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; Carr & Ferrell LLP
• 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 are subject to personal jurisdiction, have regularly conducted business in the district, and Samsung Electronics America, Inc. maintains a regular and established place of business in Plano, Texas, within the district.
• Core Dispute: Plaintiff alleges that Defendant's smartphones, wearables, and mobile computing devices, along with associated software like Samsung Pay, infringe six U.S. patents related to secure mobile financial transactions using features such as inductive antennas, electronic switches, and biometric or PIN-based authentication.
• Technical Context: The patents address foundational technologies for enabling secure, user-authenticated transactions on mobile devices, a domain that has become central to the functionality of modern smartphones and mobile payment ecosystems.
• Key Procedural History: This First Amended Complaint was filed to include an Appendix that was mistakenly omitted from the original complaint. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the Asserted Patents.

Case Timeline

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

U.S. Patent No. 7,924,156 - "Electronically switchable RFID Tags," Issued April 12, 2011

The Invention Explained

• Problem Addressed: The complaint suggests that at the time of the invention, technologies like Radio Frequency Identification (RFID) presented a security challenge, as early mobile phones did not support authenticated financial transactions, creating a risk of unauthorized access to sensitive information stored on RFID tags Compl. ¶29 '949 Patent, col. 1:26-29
• The Patented Solution: The patent describes an RFID tag with a physical, user-operated mechanical switch Compl. ¶32 This switch allows a user to select between different "ON" states, which in turn controls whether the RFID tag will transmit its radio frequency (RF) signal Compl. ¶32 Compl. ¶34 This provides a physical method for a user to enable or disable the RFID tag's communication capabilities, thereby preventing unauthorized reading.
• Technical Importance: The invention provided a direct, user-controlled security mechanism for RFID-based data transmission before more complex, software-integrated authentication methods became widespread in mobile devices Compl. ¶¶27-29

Key Claims at a Glance

• The complaint asserts at least independent claim 20 Compl. ¶¶34, 65-66
• Claim 20 requires, in summary:
  • An RFID tag comprising:
  • A "mechanical switch" configured for selecting between two or more ON states of the RFID tag;
  • An antenna for receiving and transmitting RF signals; and
  • Integrated circuitry with switch logic configured to determine whether to transmit a signal based on the state of the mechanical switch or a stored state memory.
• The complaint also asserts dependent claims 24, 25, 29, 32, 34, 37, 57, and 58, and method claim 60 Compl. ¶66

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 RFID tags being read by any nearby reader, which creates privacy and security vulnerabilities for electronic tracking and information storage '949 Patent, col. 1:22-29
• The Patented Solution: The patent describes a cellular telephone that incorporates an "electronic switch" into a circuit with an inductive coupling (e.g., an NFC antenna) '949 Patent, abstract Compl. ¶37 The state of this electronic switch, which can be tied to user authentication like a PIN or biometric input, controls whether the device communicates wirelessly for financial transactions Compl. ¶35 This solution moves the control from a simple mechanical switch to a more sophisticated electronic switch integrated within the phone's circuitry and logic.
• Technical Importance: This technology represents a step toward integrating authentication logic (like PINs or biometrics) directly with the hardware (the inductive antenna circuit) used for mobile payments, enhancing security over a simple, always-on transmitter Compl. ¶35

Key Claims at a Glance

• The complaint asserts at least independent claims 1 and 30 Compl. ¶¶37, 80-81
• Claim 1 requires, in summary:
  • 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 the circuit's states; and
  • The circuit is configured to communicate via the inductive coupling responsive to the circuit's states.
• The complaint also asserts dependent claims 2-8, 10-12, 14-24, and 26-29 Compl. ¶81

Multi-Patent Capsule

• U.S. Patent No. 11,599,734, "Methods of Inductive Communication in a Cellular Telephone," Issued March 7, 2023

  • Technology Synopsis: This patent claims methods for performing financial transactions by placing a cellular phone near a point-of-sale device. The method involves activating an electronic switch to change the state of an inductive coupling circuit and communicating financial account information responsive to that state Compl. ¶¶38, 40
  • Asserted Claims: Independent claims 1, 15, and 23 are asserted Compl. ¶95
  • Accused Features: The complaint alleges that the use of Samsung's mobile devices to conduct transactions via Samsung Pay or other payment applications infringes these method claims Compl. ¶¶53, 56, 95

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

  • Technology Synopsis: This patent claims methods for performing financial transactions where the activation of an electronic switch is responsive to a biometric sensor on the cellular phone. This activation changes the circuit's state and allows financial information to be communicated via an inductive coupling or an RF antenna Compl. ¶¶41, 43
  • Asserted Claims: Independent claims 1 and 19 are asserted Compl. ¶110
  • Accused Features: The use of biometric sensors (e.g., fingerprint readers) on Samsung devices to authenticate and execute mobile payments is alleged to infringe these method claims Compl. ¶¶50, 56, 110

• U.S. Patent No. 11,989,612, "Cellular Telephone Including Biometric Sensor," Issued May 21, 2024

  • Technology Synopsis: Similar to the '741 Patent, this patent claims methods for performing a financial transaction where activation of an electronic switch is responsive to a biometric sensor. This changes the state of an inductive coupling circuit to facilitate the transaction Compl. ¶¶44, 46
  • Asserted Claims: Claims 1-5 are asserted Compl. ¶¶125-126
  • Accused Features: The use of biometric sensors on Samsung devices to authorize mobile payments via inductive antenna (NFC) is alleged to infringe these method claims Compl. ¶¶50, 56, 125

• U.S. Patent No. 12,039,396, "Cellular Telephone Including Biometric Control of Transactions," Issued July 16, 2024

  • Technology Synopsis: This patent claims a cellular phone configured with circuits for both cellular (first wireless mode) and short-range (second wireless mode) communication. The device includes a biometric sensor to approve financial transactions and an inductive antenna for communication in the second mode Compl. ¶¶47, 49 It also includes claims directed to using a phone to open locks or unlock a car Compl. ¶47
  • Asserted Claims: Claims 1-17 and 19-20 are asserted Compl. ¶¶140-141
  • Accused Features: Samsung smartphones that operate on cellular networks while also using NFC for biometrically-authenticated transactions are alleged to infringe Compl. ¶¶50, 56, 140 The complaint also accuses functionality in apps like SmartThings and Samsung Wallet's digital key feature for infringing claims related to lock and car operation Compl. ¶¶57, 142

III. The Accused Instrumentality

Product Identification

The complaint names a broad set of "Accused Instrumentalities," including a wide range of Samsung Galaxy smartphones (e.g., S, Note, Z Fold/Flip, and A series), wearables (e.g., Galaxy Watch), and tablets (e.g., Galaxy Tab) Compl. ¶¶51-52 Compl. ¶58 The allegations also extend to software, including the Samsung Pay application (now part of Samsung Wallet), the Samsung Blockchain Wallet, and application stores like the Google Play store and Samsung Galaxy Store that distribute payment and remote access applications Compl. ¶¶53-55

Functionality and Market Context

The accused devices are alleged to be configured to engage in mobile transactions using Near-Field Communication (NFC) Compl. ¶¶51, 56 The complaint highlights features such as biometric sensors and PIN-based authentication for authorizing these transactions Compl. ¶26a The complaint references promotional images of recent Samsung smartphone models, such as the Galaxy Z Fold7 and Galaxy S25 Ultra, as representative examples of devices configured for mobile transactions Compl. ¶51 The complaint asserts that these products generate substantial revenue for the Defendants, suggesting significant commercial importance Compl. ¶64

IV. Analysis of Infringement Allegations

The complaint states that claim charts are provided in an appendix, but this appendix was not included in the provided document Compl. ¶31 Compl. ¶p. 43 The infringement theory is therefore summarized from the complaint's narrative allegations.

Narrative Infringement Summary

• '156 Patent (Claim 20): The complaint alleges that Defendants' devices infringe by incorporating the claimed features, which include a "mechanical switch" for approving transactions Compl. ¶26e Compl. ¶66 The complaint does not specify which physical component on the accused smartphones constitutes the claimed "mechanical switch."
• '949 Patent (Claim 1): The complaint alleges that Samsung's cellular devices utilize an "inductive coupling" (NFC antenna) as part of a circuit containing an "electronic switch" Compl. ¶37 The theory suggests that when a user authenticates a transaction (e.g., with a fingerprint or PIN), this action serves to activate the electronic switch, change the circuit's state, and enable the communication of financial account information to a point-of-sale terminal, thereby practicing the claimed invention Compl. ¶35 Compl. ¶¶80-81

Identified Points of Contention

• Scope Questions: The infringement analysis for the '156 Patent may raise the question of whether a multi-purpose physical button on a smartphone (e.g., a power or volume button), which requires software interaction to affect a transaction, meets the claim limitation of a "mechanical switch configured for selecting between two or more ON states of the RFID tag." For the '949 Patent and related patents, a central question may be whether the software-driven authentication process that enables NFC functionality in the accused devices constitutes an "electronic switch" as that term is used in the patents.
• Technical Questions: A key technical question for the '156 Patent will be what evidence Plaintiff provides to show that a physical button on an accused Samsung device directly or indirectly performs the specific function of selecting an "ON state" for the RFID/NFC circuit, as required by the claim.

V. Key Claim Terms for Construction

• The Term: "mechanical switch" (from '156 Patent, Claim 20)

  • Context and Importance: This term is critical because modern smartphones do not have a dedicated mechanical toggle for enabling or disabling NFC/RFID functionality. Practitioners may focus on this term because the viability of the infringement claim for the '156 Patent may depend on construing "mechanical switch" broadly enough to read on a general-purpose button (e.g., a power or side button) that initiates a software-based state change.
  • Intrinsic Evidence for Interpretation (from related '949 Patent specification):
    • Evidence for a Broader Interpretation: The specification discloses various types of switches, suggesting the term is not limited to a single form. For example, it describes how the opening and closing of a clamshell phone can function as a switch, indicating a broad functional definition '949 Patent, col. 12:4-10
    • Evidence for a Narrower Interpretation: The specification includes embodiments showing distinct physical switches, such as a "sliding switch," a "flip switch," and a "membrane switch," which could be used to argue for a construction limited to such physically distinct, user-actuated components '949 Patent, col. 25:20-22 '949 Patent, Figs. 25A, 26A

• The Term: "electronic switch" (from '949 Patent, Claim 1)

  • Context and Importance: The infringement theory for the '949 Patent and its successors relies on mapping this term to the process of user authentication (e.g., via biometrics) that enables a mobile payment. Practitioners may focus on this term because its construction will determine whether a complex, software-mediated process qualifies as the claimed "switch," or if the term requires a more discrete, hardware-based component.
  • Intrinsic Evidence for Interpretation ('949 Patent):
    • Evidence for a Broader Interpretation: The claims link the "electronic switch" to being "responsive to a biometric sensor" (e.g.,'949 Patent, cl. 29) or a PIN (e.g.,'949 Patent, cl. 21), which supports an interpretation where software and processing logic are part of the "switch" functionality. The patent describes the switch functionally as being "configured to change between states of the circuit" '949 Patent, col. 44:2-3
    • Evidence for a Narrower Interpretation: Figures in the patent depict switches as discrete circuit elements (e.g.,'949 Patent, Fig. 23, element 2270), which could support an argument that the term refers to a specific electronic component like a transistor that opens or closes a circuit path, rather than a multi-step software process.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all asserted patents. The inducement allegations are based on Defendants' activities such as providing user instructions, advertising infringing uses, and promoting the installation of payment applications Compl. ¶70 Compl. ¶85 The contributory infringement allegations are based on Defendants providing the essential hardware (e.g., NFC antennae, biometric sensors) and software platforms (e.g., operating systems, app stores) for the infringing activity Compl. ¶72 Compl. ¶87

Willful Infringement

The complaint does not use the word "willful" in its counts but seeks treble damages for willful infringement in the prayer for relief Prayer for Relief ¶4 The allegations state that Defendants had knowledge of the patents and infringement at least as of the date of service of the complaint, forming a basis for post-suit willfulness Compl. ¶63 Compl. ¶78 Compl. ¶93 Compl. ¶108 Compl. ¶123 Compl. ¶138 No facts alleging pre-suit knowledge are presented.

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

• A core issue will be one of definitional scope: can the term "mechanical switch," as claimed in the earliest asserted patent, be construed to cover a general-purpose button on a modern smartphone that triggers a software function? Similarly, can the term "electronic switch" from the later patents be construed to encompass a complex, multi-step, software-and-hardware authentication process like a fingerprint scan that enables an NFC transaction?
• A second central issue will be one of technological evolution: do the systems described in patents with a 2005 priority date, which contemplate discrete switches and state changes, map onto the integrated and software-heavy architecture of modern mobile payment systems like Samsung Pay? The case may turn on whether the accused functionality represents a fundamentally different mode of operation or is merely an evolution of the claimed inventions.
• A key evidentiary question will be one of causation for indirect infringement: what specific instructions, advertisements, or other affirmative acts by Samsung will the Plaintiff present as evidence that Samsung possessed the specific intent to encourage its users to infringe the specific methods claimed in the patents, beyond merely providing general mobile payment functionality?