DCT

2:26-cv-00106

Surecell Transactions LLC v. Samsung Electronics America Inc

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00106, E.D. Tex., 09/02/2026
  • Venue Allegations: Venue is based on Defendant Samsung Electronics America, Inc. maintaining a regular and established place of business in the Eastern District of Texas, specifically an office in Plano, Texas.
  • Core Dispute: Plaintiff alleges that Defendant's smartphones, wearables, and mobile computing devices infringe six U.S. patents related to performing secure mobile financial transactions using features like inductive coupling (NFC), biometric or PIN authentication, and state-based communication control.
  • Technical Context: The technology concerns the integration of secure, contactless payment and identification functionalities into cellular devices, a central feature of the modern smartphone and wearable market.
  • Key Procedural History: The complaint notes that U.S. Patent No. 7,924,156 was previously the subject of litigation against the U.S. Government concerning its use in U.S. Passports. Plaintiff characterizes the settlement of that case as an eminent domain action, arguing it does not trigger patent marking requirements.

Case Timeline

Date Event
2005-05-06 Earliest Priority Date for all Asserted Patents
2011-04-12 U.S. Patent No. 7,924,156 Issued
2022-05-31 U.S. Patent No. 11,347,949 Issued
2023-03-07 U.S. Patent No. 11,599,734 Issued
2023-06-27 U.S. Patent No. 11,687,741 Issued
2024-05-21 U.S. Patent No. 11,989,612 Issued
2024-07-16 U.S. Patent No. 12,039,396 Issued
2026-09-02 Complaint Filed

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

U.S. Patent No. 7,924,156 - Electronically switchable RFID Tags

  • Patent Identification: U.S. Patent No. 7,924,156, issued April 12, 2011.

The Invention Explained

  • Problem Addressed: The complaint suggests that as of the patent's priority date, mobile devices lacked the capability to perform secure, authenticated financial transactions using technologies like NFC, Wi-Fi, PIN, or biometrics Compl. ¶¶27-29 The broader patent family addresses the risk of Radio Frequency Identification (RFID) tags being read without authorization, creating security and privacy vulnerabilities '949 Patent, col. 14:3-14
  • The Patented Solution: The invention provides for an RFID tag with a mechanical or electronic switch that controls its operational state Compl. ¶32 This allows a user to select between different "ON states" or an "OFF state" to control when and what information the tag transmits, thereby preventing unauthorized access while enabling intentional transactions '949 Patent, col. 5:5-15
  • Technical Importance: This approach provided a user-controlled security layer for emerging contactless technologies, enabling their integration into personal devices for sensitive applications like payments and identification.

Key Claims at a Glance

  • The complaint asserts independent claim 20 Compl. ¶¶34, 66
  • The essential elements of Claim 20 include:
    • A mechanical switch configured for selecting between two or more ON states of the RFID tag;
    • An antenna configured to receive/transmit RF signals and energy; and
    • Integrated circuitry with a state memory and switch logic to determine whether to transmit a signal based on the state stored in the memory or the mechanical switch.
  • The complaint also asserts claims 24, 25, 29, 32, 34, 37, 57, 58 & 60 Compl. ¶67

U.S. Patent No. 11,347,949 - Cellular Device Including an Inductive Antenna

  • Patent Identification: U.S. Patent No. 11,347,949, issued May 31, 2022.

The Invention Explained

  • Problem Addressed: As with the '156 Patent, the underlying problem is enabling secure mobile transactions. The patent background highlights the fields of electronic passports and the need for shielding and switchable RFID tags to prevent unauthorized reading '949 Patent, col. 2:1-4
  • The Patented Solution: The patent describes a cellular telephone that uses an "inductive coupling" (such as RFID or NFC) as part of a circuit that includes an electronic switch Compl. ¶35 This switch allows the device to change between different communication states (e.g., an authenticated state vs. a non-authenticated state), with communication through the inductive coupling being responsive to the selected state '949 Patent, col. 9:39-44
  • Technical Importance: This invention provides a framework for integrating switchable, state-dependent contactless communication directly into the architecture of a cellular phone.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 30 Compl. ¶¶37, 81
  • The essential elements of Claim 1 include:
    • An electronic communication system comprising: a cellular telephone configured to communicate wirelessly using an inductive coupling;
    • Wherein the inductive coupling is part of a circuit that includes an electronic switch configured to change between states of the circuit; and
    • The circuit is also configured to communicate via the inductive coupling responsive to the states of the circuit.
  • The complaint also asserts claims 1-8, 10-12, 14-24 & 26-30 Compl. ¶82

U.S. Patent No. 11,599,734 - Methods of Inductive Communication in a Cellular Telephone

  • Patent Identification: U.S. Patent No. 11,599,734, issued March 7, 2023.
  • Technology Synopsis: The patent describes methods for performing financial transactions by placing a cellular phone near a point-of-sale device '734 Patent, abstract It involves using an inductive coupling and activating an electronic switch to change the circuit's state to facilitate communication of financial account information Compl. ¶38 Compl. ¶40
  • Asserted Claims: Independent claims 1, 15, and 23 are asserted Compl. ¶96
  • Accused Features: The accused features are the functionalities in Samsung's mobile devices that enable financial transactions with point-of-sale systems using inductive coupling (NFC) Compl. ¶38 Compl. ¶96

U.S. Patent No. 11,687,741 - Methods of Using a Cellular Telephone

  • Patent Identification: U.S. Patent No. 11,687,741, issued June 27, 2023.
  • Technology Synopsis: This patent covers methods of performing financial transactions with a cellular phone by activating an electronic switch in response to a biometric sensor '741 Patent, abstract This changes the state of a circuit to allow financial account information to be communicated via inductive coupling or an RF antenna Compl. ¶41 Compl. ¶43
  • Asserted Claims: Independent claims 1 and 19 are asserted Compl. ¶111
  • Accused Features: The complaint targets features in Samsung devices that use a biometric sensor to authorize and execute financial transactions via NFC or other RF communications Compl. ¶41 Compl. ¶111

U.S. Patent No. 11,989,612 - Cellular Telephone Including Biometric Sensor

  • Patent Identification: U.S. Patent No. 11,989,612, issued May 21, 2024.
  • Technology Synopsis: The patent describes a method for a financial transaction where a cellular phone is placed near a point-of-sale device, and an electronic switch is activated in response to a biometric sensor to change the circuit's state '612 Patent, abstract This enables communication of account information using an inductive antenna Compl. ¶44 Compl. ¶46
  • Asserted Claims: Claims 1-5 are asserted Compl. ¶126
  • Accused Features: The accused features are the functionalities in Samsung devices for performing financial transactions that are initiated in response to a biometric sensor, using an inductive antenna (NFC) for communication Compl. ¶44 Compl. ¶126

U.S. Patent No. 12,039,396 - Cellular Telephone Including Biometric Control of Transactions

  • Patent Identification: U.S. Patent No. 12,039,396, issued July 16, 2024.
  • Technology Synopsis: This patent is directed to a cellular phone that uses two or more different wireless communication modes (e.g., cellular and short-range) and employs a biometric sensor to approve financial transactions '396 Patent, abstract Compl. ¶47 The phone uses an inductive antenna for short-range communication Compl. ¶49
  • Asserted Claims: Claims 1-17 and 19-20 are asserted Compl. ¶141
  • Accused Features: The complaint targets Samsung devices that operate on both cellular and other wireless networks (like Wi-Fi or NFC) and use a biometric sensor to approve financial transactions or other actions like unlocking a car Compl. ¶¶47, 143

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are a broad range of Samsung's mobile devices, including smartphones (e.g., Galaxy S, Z Fold, Z Flip series), wearables (e.g., Galaxy Watch series), and tablet computers (e.g., Galaxy Tab series) Compl. ¶50 Compl. ¶52 Compl. ¶58 The complaint also names associated software and services like Samsung Pay, Samsung Blockchain Wallet, and various third-party applications available through Samsung-supported app stores Compl. ¶¶53-57

Functionality and Market Context

The complaint alleges these devices are configured to engage in mobile transactions using technologies such as Near Field Communication (NFC) Compl. ¶¶51, 56 The complaint provides an image of a Samsung SGH-X480 flip phone to illustrate the state of cellular technology at the patents' priority date, which it alleges lacked features like touch screens and authenticated financial transaction capabilities Compl. ¶27 In contrast, the accused products, represented by images of modern foldable and slate-style smartphones, are alleged to incorporate these advanced features Compl. ¶51 The complaint alleges these devices and their associated services generate substantial financial revenues for the Defendants Compl. ¶65

IV. Analysis of Infringement Allegations

The complaint states that "Exemplary Claim Charts" are attached as exhibits for each asserted patent, but the exhibits themselves were not filed with the complaint Compl. ¶31 Compl. pp. 44 Therefore, the infringement allegations are summarized below in prose based on the narrative provided in the complaint.

'156 Patent Infringement Allegations

The complaint alleges that Defendants' devices infringe claim 20 of the '156 patent Compl. ¶66 The theory appears to be that a physical button on the accused devices, such as a power or volume button, functions as the claimed "mechanical switch" Compl. ¶32 This switch is allegedly used for "selecting between two or more ON states of the RFID tag," such as an "authenticated" and "non-authenticated" state for a financial transaction Compl. ¶26(c) The devices' NFC components allegedly meet the "antenna" and "integrated circuitry" limitations Compl. ¶34

'949 Patent Infringement Allegations

The complaint alleges that Defendants' devices infringe claim 1 of the '949 patent Compl. ¶81 The infringement theory centers on the accused smartphones functioning as a "cellular telephone configured to communicate wirelessly using an inductive coupling" (i.e., NFC) Compl. ¶37 The complaint alleges this inductive coupling is part of an internal circuit that includes an "electronic switch" used to change the device's state (e.g., from locked to unlocked via biometric or PIN entry) to enable secure communication for a financial transaction Compl. ¶¶26(a), 35

Identified Points of Contention

  • Scope Questions: For the '156 patent, a primary question will be whether a general-purpose hardware button (e.g., a power or volume button) on a smartphone can be considered a "mechanical switch configured for selecting between two or more ON states of the RFID tag," as the claim requires. For the '949 patent, a question may be whether the broad term "inductive coupling" as used in the patent, which is rooted in RFID technology, reads on the specific implementation of NFC technology in the accused devices.
  • Technical Questions: A key evidentiary question for the '156 patent will be what evidence demonstrates that a standard hardware button on an accused phone is used to perform the specific function of selecting an "ON state" of the RFID tag, as opposed to a more general device function like waking the screen. For the '949 patent, the analysis will question how the accused devices' software and hardware architecture for user authentication and NFC activation maps to the claimed "circuit including an electronic switch configured to change between states."

V. Key Claim Terms for Construction

'156 Patent, Claim 20

The Term

"mechanical switch configured for selecting between two or more ON states of the RFID tag"

Context and Importance

The construction of this term is critical because the infringement allegation for the '156 patent appears to depend on mapping this limitation to a general-purpose button on a smartphone. Practitioners may focus on this term because its interpretation will determine whether the claim can cover devices that lack a dedicated, physical switch for controlling RFID/NFC states.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification of the related '949 patent, which shares a common specification, discusses that switches can be "electronic, wireless, and/or mechanical" '949 Patent, col. 5:31-32 and can be used to "change operation of an RFID tag from a responsive state to a non-responsive state" '949 Patent, col. 5:26-29 This may support an argument that any mechanical switch used to control the operational state of the tag meets the limitation.
  • Evidence for a Narrower Interpretation: The patent family's focus on securing identity documents like passports '949 Patent, col. 2:1-4 and specific disclosed embodiments showing dedicated switches ('949 Patent, Fig. 25A, 25B) may support an argument that the "mechanical switch" must be one specifically designed or intended for the purpose of selecting RFID states, not a multipurpose button.

'949 Patent, Claim 1

The Term

"inductive coupling"

Context and Importance

This term is central to defining the scope of the claimed communication method. The complaint alleges this covers NFC technology Compl. ¶¶29, 73 Practitioners may focus on this term because its construction will determine whether it is limited to the specific RFID technologies discussed in the specification or is broad enough to cover modern, standardized protocols like NFC as implemented in smartphones.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification discusses communication using RFID technology as well as other RF technologies like "Bluetooth, WiFi, WiMAX, 802.11 or cellular standards" '949 Patent, col. 9:56-61 This could suggest the inventor contemplated a broad range of wireless technologies, and "inductive coupling" should be interpreted as one example within that broader context.
  • Evidence for a Narrower Interpretation: The specification repeatedly uses "inductive coupling" in the context of passive RFID tags and electronic passports '949 Patent, col. 1:11-15 '949 Patent, col. 2:1-4 This context could support an argument that the term should be limited to the specific types of near-field inductive power and data transfer characteristic of the RFID systems of that era, rather than the more complex, standardized NFC protocols in modern smartphones.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is alleged based on Defendants providing user instructions and operating app stores that encourage infringing uses Compl. ¶¶71, 86 Contributory infringement is alleged based on Defendants providing the platform (e.g., devices with NFC and biometric sensors) with the intention that it be used in an infringing manner Compl. ¶¶73, 88

Willful Infringement

The complaint alleges that Defendants had knowledge of the patents "at least as early as the dates of service of this Complaint" (e.g.,Compl. ¶¶63-64). The prayer for relief seeks enhanced damages for willful infringement occurring after service of the complaint, indicating a theory of post-filing willfulness Compl. p. 42, prayer 4

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

  • A core issue will be one of definitional scope: can the term "mechanical switch configured for selecting... ON states of the RFID tag" from the '156 patent, which originates in a context of specialized RFID devices, be construed to cover a general-purpose power or volume button on a modern smartphone?
  • A second central question will be one of technical mapping: does the software-driven security architecture of a modern smartphone-which uses biometric or PIN authentication to enable NFC payment functionality-constitute the "circuit including an electronic switch configured to change between states... and configured to communicate... responsive to the states" as claimed in the '949 patent and its relatives?
  • A broader evidentiary question will be one of technological evolution: how will the court apply claims drafted with a 2005 priority date, rooted in the technology of RFID-enabled passports and physical switches, to the vastly more complex and integrated systems of modern smartphones and their operating systems?