DCT
2:26-cv-00338
Lepton Computing LLC v. Samsung Electronics Co Ltd
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lepton Computing LLC (Delaware)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff's Counsel: Capshaw DeRieux LLP
- Case Identification: 2:26-cv-00338, E.D. Tex., 04/23/2026
- Venue Allegations: Venue is alleged based on Defendant Samsung Electronics America, Inc. maintaining a regular and established place of business in the Eastern District of Texas, specifically a "flagship campus" in Plano, Texas. Venue for Samsung Electronics Co., Ltd. is asserted on the basis of it being a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant's foldable smartphone lines (Galaxy Z Fold, Z Flip, and Z TriFold) infringe nine patents related to flexible display configurations, hinge mechanisms, and graphical user interface transitions.
- Technical Context: The lawsuit concerns foldable smartphones, a premium segment of the mobile device market designed to offer expanded screen real estate within a compact, portable form factor.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of Plaintiff's technology and patent-pending status through business development discussions beginning in 2013. It further alleges knowledge via U.S. patent prosecution, where Plaintiff's parent application was cited by examiners against Defendant's own patent applications as early as 2013. These allegations form the basis for a claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2010-08-10 | Priority Date for all Asserted Patents (U.S. Prov. App. 61/372,391) |
| 2013-09-10 | Plaintiff's parent publication allegedly cited against a Samsung patent application |
| 2021-06-29 | U.S. Patent No. 11,048,299 ('299) Issues |
| 2021-06-29 | U.S. Patent No. 11,048,300 ('300) Issues |
| 2021-08-10 | U.S. Patent No. 11,086,361 ('361) Issues |
| 2021-08-17 | U.S. Patent No. 11,093,002 ('002) Issues |
| 2021-08-27 | Accused Products Samsung Galaxy Z Fold3 & Z Flip3 Released |
| 2021-12-28 | U.S. Patent No. 11,209,863 ('863) Issues |
| 2022-08-25 | Accused Products Samsung Galaxy Z Fold4 & Z Flip4 Released |
| 2022-12-06 | U.S. Patent No. 11,520,377 ('377) Issues |
| 2022-12-06 | U.S. Patent No. 11,520,378 ('378) Issues |
| 2023-07-04 | U.S. Patent No. 11,693,450 ('450) Issues |
| 2023-08-11 | Accused Products Samsung Galaxy Z Fold5 & Z Flip5 Released |
| 2024-07-10 | Accused Product Samsung Galaxy Z Flip6 Released |
| 2024-07-24 | Accused Product Samsung Galaxy Z Fold6 Released |
| 2024-11-12 | U.S. Patent No. 12,140,998 ('998) Issues |
| 2025-07-25 | Accused Products Samsung Galaxy Z Fold7 & Z Flip7 Released |
| 2026-01-30 | Accused Product Samsung Galaxy Z TriFold Released |
| 2026-04-23 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,048,299 - Graphical User Interface for Flexible Touch Screen Display Devices
The Invention Explained
- Problem Addressed: The patent describes the difficulty of using small-screen handheld devices, which can be "cumbersome to physically interact with," leading to "imprecise manipulation of features and text inputs" and reduced viewing capacity for media-rich applications '299 Patent, col. 1:36-44 Compl. ¶37
- The Patented Solution: The invention is a "reconfigurable touch screen computing device" that can transition from a compact phone-like state to an expanded tablet-like state '299 Patent, col. 2:15-25 It discloses a graphical user interface method to facilitate the transition of content between a principal (rigid) display and an auxiliary (flexible) display, for example by rescaling content to fit the screen's current configuration '299 Patent, abstract '299 Patent, Fig. 4
- Technical Importance: This technology addresses the fundamental design trade-off in mobile devices between portability and screen size by enabling a single device to serve as both a compact phone and a larger-screen tablet Compl. ¶15
Key Claims at a Glance
- The complaint asserts at least Claim 1 Compl. ¶77
- Independent Claim 1 of the '299 Patent includes these essential elements:
- An apparatus with a plurality of touch-sensitive displays, including at least one principal display (with a rigid segment) and at least one auxiliary display (with flexible segments) having a folded and an expanded state.
- A first touch-sensitive interface means for generating a first and second set of instructions.
- A second touch-sensitive interface means for generating a first and second set of instructions.
- A processor that, based on the first interface means, displays an image on the principal display (first instruction set) or removes it (second instruction set).
- The processor also, based on the second interface means, displays an image on the auxiliary display (first instruction set) or removes it (second instruction set).
U.S. Patent No. 11,048,300 - Flexible and Rigid Touch Screen Display Computing Devices
The Invention Explained
- Problem Addressed: As with the '299 Patent, this invention aims to overcome the limitations of small-screen devices by providing a way to expand the display size on demand '300 Patent, col. 1:36-47
- The Patented Solution: The patent discloses the mechanical and structural aspects of a reconfigurable handheld device. This includes a rigid touch-sensitive OLED display, a flexible touch-sensitive OLED display attached to structural supports, magnets for holding the device in a folded state, a flexible circuit to maintain electrical connection, and a hinge assembly with an aperture to accommodate the screen's folding radius '300 Patent, abstract '300 Patent, col. 5:47-6:6
- Technical Importance: The invention provides a detailed mechanical framework for creating a durable and functional foldable device, addressing key engineering challenges like hinge design, screen protection, and maintaining electrical connectivity across a fold Compl. ¶16
Key Claims at a Glance
- The complaint asserts at least Claim 1 Compl. ¶92
- Independent Claim 1 of the '300 Patent includes these essential elements:
- An apparatus with a rigid touch-sensitive OLED display.
- A flexible touch-sensitive OLED display attached to a first and a second structural support segment, capable of a fully folded state (<5 degrees), a fully expanded state (175-185 degrees), and partially expanded states.
- A first magnet on the first structural support and a second magnet on the second.
- A flexible circuit with traces electrically connecting the two segments.
- A magnetic sensor connected to the first structural support segment.
- A sleeve comprising a hinge assembly with slots and pins.
- An aperture between the structural support segments where the folding radius of the flexible display fits when in the fully folded state.
U.S. Patent No. 11,086,361 - Flexible and Rigid Touch Screen Display Computing Devices
- Patent Identification: U.S. Patent No. 11,086,361, issued August 10, 2021 Compl. ¶21
- Technology Synopsis: The patent discloses a handheld device with rigid and/or flexible OLED displays, magnets, sensors, a camera, microphone, speaker, and a flexible circuit. It features a sliding structural support and a hinge assembly that creates space for the flexible screen to fold within Compl. ¶22
- Asserted Claims: At least Claim 1 Compl. ¶111
- Accused Features: The complaint alleges infringement by the Accused Products' rigid cover displays, flexible inner displays, magnets, flexible circuits, cameras/microphones/speakers, and sliding hinge mechanisms Compl. ¶¶111-118
U.S. Patent No. 11,093,002 - Flexible Touch Screen Display Computing Devices
- Patent Identification: U.S. Patent No. 11,093,002, issued August 17, 2021 Compl. ¶23
- Technology Synopsis: The patent describes an apparatus with flexible/rigid displays reconfigurable into different states. It includes sensors to indicate the configuration state and a processor that uses the sensor signal to determine which screen to display an image on Compl. ¶24
- Asserted Claims: At least Claim 1 Compl. ¶131
- Accused Features: The infringement allegations focus on the Accused Products' dual-display setup (principal/cover and auxiliary/inner), integrated phone components (speaker/microphone), Hall sensors for state detection, and processor for controlling image display based on the sensor signal Compl. ¶¶131-136
U.S. Patent No. 11,209,863 - Magnetic Configurations for Flexible Display Computing Devices
- Patent Identification: U.S. Patent No. 11,209,863, issued December 28, 2021 Compl. ¶25
- Technology Synopsis: The patent discloses an apparatus with a foldable touch screen display having multiple segments, a magnetic component, and a touch-sensitive interface. The interface generates instructions for the processor to display an image on one of the flexible display segments Compl. ¶26
- Asserted Claims: At least Claim 1 Compl. ¶149
- Accused Features: Allegations target the Accused Products' foldable displays with multiple segments, integrated magnets, and the "multi-window" feature, which is alleged to be the claimed touch-sensitive interface for generating instructions to display content on different display segments Compl. ¶¶149-152
U.S. Patent No. 11,520,377 - Flexible Touch Screen Display Computing Devices
- Patent Identification: U.S. Patent No. 11,520,377 B2, issued December 6, 2022 Compl. ¶27
- Technology Synopsis: The patent describes an apparatus with a flexible touch-sensitive display attached to structural supports, a hinge connecting the supports, and an aperture to accommodate the flexible display's folding radius when in a fully folded configuration Compl. ¶28
- Asserted Claims: At least Claim 1 Compl. ¶165
- Accused Features: The complaint accuses the "Flex Hinge" of the Accused Products, which connects the structural segments and allows for multiple configurations (fully folded, fully expanded). The allegations also target the folding radius of the display and the aperture created by the hinge Compl. ¶¶165-167
U.S. Patent No. 11,520,378 - Flexible Display Computing Devices
- Patent Identification: U.S. Patent No. 11,520,378 B2, issued December 6, 2022 Compl. ¶29
- Technology Synopsis: This patent discloses an apparatus with a flexible touch-sensitive OLED display on structural supports, a magnetic sensor, multiple folding configurations, and an aperture for the display to fit within when fully folded Compl. ¶30
- Asserted Claims: At least Claim 1 Compl. ¶180
- Accused Features: Allegations focus on the flexible OLED display, magnetic Hall sensor, Flex Hinge enabling multiple configurations, and the aperture allowing the screen to fit within the device when folded Compl. ¶¶180-183
U.S. Patent No. 11,693,450 - Flexible Display Computing Devices
- Patent Identification: U.S. Patent No. 11,693,450 B2, issued July 4, 2023 Compl. ¶31
- Technology Synopsis: The patent describes an apparatus with a flexible OLED display, structural segments, a folding radius, multiple folding configurations, and an aperture allowing the display to fit within the device when fully folded Compl. ¶32
- Asserted Claims: At least Claim 1 Compl. ¶196
- Accused Features: Allegations are similar to those for the '377 and '378 patents, focusing on the flexible OLED display, the Flex Hinge enabling various folded/expanded configurations, and the folding radius/aperture mechanism Compl. ¶¶196-198
U.S. Patent No. 12,140,998 - Flexible Display Computing Devices
- Patent Identification: U.S. Patent No. 12,140,998 B2, issued November 12, 2024 Compl. ¶33
- Technology Synopsis: This patent discloses an apparatus with a flexible OLED display, structural segments, a folding radius, and at least a fully folded, fully expanded, and one partially expanded configuration Compl. ¶34
- Asserted Claims: At least Claim 1 Compl. ¶211
- Accused Features: Allegations target the Accused Products' flexible OLED display, Armor FlexHinge, and its ability to achieve fully folded, fully expanded, and partially expanded states (e.g., Flex Mode) Compl. ¶¶211-213
III. The Accused Instrumentality
Product Identification
The Samsung Galaxy Z Fold series (specifically Fold3, Fold4, Fold5, Fold6, and Fold7), the Samsung Galaxy Z Flip series (specifically Flip3, Flip4, Flip5, Flip6, and Flip7), and the Samsung Galaxy Z TriFold mobile smartphones (collectively, the "Accused Products") Compl. ¶42
Functionality and Market Context
The Accused Products are foldable smartphones featuring a smaller, rigid outer "cover" display and a larger, flexible inner display that is revealed when the device is unfolded Compl. ¶48 Compl. ¶57 A hinge mechanism connects the two halves of the device, allowing the inner screen to fold while creating an "aperture" for the screen to rest within Compl. ¶49 Compl. ¶58 The complaint alleges the devices use magnetic Hall Sensors to detect the folding state (e.g., folded, unfolded, or partially open "Flex Mode") and adjust the user interface accordingly Compl. ¶50 Compl. ¶59 The devices are positioned as premium, next-generation smartphones, with successive models released annually from 2021 to 2025 Compl. ¶¶43-47 Compl. ¶¶52-56 A diagram from the complaint shows the various modes of operation for a Z Fold device, including "Flex mode," "Tent view," and "Cover view" Compl. p. 16
IV. Analysis of Infringement Allegations
'299 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of touch-sensitive displays, including at least one principal display having at least one rigid display segment, and at least one auxiliary display having at least two flexible display segments, said auxiliary display having a folded state and an expanded state | The Accused Products have a rigid outer cover display (the "principal display") and an inner flexible main display (the "auxiliary display") that has folded and expanded states. | ¶77 | col. 2:15-25 |
| a first touch-sensitive interface means for generating a set of instructions... having a first set of instructions and a second set of instructions | The touch-sensitive interfaces of the products allegedly generate instructions. The complaint alleges a user "swipe" to move an image to the primary display corresponds to one set of instructions. | ¶78 | col. 17:11-20 |
| a processor to... display the image based on the set of instructions of the first touch-sensitive interface means, wherein when the first set of instructions is generated, the processor is to display the image substantially on the principal display, and when the second set of instructions is generated, the processor is to remove the image from the principle display | The processor displays an image on the principal (cover) display based on a user's touch input. A swipe gesture to remove the image allegedly corresponds to the second set of instructions. | ¶79 | col. 17:21-30 |
| a second touch-sensitive interface means for generating a set of instructions... having a first set of instructions and a second set of instructions | The touch-sensitive interfaces allegedly generate instructions for the auxiliary display. The complaint alleges a swipe to move an image to the auxiliary display corresponds to one set of instructions. | ¶78 | col. 17:31-38 |
| a processor to... display the image based on the set of instructions of the second touch-sensitive interface means, wherein when the first set of instructions is generated, the processor is to display the image substantially on the auxiliary display... | The processor displays an image on the auxiliary (inner) display based on user touch input. | ¶79 | col. 17:39-45 |
'300 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a rigid touch-sensitive OLED display | The Accused Products have a rigid touch-sensitive OLED display on their cover. A product image shows the outer display of the Z Flip and Z Fold models. | ¶92 | col. 1:49-51 |
| a flexible touch-sensitive OLED display... having a fully folded state... a fully expanded state, and partially expanded states | The flexible inner OLED display has folded, expanded, and partially expanded "Flex Mode" states. The complaint includes a diagram showing these various states. | ¶93 | col. 2:15-22 |
| a first magnet along the edge of the first structural support segment; [and] a second magnet along the edge of the second structural support segment | The products include multiple magnets along the edges of the structural support segments to hold the two sides together. | ¶94 | col. 3:35-39 |
| a flexible circuit comprising a plurality of traces wherein the traces provide an electrical connection between the first structural support segment and the second structural support segment | The products use a flexible circuit to electrically connect the two halves of the phone. | ¶95 | col. 2:17-18 |
| a magnetic sensor wherein the magnetic sensor is connected to the first structural support segment | The products have at least one magnetic Hall sensor within the edges of the structural support segments to sense the device's configuration. | ¶96 | col. 9:43-46 |
| a sleeve comprising a hinge assembly... wherein the hinge assembly further comprises: (1) a first slot associated with the first structural support segment; (2) a second slot... (3) a first pin engaged...; and (4) a second pin engaged... | The products include a hinge assembly with slots and pins. A complaint diagram shows a cross-section of the Z Fold6 and Z Fold7 hinges. | ¶97 | col. 14:7-12 |
| an aperture between the first structural support segment and the second structural support segment, wherein a folding radius of the flexible touch-sensitive OLED display fits within the aperture... | The products have an aperture between the primary and secondary structural supports where the screen fits when folded. A diagram shows the "rounder" aperture in newer models. | ¶98 | col. 12:50-57 |
Identified Points of Contention
- Scope Questions: A central question may be whether the terms "principal display" and "auxiliary display" in the '299 patent, which describes a phone-sized device with an unfolding screen, can be construed to read on the Accused Products' "cover screen" and "main screen" configuration. Similarly, for the '300 patent, the court may need to resolve whether the space created by Defendant's hinge mechanism constitutes an "aperture" where the display "fits within," as contemplated by the patent.
- Technical Questions: For the '299 patent, a key question is whether a single user action, like swiping an application between screens, constitutes the separate "first and second touch-sensitive interface means" generating distinct "sets of instructions" as required by the claim language. For the '300 patent, the analysis will likely focus on whether the specific components of Defendant's "Flex Hinge," as depicted in teardowns and diagrams (Compl. p. 14; Compl. p. 35), meet the structural limitations of the claimed "sleeve comprising a hinge assembly."
V. Key Claim Terms for Construction
"principal display" and "auxiliary display" ('299 Patent, Claim 1)
- Context and Importance: The distinction and relationship between these two displays are fundamental to the infringement theory for the '299 patent. Practitioners may focus on this term because the patent's description of a "compact state" phone with an "expanded state" tablet screen could be argued to differ from the accused Z Fold, which is a phone-like device when closed and a tablet-like device when open.
- Intrinsic Evidence for a Broader Interpretation: The specification describes a "reconfigurable touch screen computing device" that can change from a "compact state to an expanded state," language that could be argued to broadly cover any device with this transformative capability, regardless of which screen is considered "principal" '299 Patent, col. 2:15-22
- Intrinsic Evidence for a Narrower Interpretation: The abstract describes the compact state as the "size of a handheld phone" and the expanded state as the "size of a tablet computer," which may support an argument that the "principal display" is the one used in the primary phone-sized configuration '299 Patent, abstract The figures may also depict a specific arrangement that could be used to narrow the scope of these terms '299 Patent, Fig. 1a
"aperture" ('300 Patent, Claim 1)
- Context and Importance: The existence and nature of the "aperture" are critical for infringement of the '300 patent. The dispute will likely center on whether the teardrop-shaped space created by the folding of the screen in the accused devices qualifies as the claimed "aperture."
- Intrinsic Evidence for a Broader Interpretation: The patent does not appear to provide an explicit, limiting definition of "aperture," which may support an argument that any opening or gap that accommodates the screen's folding radius meets the limitation Compl. ¶41
- Intrinsic Evidence for a Narrower Interpretation: Embodiments and figures in the patent could be argued to disclose a specific type of opening or gap, which a defendant might contend is structurally different from the space created by its hinge. The complaint itself includes diagrams showing the evolution of this space in Samsung's products, suggesting its specific geometry is a point of technical focus Compl. p. 35 Compl. p. 52
VI. Other Allegations
Indirect Infringement
While no separate count for indirect infringement is pleaded, the complaint alleges facts that may support such a claim. It states that Defendant's user manuals, developer guides, and marketing materials instruct and encourage users to perform allegedly infringing acts, such as using "Flex mode," multi-window features, and application continuity between the two screens Compl. ¶49 Compl. ¶51 Compl. ¶78
Willful Infringement
The complaint alleges willful infringement for all asserted patents. This is based on allegations of both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged to stem from business meetings between Plaintiff and senior Samsung executives beginning in 2013, where Plaintiff's technology and patent-pending status were allegedly disclosed Compl. ¶66 Knowledge is also alleged through U.S. patent prosecution, where Plaintiff's parent publication was cited against at least six of Defendant's own patent applications, with one such citation occurring as early as 2013 Compl. ¶¶67-68
VII. Analyst's Conclusion: Key Questions for the Case
This case presents a comprehensive challenge to a major product line, turning on several key technical and legal questions for the court.
- A core issue will be one of definitional scope: can the claim terms from a patent family with a 2010 priority date, such as "principal display" and "aperture," be construed to cover the specific screen configurations and advanced hinge mechanisms implemented in Defendant's modern foldable smartphones?
- A second central question will be one of technical and functional mapping: does the operation of Defendant's user interface, such as the "Flex Mode" and "App Continuity" features, perform the specific functions in the manner required by the patent claims, or is there a fundamental mismatch between the claimed methods and the accused software's actual operation?
- Finally, a significant question for damages will concern willfulness: can Plaintiff prove its specific allegations of Defendant's pre-suit knowledge, based on 2013 business meetings and citations in patent prosecution, to establish that any infringement was willful, deliberate, and egregious?
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