Connectquest LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ConnectQuest LLC (Connecticut)
  • Defendant: Samsung Electronics Co., Ltd (Republic of Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:26-cv-00037, E.D. Tex., 01/16/2026
• Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. because it allegedly committed acts of infringement and maintains a regular and established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy smartphones, equipped with features such as SmartThings Find, Quick Share, and Smart Switch, infringe eight patents related to systems for close-proximity wireless notifications and data exchange.
• Technical Context: The technology at issue involves using short-range wireless signals, such as Bluetooth, to enable location-aware notifications, device discovery, and data transfer between devices.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patents-in-suit. Seven of the eight asserted patents claim priority to the same August 15, 2011 provisional application.

Case Timeline

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

U.S. Patent No. 8,831,642 - "Close Proximity Notification System" (issued September 9, 2014)

The Invention Explained

• Problem Addressed: The patent describes existing internet-based marketing services like Groupon as "disconnected from the actual shopping experience" because they require a consumer to purchase a deal online, download a voucher, and later travel to the retailer, which is an "asynchronous" process (Compl. ¶9; ’642 Patent, col. 2:38-54).
• The Patented Solution: The invention proposes a system to deliver marketing information to a consumer in real time when they are physically near a business. A short-range wireless transmitter at a retail location broadcasts a unique identifier; a user's mobile device receives this identifier, processes it, and communicates with a remote server to retrieve and display relevant information, such as a coupon, coinciding with the consumer's presence at the location ’642 Patent, Abstract col. 6:11-24 FIG. 1
• Technical Importance: This approach was designed to make local advertising more immediate by targeting consumers in the direct vicinity of an establishment, with the goal of spurring "sales which otherwise might not have occurred" ’642 Patent, col. 2:12-16

Key Claims at a Glance

• The complaint asserts independent claims 1 and 13, and dependent claim 5 Compl. ¶25
• Claim 1 is a method claim comprising the essential elements of:
  • Receiving, on a mobile device, a signal from a short-range wireless transmitter at a geographic location, where the signal includes an identification code.
  • Processing the signal on the mobile device, which includes determining if associated information is stored locally and identifying a "retrieval location" for the information.
  • Performing this processing step "exclusively by a software application located on the mobile device and independently of any networks."
  • Retrieving the information from the retrieval location using the mobile device.
  • Displaying the information on the mobile device.
• Claim 13 adds the element of the mobile device comprising "a means for the user to take an action based on the information."

U.S. Patent No. 9,219,979 - "Beacon for Close Proximity Notification System" (issued December 22, 2015)

The Invention Explained

• Problem Addressed: The patent addresses the same challenge as the ’642 Patent: creating a more effective, real-time system for location-based advertising (’979 Patent, col. 1:40-62).
• The Patented Solution: This invention focuses on the operation of the "beacon" or transceiver itself. It describes a method where the transceiver discovers nearby mobile devices and initiates a brief communication to exchange data without requiring a full, user-approved pairing. The specification details a process where the transceiver sends a connection request, broadcasts its unique identifier, and then "immediately cancel[s] the connection" before a reply is needed, streamlining the interaction ’979 Patent, Abstract col. 14:70-74 FIG. 8
• Technical Importance: This "pairing-less" data exchange method was intended to create a seamless and less intrusive user experience for proximity-based notifications, as it avoids requiring the user to approve a connection request for each interaction ’979 Patent, col. 15:1-11

Key Claims at a Glance

• The complaint asserts independent claims 26, 27, 35, and 36 Compl. ¶32
• Claim 26 is a method claim performed at a transceiver, comprising the essential elements of:
  • Discovering wireless mobile devices within a proximity range.
  • Initiating communication with one or more of the discovered devices.
  • Exchanging data with the devices, where the exchange includes either receiving input data at the transceiver or transmitting output data from it.
  • The transmitted output data includes a "unique identifier associated with the transceiver."

U.S. Patent No. 9,219,981 - "Distributed Data in a Close Proximity Notification System" (issued December 22, 2015)

• Technology Synopsis: This patent, related to the ’979 Patent, claims a method performed by a transceiver. The method involves discovering a wireless mobile device, receiving a request for information from that device, and, in response, identifying a "retrieval location" for a subset of the requested information and transmitting either the information itself or an identifier for that location back to the mobile device (’981 Patent, Abstract).
• Asserted Claims: Independent claim 26 Compl. ¶39
• Accused Features: Samsung Galaxy smartphones with Samsung Quick Share or Samsung Smart Switch Compl. ¶39

U.S. Patent No. 9,628,949 - "Distributed Data in a Close Proximity Notification System" (issued April 18, 2017)

• Technology Synopsis: This patent claims a method performed by a transceiver for data exchange. The method includes discovering mobile devices, receiving a request for information from a device, identifying a retrieval location for at least a subset of the requested information, and transmitting that subset of information or an identifier for its retrieval location to the mobile device (’949 Patent, Abstract).
• Asserted Claims: Independent claim 19 Compl. ¶46
• Accused Features: Samsung Galaxy smartphones with Samsung Smart Switch or Samsung Quick Share Compl. ¶46

U.S. Patent No. 9,674,688 - "Close Proximity Notification System" (issued June 6, 2017)

• Technology Synopsis: This patent claims a method performed on a wireless communication device. The method involves receiving a signal from a short-range transceiver, processing the signal "exclusively by the wireless communication device and independently of any networks" to identify a retrieval location for associated information, and then retrieving that information for display (’688 Patent, cl. 1).
• Asserted Claims: Independent claims 1 and 14 Compl. ¶53
• Accused Features: Samsung Galaxy smartphones with SmartThings Find and/or Samsung Quick Share Compl. ¶53

U.S. Patent No. 9,693,190 - "Campus Security in a Close Proximity Notification System" (issued June 27, 2017)

• Technology Synopsis: This patent applies the core proximity-notification technology to a campus security environment. The claimed method involves a mobile device receiving a signal from a transmitter, processing it locally to determine a retrieval location for information, retrieving the information, monitoring for user inputs, and transmitting a security request to a security system in response to a specific input (’190 Patent, Abstract).
• Asserted Claims: Independent claim 14 Compl. ¶60
• Accused Features: Samsung Galaxy smartphones with SmartThings Find Compl. ¶60

U.S. Patent No. 9,743,229 - "System and Method for Facilitating Interpersonal Contacts and Social and Commercial Networking" (issued August 22, 2017)

• Technology Synopsis: This patent describes a social networking system where a server generates a "pre-qualifying list" of other users based on matching criteria. A user's mobile device is then notified via a short-range wireless protocol when another user from that list is detected in close proximity, enabling interpersonal contact (’229 Patent, Summary of the Invention).
• Asserted Claims: Independent claims 1, 10, 12, and 19 Compl. ¶67
• Accused Features: Samsung Galaxy smartphones with SmartThings Find Compl. ¶67

U.S. Patent No. 9,998,906 - "Close Proximity Notification System" (issued June 12, 2018)

• Technology Synopsis: This patent claims a method where a wireless communication device receives a signal from a short-range transceiver, processes the signal "exclusively by the wireless communication device and independently of any networks" to identify a retrieval location, and retrieves the information. The claims specify that one or both of the device and transceiver are located on a mobile object (’906 Patent, cl. 1).
• Asserted Claims: Independent claim 1 Compl. ¶72
• Accused Features: Samsung Galaxy smartphones with SmartThings Find Compl. ¶72

III. The Accused Instrumentality

Product Identification

• The complaint names Samsung Galaxy smartphones as the accused instrumentalities Compl. ¶¶25, 32, 39, 46, 53, 60, 67, 72

Functionality and Market Context

• The complaint targets specific software features on these smartphones:
  • Samsung SmartThings Find: This feature is accused of infringing patents related to receiving a signal and retrieving information, including in a campus security context and for social networking Compl. ¶¶25, 53, 60, 67, 72 This functionality allows users to locate their Samsung devices.
  • Samsung Quick Share and Samsung Smart Switch: These features are accused of infringing patents related to transceiver operations for discovering devices and exchanging data Compl. ¶¶32, 39, 46, 53 These are device-to-device data transfer and setup migration tools.
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates by reference preliminary claim charts (Exhibits I-T) that were not included in the provided filing Compl. ¶¶25, 32, 39, 46, 53, 60, 67, 72 The analysis is therefore based on the complaint's narrative allegations.

• Infringement Theory for the ’642 Patent: The complaint alleges that Samsung Galaxy smartphones using the SmartThings Find feature practice the method of claim 1 by receiving signals from nearby devices (acting as transmitters), processing those signals via an application on the phone to identify a retrieval location for information, and then retrieving and displaying that information Compl. ¶¶25-26
• Infringement Theory for the ’979 Patent: The complaint alleges that Samsung Galaxy smartphones, when using Quick Share or Smart Switch, function as the claimed "transceiver" by discovering other nearby devices, initiating communication, and exchanging data, thereby practicing the method of claim 26 Compl. ¶¶32-33
• Identified Points of Contention:
  • Scope Questions: A central dispute for the '979, '981, and '949 patents may be definitional. These patents claim methods for a "transceiver" or "beacon," often described in the context of a stationary device deployed by a merchant. The complaint's accusation that a general-purpose smartphone infringes these claims raises the question of whether a smartphone, when initiating a data transfer, can be construed as the claimed "transceiver."
  • Technical Questions: For the '642, '688, and '906 patents, a key technical question will concern the limitation requiring signal processing "exclusively by a software application... and independently of any networks." The infringement analysis may turn on evidence of whether the accused Samsung features perform this specific local-only logic to identify a retrieval location before any network communication occurs, or if they instead immediately pass a received identifier to a cloud server for all processing.

V. Key Claim Terms for Construction

• The Term: "transceiver" (from '979 Patent, Claim 26)

  • Context and Importance: The patents directed to beacon/transceiver operations ('979, '981, '949) are asserted against Samsung's smartphones. The definition of "transceiver" is therefore critical to determining if a multi-function smartphone can be the infringing device for claims written from the perspective of a dedicated beacon.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification notes that the location of the transceiver "may be static or mobile" ’979 Patent, col. 10:40-41 A smartphone is a mobile electronic device containing an "antenna, a processing device, and a memory device," which are the core components of the claimed transceiver ’979 Patent, cl. 1
    • Evidence for a Narrower Interpretation: The background and summary consistently frame the invention as a "beacon for [a] close proximity notification system" deployed by a retailer at a specific location to interact with a consumer's mobile device, suggesting a purpose-built device distinct from a general-purpose smartphone ’979 Patent, Abstract col. 5:55-61

• The Term: "processing the signal... exclusively by a software application located on the mobile device and independently of any networks" (from '642 Patent, Claim 1)

  • Context and Importance: This limitation appears in claims across three asserted patents ('642, '688, '906) and is central to defining the invention's architecture. Its construction will determine whether systems that offload the initial processing logic to a network server can infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language distinguishes this "processing" step from the subsequent "retrieving" step, which is not restricted from using a network. The specification's primary embodiment shows the mobile device contacting a remote application server after receiving the signal, which may suggest that only the initial decision-making logic must be network-independent ’642 Patent, col. 6:11-20
    • Evidence for a Narrower Interpretation: The term "exclusively" strongly suggests that no part of the "processing" step—which includes "determining" and "identifying"—can involve a network. A defendant may argue this requires the entire logic for locating the information to be completed on-device before any network call for retrieval is made.

VI. Other Allegations

• Indirect Infringement: For each asserted patent, the complaint alleges induced infringement based on Defendant's sale of the accused smartphones and the distribution of "product literature or videos inducing end users" to operate the devices in an infringing manner (e.g., Compl. ¶¶27, 34).
• Willful Infringement: The complaint does not use the word "willful" but alleges that Defendant has "actively, knowingly, and intentionally continued to induce infringement" at least since being served with the complaint, which lays a foundation for a claim of post-filing willful infringement (e.g., Compl. ¶¶27, 34).

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

• Definitional Scope: A core issue will be one of role and definition: Can a general-purpose smartphone running a data-transfer application be legally construed as the claimed "transceiver" or "beacon," a term rooted in the patents' context of a dedicated, stationary device deployed by a merchant?
• Operational Locus: The case will likely turn on a key question of technical architecture: Do the accused Samsung features perform the critical step of identifying an information retrieval location "exclusively" on the device and "independently of any networks" as required by multiple patents, or do they immediately offload this logic to a cloud server, potentially creating a fundamental operational mismatch with the claims?
• Evidentiary Sufficiency: With infringement allegations hinging on specific software operations and protocols (e.g., the "initiate-and-cancel" connection method), a central evidentiary challenge will be to determine whether the accused Samsung features actually perform the precise, multi-step functions recited in the claims or if they achieve a similar result using different, non-infringing technical means.