Alpha Touch Group LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Alpha Touch Group LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York); Samsung Display Co., Ltd. (Republic of Korea)
  • Plaintiff’s Counsel: Fabricant LLP; Rubino IP
• Case Identification: 2:26-cv-00105, E.D. Tex., 02/12/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Defendants’ sales, offers for sale, and acts of infringement within the district, as well as the presence of regular and established places of business for certain defendants. For foreign-domiciled defendants, venue is alleged as proper in any judicial district.
• Core Dispute: Plaintiff alleges that a wide range of Samsung's smartphones, tablets, and computers, particularly those featuring foldable and On-Cell Touch AMOLED displays, infringe four patents related to the construction and manufacturing of touch screen panels.
• Technical Context: The technology at issue concerns methods for manufacturing thinner, more durable, and more integrated capacitive touch screens, including structures for modern foldable displays, a key area of innovation and competition in the consumer electronics market.
• Key Procedural History: The complaint alleges that Samsung entities cited the patent families of all four patents-in-suit during the prosecution of their own U.S. and foreign patent applications. This allegation may be used by the Plaintiff to support claims of pre-suit knowledge for willfulness and induced infringement.

Case Timeline

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

U.S. Patent No. 11,493,794 - "Electronic Device and Method of Manufacturing the Same"

• Patent Identification: U.S. Patent No. 11,493,794, "Electronic Device and Method of Manufacturing the Same," issued November 8, 2022 Compl. ¶8

The Invention Explained

• Problem Addressed: The patent’s background section identifies durability issues in foldable screens made from plastic films, which are prone to forming permanent creases after repeated folding due to their low stress-release ability (low Young's modulus). The use of conventional adhesives to stack layers also increases thickness and can create crack gaps ʼ794 Patent, col. 1:24-41
• The Patented Solution: The invention proposes a composite cover plate for electronic devices, particularly foldable ones. The solution involves a central glass layer, such as ultra-thin glass (UTG), directly laminated with at least one transparent covering layer (e.g., polyimide) on one or both sides without a separate adhesive layer. This creates an integrated structure intended to be more resilient to bending, harder, and thinner than previous designs ʼ794 Patent, abstract ʼ794 Patent, col. 3:1-12 ʼ794 Patent, col. 5:10-24
• Technical Importance: This technology aims to solve a core engineering challenge for foldable devices by creating a cover structure that balances the competing demands of flexibility for folding and rigidity for durability and a high-quality user experience ʼ794 Patent, col. 1:12-23

Key Claims at a Glance

The complaint asserts at least independent Claim 1 Compl. ¶20 Its essential elements include:

• An electronic device, comprising:
• a cover plate comprising:
  • a glass layer having a first surface and a second surface; and
  • at least one transparent covering layer disposed on and in contact with the glass layer and laminated with it;
  • wherein the at least one transparent covering layer comprises a first and a second transparent covering layer, and the glass layer is laminated between them;
• a touch sensing layer disposed under the cover plate; and
• a display module disposed under the touch sensing layer.

U.S. Patent No. 9,606,675 - "Capacitive Touch Panel"

• Patent Identification: U.S. Patent No. 9,606,675, "Capacitive Touch Panel," issued March 28, 2017 Compl. ¶9

The Invention Explained

• Problem Addressed: Related patents in the same family describe the complexity, cost, and thickness associated with conventional touch panels that require multiple separate substrates (e.g., a cover lens and a touch sensor substrate) to be bonded together with optical adhesives '542 Patent, col. 1:36-52
• The Patented Solution: The patent describes an "integrally-formed" capacitive touch panel built upon a "singular lens substrate." In this design, the sensing circuit and a peripheral mask layer are formed directly on a single substrate, which also serves as the device's cover lens. This approach eliminates the need for a separate touch panel substrate and the associated lamination step, thereby simplifying manufacturing and reducing the final product's thickness '675 Patent, abstract '675 Patent, col. 3:42-49 '675 Patent, FIG. 2
• Technical Importance: The invention represents a step toward component integration in touch screen manufacturing, a crucial trend for producing the thinner and lighter consumer electronics demanded by the market '675 Patent, col. 4:5-15

Key Claims at a Glance

The complaint asserts at least independent Claim 1 Compl. ¶38 Its essential elements include:

• A capacitive touch panel comprising:
• a substrate made of glass or plastic material having a first and second surface;
• a sensing circuit;
• a physical tactile inputting integration having a peripheral masking area, a first surface for receiving tactile input, and a second surface for forming the sensing circuit;
• wherein there is no other substrate made of glass or plastic material laminated or bonded on the first surface of the substrate.

U.S. Patent No. 9,395,857 - "Capacitive Touch Panel"

• Patent Identification: U.S. Patent No. 9,395,857, "Capacitive Touch Panel," issued July 19, 2016 Compl. ¶10
• Technology Synopsis: This patent discloses a capacitive touch panel where key components are integrated with the display stack. It describes a structure comprising a cover lens, a color filter substrate parallel to the lens, and an electrode layer disposed on the color filter substrate to perform touch-sensing operations. This "on-cell" or "in-cell" architecture reduces the need for separate touch substrates, aiming to decrease panel thickness and simplify manufacturing '857 Patent, abstract '857 Patent, claim 1
• Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶54
• Accused Features: The complaint alleges that Samsung's Super AMOLED displays, which feature an integrated color filter and electrode layer beneath a cover lens, infringe the patent Compl. ¶¶55-59

U.S. Patent No. 8,482,542 - "Capacitive Touch Panel"

• Patent Identification: U.S. Patent No. 8,482,542, "Capacitive Touch Panel," issued July 9, 2013 Compl. ¶11
• Technology Synopsis: This patent describes a simplified touch panel construction featuring a first electrode layer on a cover lens and a second electrode layer separated by a "nongaseous insulating layer." This design avoids the conventional approach of forming electrode layers on two separate, rigid substrates that are then bonded together, thereby reducing component count and manufacturing complexity '542 Patent, abstract '542 Patent, claim 1
• Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶70
• Accused Features: The complaint alleges that Samsung's devices utilize a structure with a cover lens, an integrated electrode layer, an anti-reflective/insulating layer, and a second electrode layer, which corresponds to the claimed invention Compl. ¶¶71-75

III. The Accused Instrumentality

Product Identification

• The complaint accuses two primary categories of Samsung products. The first, accused of infringing the ’794 Patent, includes Samsung smartphones with foldable Eco² OLED displays, such as the Galaxy Z Fold and Galaxy Z Flip series Compl. ¶14 Compl. ¶19 The second category, accused of infringing the ’675, ’857, and ’542 Patents, is a broad range of devices with capacitive touch displays, including the Galaxy S, A, Tab, Book, and Note series, with the Galaxy A16 5G often used as an exemplary product Compl. ¶15 Compl. ¶38 Compl. ¶54 Compl. ¶70

Functionality and Market Context

• The accused foldable devices feature "Infinity Flex Displays" which utilize Ultra-Thin Glass (UTG) and protective polymer films to create a screen that can be folded and unfolded Compl. ¶21 Compl. ¶22 A diagram provided in the complaint illustrates a stack-up of a protective film, a protective layer, UTG, and an AMOLED panel Compl. p. 11 This technology is central to Samsung's premium, foldable smartphone lineup.
• The second category of accused devices allegedly incorporates "On Cell Touch AMOLED" (OCTA) technology Compl. p. 23 This technology embeds the touch sensor directly into the display panel, integrating it at the Thin Film Encapsulation (TFE) stage Compl. ¶42 Compl. p. 27 This integration eliminates a separate touch sensor panel film, which allows for thinner and lighter device profiles Compl. p. 24 The complaint alleges Samsung is a leading global manufacturer and seller of these devices Compl. ¶2

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,493,794 Infringement Allegations

Identified Points of Contention

• Scope Questions: A potential point of dispute is whether the accused "protective film" and "protective layer" meet the claim requirement of being "laminated with" the glass layer. The defendant may argue that the method of attachment used in its products differs from the direct coating and drying process described in the patent's specification, especially if an adhesive is used, which the patent sought to avoid '794 Patent, col. 1:36-41
• Technical Questions: The complaint relies on marketing materials and general diagrams to describe the accused structure Compl. p. 11 A key question for the court will be whether the actual, physical construction of the accused foldable displays corresponds to the specific layered arrangement required by Claim 1, including the direct contact between the covering layers and the glass layer.

U.S. Patent No. 9,606,675 Infringement Allegations

Identified Points of Contention

• Scope Questions: The central dispute may concern the negative limitation "wherein there is no other substrate... laminated or bonded on the first surface of the substrate." Samsung may argue that the complex, multi-layered OLED panel, including the Thin Film Encapsulation (TFE) layer upon which the sensor is deposited, itself constitutes a "substrate" within the ordinary meaning of the term, even if it is not the separate, rigid substrate the patent criticizes.
• Technical Questions: A diagram in the complaint shows the difference between traditional TSP and OCTA technology, where the touch layer is embedded in the panel Compl. p. 24 The factual question will be whether this embedded structure, formed as part of the OLED manufacturing process, is technically distinct from bonding a separate substrate as contemplated by the claim language.

V. Key Claim Terms for Construction

• Term from the ’794 Patent: "laminated with"

  • Context and Importance: This term is critical because the patent’s background distinguishes its invention from prior art that uses adhesives like OCA, which add thickness and create defects. The infringement analysis will depend on whether the method used to join the layers in Samsung’s foldable displays falls within the scope of "laminated with" as used in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims themselves do not specify a particular method of lamination, which may support a construction covering any process that joins layers together.
    • Evidence for a Narrower Interpretation: The specification describes a process of "coating a polymer material layer on the glass layer; and drying the polymer material layer" '794 Patent, col. 2:60-64 This, combined with the claim language "disposed on and in contact with," could support a narrower construction limited to direct formation of one layer on another, excluding the use of a separate adhesive film.

• Term from the ’675 Patent: "substrate" (in the phrase "no other substrate...laminated or bonded")

  • Context and Importance: Practitioners may focus on this term because the infringement allegation hinges on the accused OCTA technology not having a second, separate substrate. The definition of "substrate" will determine whether integrated layers within the OLED panel stack, like the TFE layer, count as a "substrate" under the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "substrate." A defendant could argue for its plain and ordinary meaning as any underlying layer on which circuits can be formed, which could potentially read on the TFE layer.
    • Evidence for a Narrower Interpretation: The patent aims to create an "integrally-formed" panel on a "singular lens substrate" '675 Patent, abstract; '675 Patent, col. 3:44 The context provided by the patent family suggests the term was meant to refer to the discrete, separate glass or plastic substrates used in the prior art, not layers that are integral to the display panel's own manufacturing process.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is primarily based on allegations that Samsung provides user guides, manuals, and other instructions that direct end-users to operate the accused touch screens in an infringing manner Compl. ¶27 Compl. ¶45 Compl. ¶62 Compl. ¶78 Contributory infringement is based on the allegation that the accused display screens are material components of the inventions, are not staple articles of commerce, and have no substantial non-infringing uses Compl. ¶30 Compl. ¶48 Compl. ¶65 Compl. ¶81

• Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. The primary basis for this allegation is that Samsung Display and/or Samsung Electronics cited the patent families of all four asserted patents in their own U.S. and foreign patent applications, allegedly demonstrating knowledge of the patented technology before the lawsuit was filed Compl. ¶26, fn 16 Compl. ¶44, fn 29 Compl. ¶61, fn 45 Compl. ¶77, fn 49 The complaint also alleges willful blindness based on a purported policy of not reviewing the patents of others Compl. ¶26 Compl. ¶44 Compl. ¶61 Compl. ¶77

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

This case appears to center on the intersection of claim language rooted in early 2010s touch panel technology and the highly integrated display technologies of the 2020s. The key questions for the court will likely be:

• A core issue will be one of definitional scope: can terms like "substrate" and "laminated with", which have specific meanings in the context of the prior art the patents describe, be construed to read on the functionally similar but structurally different features of modern, highly integrated display technologies like OCTA and foldable UTG screens?

• A second major issue will be one of structural correspondence: does the physical assembly of Samsung's accused displays—from the specific materials used to the method of their bonding and integration—actually align with the precise, multi-part structures required by the asserted claims, or is there a fundamental mismatch in their technical construction?

• Finally, a key question for damages will be pre-suit knowledge: will the plaintiff’s evidence showing that Samsung cited the asserted patent families during its own patent prosecution be sufficient to establish the knowledge and intent required for a finding of willful and induced infringement, potentially leading to enhanced damages?