Surecell Transactions LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SureCell Transactions LLC (Nevada)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff's Counsel: Rimôn PC
• Case Identification: 2:26-cv-00106, E.D. Tex., 02/26/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants conduct substantial business in the district, have committed acts of infringement there, and Defendant Samsung Electronics America, Inc. maintains a regular and established place of business in Plano, Texas.
• Core Dispute: Plaintiff alleges that a wide range of Defendant's smartphones, wearables, and other mobile computing devices infringe six U.S. patents relating to methods and systems for performing secure financial transactions using technologies such as inductive coupling (NFC/RFID), biometric sensors, and multi-state authentication.
• Technical Context: The technology at issue forms the basis of modern mobile payment systems (e.g., "tap-to-pay"), which allow users to securely conduct financial transactions by bringing a device like a smartphone or smartwatch near a point-of-sale terminal.
• Key Procedural History: The complaint is a First Amended Complaint, filed to correct the mistaken omission of an Appendix in the original complaint. The patents-in-suit are part of a large family with a complex prosecution history, including numerous continuations and continuations-in-part, but no prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date	Event
2005-05-06	Earliest Priority Date for 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
2026-02-26	First Amended Complaint Filed

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

As the full patent documents for U.S. Patent Nos. 7924156 and 11599734 were not provided as exhibits to the complaint, the following analysis focuses on the first two patents for which full documents were available: U.S. Patent Nos. 11347949 and 11687741.

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

• Patent Identification: U.S. Patent No. 11,347,949, "Cellular Device Including an Inductive Antenna," issued May 31, 2022.

The Invention Explained

• Problem Addressed: The patent background describes the risk of radio frequency identity (RFID) tags, such as those in passports or credit cards, being read by unauthorized readers, creating security and privacy vulnerabilities '949 Patent, col. 1:30-47
• The Patented Solution: The '949 Patent discloses a cellular telephone that uses an "inductive coupling" (such as an NFC antenna) as part of a circuit that includes an "electronic switch." This switch can change between different "states" (e.g., authenticated vs. non-authenticated), and the device's ability to communicate wirelessly is responsive to the current state of that circuit '949 Patent, abstract '949 Patent, col. 10:46-65 This provides a mechanism to control when the device can perform a transaction.
• Technical Importance: This approach provided a technical framework for making short-range wireless transactions from a mobile phone contingent on the device being in a specific, secure state, a foundational concept for modern mobile payment security.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶81
• Claim 1 of the '949 Patent requires:
  • 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 including an electronic switch configured to change between states of the circuit,
  • and configured to communicate via the inductive coupling responsive to the states of the circuit.
• The complaint reserves the right to assert additional claims, including dependent claims 2-8, 10-12, 14-24, and 26-30 Compl. ¶81

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

• Patent Identification: U.S. Patent No. 11,687,741, "Methods of Using a Cellular Telephone," issued June 27, 2023.

The Invention Explained

• Problem Addressed: Like its sibling patents, the '741 Patent addresses the problem of unauthorized reading of information from RFID tags embedded in devices like passports and credit cards, which poses a security risk '741 Patent, col. 1:30-49
• The Patented Solution: The patent describes a method for performing a financial transaction where a cellular phone, containing a circuit with an electronic switch, is placed near a wireless communication device. The key step is "activating the electronic switch... responsive to a biometric sensor included in the cellular telephone" to change the circuit's state, which then allows financial account information to be communicated '741 Patent, abstract '741 Patent, col. 5:4-11 This links the ability to transact directly to a user's biometric authentication.
• Technical Importance: This method explicitly ties biometric authentication (e.g., a fingerprint scan) to the act of enabling a secure transaction, a user experience that has become a standard security feature in mobile payment applications.

Key Claims at a Glance

• The complaint asserts at least independent claims 1 and 19 Compl. ¶111
• Claim 1 of the '741 Patent requires a method comprising:
  • placing a cellular telephone (with a circuit including an electronic switch) within reading range of a wireless communication device;
  • activating the electronic switch to change the circuit's state, where the activation is responsive to a biometric sensor in the phone; and
  • communicating financial account information responsive to the circuit's state to facilitate the transaction.
• The complaint reserves the right to assert additional claims, including dependent claims 2-13, 15-16, and 18-28 & 30 Compl. ¶111

Multi-Patent Capsule Analysis

• Patent Identification: U.S. Patent No. 7,924,156, "Electronically switchable RFID Tags," issued April 12, 2011 Compl. ¶33

• Technology Synopsis: The patent pertains to an RFID device that includes a mechanical switch for selecting between two or more "ON states." The ability of the device to transmit an RF signal is dependent on the selected state, providing a physical control layer for RFID communication Compl. ¶32 Compl. ¶34

• Asserted Claims: At least independent claims 20 and 29, and method claim 60 Compl. ¶¶65-66

• Accused Features: Samsung mobile devices are accused of utilizing the patented technology, presumably by having switchable communication states for RFID/NFC transactions Compl. ¶¶14 Compl. ¶50

• Patent Identification: U.S. Patent No. 11,599,734, "Methods of Inductive Communication in a Cellular Telephone," issued March 7, 2023 Compl. ¶39

• Technology Synopsis: The patent is directed to methods of performing financial transactions by communicating with a point-of-sale device. The methods involve changing the authentication state of the cellular telephone and communicating financial information using an inductive coupling responsive to that state Compl. ¶38 Compl. ¶40

• Asserted Claims: At least independent claims 1, 15, and 23 Compl. ¶95

• Accused Features: The complaint alleges Samsung devices perform methods of performing financial transactions that map to the claimed steps, such as placing the phone near a POS terminal and activating a secure state to communicate financial data Compl. ¶¶53 Compl. ¶56

• Patent Identification: U.S. Patent No. 11,989,612, "Cellular Telephone Including Biometric Sensor," issued May 21, 2024 Compl. ¶45

• Technology Synopsis: This patent claims methods of performing financial transactions by placing a cellular telephone near a point-of-sale device. The method includes activating an electronic switch within the phone to change the circuit's state, with the activation being responsive to a biometric sensor, which then allows financial account information to be communicated Compl. ¶44 Compl. ¶46

• Asserted Claims: At least claims 1-5 Compl. ¶125

• Accused Features: The complaint accuses Samsung's mobile devices and wearables that use biometric sensors to authenticate payments via NFC (Compl. ¶52; Compl. ¶53; Compl. ¶56).

• Patent Identification: U.S. Patent No. 12,039,396, "Cellular Telephone Including Biometric Control of Transactions," issued July 16, 2024 Compl. ¶48

• Technology Synopsis: The patent is directed to a cellular telephone that uses two or more different wireless communication modes (e.g., cellular and short-range) and a biometric sensor to approve financial transactions. The short-range communication mode uses an inductive antenna Compl. ¶47 Compl. ¶49

• Asserted Claims: At least claims 1-17 and 19-20 Compl. ¶140

• Accused Features: Samsung smartphones that operate on cellular networks and also use short-range NFC/RFID for transactions, with such transactions being approved by a biometric sensor, are accused of infringement Compl. ¶50 Compl. ¶51 Compl. ¶52

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are a broad range of Samsung's mobile devices, including smartphones, wearables, and other computing devices Compl. ¶50 The complaint provides an extensive, non-exhaustive list, including various models from the Galaxy S, Note, Z Fold/Flip, and A series of smartphones, as well as Galaxy Watch wearables Compl. ¶52 The complaint also includes an image showcasing future or conceptual products such as the "Galaxy Z Fold7" and "Galaxy S25 Ultra" Compl. ¶51 This image from the complaint shows four conceptual smartphone models, illustrating Plaintiff's intent to capture future and unreleased Samsung products in the lawsuit Compl. ¶51

Functionality and Market Context

The complaint alleges these devices are configured to engage in mobile transactions through features like Samsung Pay and the Samsung Blockchain Wallet (Compl. ¶53; Compl. ¶54). The relevant functionality involves the use of Near-Field Communication (NFC) for short-range wireless communication, often authenticated using biometric sensors (e.g., fingerprint readers) or PINs, to conduct financial transactions with point-of-sale terminals or to interact with other devices like smart locks and automotive digital keys Compl. ¶¶56-57 The complaint also notes that these devices support a wide variety of third-party payment and financial applications downloaded from app stores Compl. ¶55

IV. Analysis of Infringement Allegations

The complaint states that "Exemplary Claim Charts and Evidence of Infringement" are attached as exhibits in Appendix A Compl. ¶31 However, these detailed claim chart exhibits were not included in the provided documents. The complaint's infringement allegations are therefore summarized in prose based on its narrative infringement theory.

'949 Patent Infringement Allegations
The complaint alleges that the Accused Instrumentalities infringe the '949 Patent because they are cellular telephones that embody the claimed system Compl. ¶80 The infringement theory suggests that the NFC hardware in Samsung's devices constitutes the claimed "inductive coupling." This coupling is part of a larger circuit, controlled by the device's processor and software, which acts as the "electronic switch." This "switch" changes between states (e.g., an unlocked, authenticated state versus a locked, unauthenticated state), and the ability to communicate financial data via NFC is responsive to these states Compl. ¶¶80 Compl. ¶83

'741 Patent Infringement Allegations
The complaint alleges that the use of the Accused Instrumentalities to perform financial transactions constitutes infringement of the method claims of the '741 Patent Compl. ¶110 The theory posits that when a user places a Samsung device near a POS terminal, authenticates with a biometric sensor to enable a payment via an application like Samsung Pay, and then communicates financial data, they are performing the claimed method steps. The act of biometric authentication is alleged to be "activating the electronic switch... responsive to a biometric sensor" to change the circuit's state and facilitate the transaction Compl. ¶¶110 Compl. ¶113

• Identified Points of Contention:
  • Scope Questions: A central dispute for both the '949 and '741 patents will likely be the definition of "electronic switch." The court will have to determine if a software-controlled state change within a general-purpose processor or NFC controller meets the definition of the claimed "electronic switch," or if the term requires a more discrete hardware component as might be suggested by certain patent embodiments.
  • Technical Questions: For the '741 Patent, a key technical question is one of causation. What evidence will show that the activation of the communication circuit is directly "responsive to a biometric sensor" as claimed, versus being the result of a multi-step, user-driven software process that is merely initiated following a successful biometric authentication for a separate purpose (e.g., unlocking the device or app)?

V. Key Claim Terms for Construction

• The Term: "electronic switch" ('949 Patent, Claim 1; '741 Patent, Claim 1)
• Context and Importance: This term is foundational to the asserted claims of both the '949 and '741 patents. Its construction will be critical because Samsung's accused devices integrate NFC functionality into complex systems-on-a-chip (SoCs) controlled by software. Practitioners may focus on this term because its scope will determine whether a software-based gating of NFC functionality constitutes an infringing "switch" or falls outside the claims as simply the ordinary operation of a programmable processor.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The '949 Patent states that the switch may be "electronic, wireless, and/or mechanical" and that in some embodiments the switch is "turned on or off by a circuit external to Switchable RFID Device" '949 Patent, col. 5:35-46 This language suggests the switch is not limited to a simple mechanical component and could encompass a software-controlled electronic circuit.
  • Evidence for a Narrower Interpretation: The '741 Patent includes figures depicting a "sliding switch" and a "membrane switch" '741 Patent, FIG. 25A '741 Patent, FIG. 26A These specific, relatively simple mechanical and electromechanical embodiments could be used to argue that the inventor envisioned a more discrete and physically distinct component than a software routine running on a general-purpose processor.

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 instructs and encourages end-users to perform the infringing methods through advertising, user manuals, and customer support Compl. ¶¶70-71 Compl. ¶¶85-86 Contributory infringement is based on allegations that Samsung provides a platform (e.g., devices with NFC hardware, biometric sensors, and operating systems) with the knowledge and intent that it will be used by third-party apps and end-users to infringe Compl. ¶¶72 Compl. ¶87
• Willful Infringement: The complaint alleges that Defendants have had "actual notice" of the Asserted Patents "at least as early as the dates of service of this Complaint" Compl. ¶¶62 Compl. ¶77 Compl. ¶92 Compl. ¶107 Compl. ¶122 Compl. ¶137 This appears to form the basis for a claim of post-filing willful infringement, as there are no allegations of pre-suit knowledge. The prayer for relief explicitly requests treble damages for willful infringement Compl. prayer 4

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

This case presents a classic dispute between patents describing functional components and the complex, integrated systems that perform those functions in modern consumer electronics. The outcome will likely depend on the answers to two central questions:

1. A core issue will be one of definitional scope: Can the term "electronic switch," which is illustrated in the patents with relatively simple hardware examples, be construed broadly enough to read on the software-based logic gates and state changes that occur within a highly integrated application processor or NFC controller in Samsung's smartphones?
2. A second key question will be one of operational mapping: Does the user-driven process of authenticating via a biometric sensor to unlock an application, which in turn enables NFC communication, satisfy the claim limitation of "activating the electronic switch... responsive to a biometric sensor"? The court will need to decide if this multi-step, software-mediated sequence is functionally equivalent to the more direct activation linkage contemplated by the patents.