customization feature, which could distinguish it from conventional equalizer presets.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a user "personally adjust[ing] a volume of the tone on the man machine interface until the user can clearly perceive the tone," which could be argued to encompass a range of user-driven audio customization settings (’345 Patent, col. 2:42-46).
    • Evidence for a Narrower Interpretation: The patent also describes this process as repeating for "all of the available frequency bands to match the audio device to the hearing sensitivity of the user," which may suggest a comprehensive, multi-band hearing assessment rather than a simple adjustment (’345 Patent, col. 2:48-50).

U.S. Patent No. 10,347,232 (Claim 1)

  • The Term: "based on a determination of respective noise levels for the respective sound information and the filtered sound information"
  • Context and Importance: This phrase is critical as it appears to require a specific analytical step within the noise reduction process. Infringement may depend on whether the accused system performs this explicit, multi-part evaluation or uses a different, more integrated algorithm.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes generating output "based on a selection of one of the noise levels or a weighted combination," which could support an interpretation where any algorithm that considers various noise characteristics meets this limitation (’232 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The detailed description and figures, such as FIG. 6, depict a system where distinct noise levels are estimated for multiple, separately processed signals before a final output is computed. This may support an argument that discrete noise level calculations for both the raw and filtered streams are required (’232 Patent, FIG. 6).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of both patents, asserting that Defendant encourages infringement by providing the accused products with "instructions, manuals, advertisements, [and] marketing materials" that instruct on the use of the allegedly infringing features (Compl. ¶22, ¶31).
  • Willful Infringement: The complaint alleges knowledge of infringement "as of the filing and service of the Complaint," which provides a basis for post-suit willful infringement (Compl. ¶22, ¶31).

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

  • Definitional Scope: A core issue for the '345 Patent will be one of definitional scope: does the functionality in the accused products constitute a "tuning process" that generates user-specific "tuning data" as contemplated by the patent, or does it fall into the category of conventional user-adjustable settings?
  • Algorithmic Specificity: A key question for the '232 Patent will be one of algorithmic operation: does the accused noise reduction system perform the specific claimed step of determining and comparing noise levels from both raw and spatially filtered audio streams before generating an output, or is there a fundamental mismatch in its technical architecture?
  • Evidentiary Basis: For both asserted patents, the case will likely depend on evidence obtained during discovery that reveals the precise software and hardware implementation of the accused audio processing features in the LG products.