DCT

2:26-cv-00356

Omni MedSci Inc v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00356, E.D. Tex., 05/01/2026
  • Venue Allegations: Venue is alleged to be proper for the foreign parent company, Samsung Electronics, Co., Ltd., under 28 U.S.C. § 1391(c)(3). For the domestic subsidiaries, Samsung Electronics America, Inc. and Samsung Semiconductor, Inc., venue is alleged to be proper under 28 U.S.C. § 1400(b) based on their purported sales activities and regular and established places of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones and extended reality (XR) headsets, which incorporate time-of-flight (ToF) remote sensing systems, infringe a portfolio of eight U.S. patents.
  • Technical Context: The technology involves using near-infrared laser systems to perform time-of-flight measurements for applications such as 3D imaging, laser-assisted camera autofocus, and physiological sensing in portable electronic devices.
  • Key Procedural History: All eight asserted patents claim priority to a set of provisional applications filed on December 31, 2012. The complaint details extensive pre-suit communications, starting in 2017, between Plaintiff’s principal, Dr. Mohammed Islam, and various representatives of the Samsung defendants, during which Plaintiff’s technology and specific patents were allegedly disclosed.

Case Timeline

Date Event
2012-12-31 Earliest Priority Date for all Asserted Patents
2017-04-10 Plaintiff's principal allegedly meets with a Samsung executive
2017-07-17 Plaintiff's principal allegedly participates in a virtual meeting with a Samsung Senior Manager
2018-11-13 U.S. Patent No. 10,126,283 Issues
2021-08-26 Plaintiff's principal allegedly presents technology to Samsung's automotive division
2021-10-22 Plaintiff allegedly identifies the ’283 and future ’156 patents to Samsung
2022-02-08 U.S. Patent No. 11,241,156 Issues
2023-03-02 Plaintiff allegedly identifies the '283, '156, and future ’311 patents to Samsung
2023-03-07 U.S. Patent No. 11,596,311 Issues
2023-06-20 U.S. Patent No. 11,678,805 Issues
2024-05-28 U.S. Patent No. 11,992,291 Issues
2025-09-30 U.S. Patent No. 12,426,788 Issues
2026-03-31 U.S. Patent No. 12,588,820 Issues
2026-04-14 U.S. Patent No. 12,599,305 Issues
2026-05-01 Complaint Filed

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

U.S. Patent No. 10,126,283 - "Near-Infrared Time-Of-Flight Imaging"

  • Patent Identification: U.S. Patent No. 10,126,283, "Near-Infrared Time-Of-Flight Imaging," issued November 13, 2018.

The Invention Explained

  • Problem Addressed: The patent describes challenges in performing spectroscopy in the short-wave infrared (SWIR) spectrum, particularly for remote sensing, due to factors like reliance on sunlight, which can be obscured by weather or is unavailable at night ('283 Patent, col. 2:1-12).
  • The Patented Solution: The invention is a system, embodied in a smart phone or tablet, that uses an active light source—an array of laser diodes—pulsed in the near-infrared spectrum (700-2500 nm). This light is directed at a sample, and a photodiode array (e.g., CMOS-based) detects the reflection. By measuring the time difference between the pulse emission and detection, the system performs a "time-of-flight" measurement to create a 2D or 3D image ('283 Patent, abstract). To improve the signal-to-noise ratio, the system captures a signal with the laser off and another with the laser on, and then calculates the difference, effectively subtracting out ambient light noise ('283 Patent, col. 33:38-47).
  • Technical Importance: The technology aimed to integrate active, reliable time-of-flight imaging capabilities into ubiquitous portable devices like smartphones, which was not purely conventional at the time of invention (Compl. ¶53).

Key Claims at a Glance

  • The complaint asserts at least claims 7 and 13-15 (Compl. ¶166). The primary independent claims are 1, 7, and 16. Claim 7 depends on Claim 1.
  • The essential elements of independent claim 1 include:
    • A smart phone or tablet.
    • An array of laser diodes generating near-infrared light (700-2500 nm).
    • Lenses to direct the light to a sample.
    • A detection system with a CMOS photodiode array.
    • The detection system is configured to perform a time-of-flight measurement by measuring the time difference between emitted and reflected light.
    • The system is configured to take a first signal with the laser off and a second signal with the laser on.
    • The smart phone or tablet is configured to difference the two signals to generate a 2D or 3D image.
  • The complaint reserves the right to assert additional claims (Compl. ¶167).

U.S. Patent No. 11,241,156 - "Time-of-Flight Imaging and Physiological Measurements"

  • Patent Identification: U.S. Patent No. 11,241,156, "Time-of-Flight Imaging and Physiological Measurements," issued February 8, 2022.

The Invention Explained

  • Problem Addressed: The patent background focuses on the growing need for non-invasive monitoring of blood constituents, such as glucose for diabetes management, and the inadequacy and inconvenience of then-current methods that require drawing blood ('156 Patent, col. 3:5-24).
  • The Patented Solution: The patent describes a remote sensing system that uses a specific type of laser array featuring "Bragg reflectors" to generate modulated, near-infrared light pulses of a very short duration (0.5-2 nanoseconds) at a high repetition rate (several Megahertz) ('156 Patent, abstract; Compl. ¶61). The system architecture includes a beam splitter, a photodiode detector array, and a coupled camera system, all integrated with a processor in a device like a smartphone ('156 Patent, col. 8:59-col. 9:15). This configuration is designed to non-invasively measure physiological parameters within tissue.
  • Technical Importance: The invention describes a specific hardware configuration intended to enable sophisticated, non-invasive physiological monitoring using consumer electronic devices, a significant advancement in personal health technology (Compl. ¶61).

Key Claims at a Glance

  • The complaint asserts at least claims 16 and 17 (Compl. ¶177). Claim 16 is an independent claim.
  • The essential elements of independent claim 16 include:
    • A remote sensing system.
    • An array of laser diodes generating near-infrared light (700-2500 nm).
    • The laser diode array comprises one or more Bragg reflectors.
    • The laser diodes are modulated with a pulsed output of approximately 0.5-2 ns duration and a pulse repetition rate of several Megahertz.
    • The array is coupled to driver electronics, safety shut-offs, and a thermal management accessory.
    • A beam splitter.
    • A detection system with a photodiode array, lenses, and spectral filters.
    • A camera system coupled to a lens system and a processor.
  • The complaint reserves the right to assert additional claims (Compl. ¶178).

U.S. Patent No. 11,596,311 - "Remote Sensing and Measurement System Using Time-of-Flight Detectors"

  • Patent Identification: U.S. Patent No. 11,596,311, "Remote Sensing and Measurement System Using Time-of-Flight Detectors," issued March 7, 2023 (Compl. ¶67).
  • Technology Synopsis: This patent describes a system for non-invasively measuring physiological parameters in tissue, such as oxy- or deoxy-hemoglobin in blood vessels (Compl. ¶75). The system is configured to measure a phase shift and a time-of-flight of light reflected from the tissue to determine these parameters (Compl. ¶74).
  • Asserted Claims: At least claims 15, 16, and 19 (Compl. ¶188).
  • Accused Features: The laser AF features of the Samsung Smartphones (Compl. ¶188).

U.S. Patent No. 11,678,805 - "Active Remote Sensing System Using Time-of-Flight Sensor Combined With Cameras and Wearable Devices"

  • Patent Identification: U.S. Patent No. 11,678,805, "Active Remote Sensing System Using Time-of-Flight Sensor Combined With Cameras and Wearable Devices," issued June 20, 2023 (Compl. ¶80).
  • Technology Synopsis: This patent covers an active remote sensing system that combines a time-of-flight measurement with images from a camera. The system is specifically claimed as being coupled to a "wearable device, a smart phone, or a tablet" (Compl. ¶88).
  • Asserted Claims: At least claims 1-4 (Compl. ¶199).
  • Accused Features: The laser AF features of the Samsung Smartphones (Compl. ¶199).

U.S. Patent No. 11,992,291 - "Identifying Objects Using Near-Infrared Sensors, Cameras or Time-of-Flight Detectors"

  • Patent Identification: U.S. Patent No. 11,992,291, "Identifying Objects Using Near-Infrared Sensors, Cameras or Time-of-Flight Detectors," issued May 28, 2024 (Compl. ¶92).
  • Technology Synopsis: This patent describes a remote sensing system that uses a beam splitter to create a "sample arm light" directed to an object and a "received reference arm light" (’291 Patent, abstract). It performs a time-of-flight measurement by comparing a sample detector signal with the reference detector signal to identify an object or measure a property (Compl. ¶¶99-100).
  • Asserted Claims: At least claims 1, 5, 8, and 9 (Compl. ¶210).
  • Accused Features: The laser AF features of the Samsung Smartphones (Compl. ¶210).

U.S. Patent No. 12,426,788 - "Active Remote Sensing of Atmospheric Gases or Smoke Using a Time-of-Flight Sensor"

  • Patent Identification: U.S. Patent No. 12,426,788, "Active Remote Sensing of Atmospheric Gases or Smoke Using a Time-of-Flight Sensor," issued September 30, 2025 (Compl. ¶104).
  • Technology Synopsis: This patent covers a remote sensing system with two photodiode arrays. One array receives a reference arm light and the other a sample arm light. The processor is configured to improve the signal-to-noise ratio by comparing signals generated when the laser is on versus off (Compl. ¶¶112-113).
  • Asserted Claims: At least claims 1 and 5 (Compl. ¶221).
  • Accused Features: The laser AF features of the Samsung Smartphones (Compl. ¶221).

U.S. Patent No. 12,588,820 - "Wearable Device for Differential Measurement on Pulse Rate and Blood Flow"

  • Patent Identification: U.S. Patent No. 12,588,820, "Wearable Device for Differential Measurement on Pulse Rate and Blood Flow," issued March 31, 2026 (Compl. ¶117).
  • Technology Synopsis: This patent claims a measurement system adapted to be worn by a user. It includes laser diodes, a photodiode array, and first and second cameras, and combines time-of-flight measurements with captured images to create a combined portion (Compl. ¶¶124-126).
  • Asserted Claims: At least claims 9 and 10 (Compl. ¶232).
  • Accused Features: The Samsung XR Headsets that perform dToF to measure distance (Compl. ¶¶163, 232).

U.S. Patent No. 12,599,305 - "3D Cameras or Sensors Inputting to Multi-Modal Generative Artificial Intelligence Models Trained on Images or Videos"

  • Patent Identification: U.S. Patent No. 12,599,305, "3D Cameras or Sensors Inputting to Multi-Modal Generative Artificial Intelligence Models Trained on Images or Videos," issued April 14, 2026 (Compl. ¶131).
  • Technology Synopsis: This patent describes a system where sensor data, including time-of-flight measurements, is fed as input to a "multi-modal generative artificial intelligence model" (Compl. ¶140). The model, which may comprise a vision transformer, analyzes the input to perform tasks like anomalous occurrence detection (Compl. ¶140).
  • Asserted Claims: At least claims 1-7 (Compl. ¶243).
  • Accused Features: The Samsung XR Headsets that perform dToF (Compl. ¶¶163, 243).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Samsung smartphones and extended reality (XR) headsets (Compl. ¶¶161, 163). Specific smartphone models identified include the Galaxy Note 20 Ultra, the Galaxy S21 Ultra, the Galaxy S22 Ultra, the Galaxy S23 Ultra, the Galaxy S24 Ultra, and the Galaxy S26 Ultra (Compl. ¶161). The specific headset identified is the Samsung Galaxy XR (Compl. ¶163).

Functionality and Market Context

  • The complaint alleges that the accused smartphones incorporate a "laser autofocus (laser AF)" feature (Compl. ¶161). This feature is described as a direct time-of-flight (dToF) system that emits laser light and measures the time for the reflected light to return to a sensor, thereby calculating the distance to a subject to achieve rapid and accurate autofocus (Compl. ¶162).
  • The Samsung XR Headset is alleged to perform a similar dToF sensing function by emitting light pulses and measuring their return time (Compl. ¶164). This capability is used to enable spatial awareness, depth mapping, and interaction with the user's surroundings (Compl. ¶164).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts attached as exhibits, which were not provided for this analysis. Therefore, the infringement allegations are summarized in prose based on the complaint's narrative.

  • '283 Patent Infringement Allegations: The complaint alleges that the laser AF feature in Samsung's smartphones infringes claims of the '283 patent (Compl. ¶166). The core of the allegation is that the smartphones' ToF sensor functions as a system with a near-infrared laser diode array, a CMOS photodiode detector, and a processor that performs a time-of-flight measurement to create a 3D image (or depth map) used for autofocus, directly corresponding to the elements of claim 1 (Compl. ¶¶50, 162). The complaint does not specify how the accused products perform the signal differencing (laser on vs. laser off) element of claim 1.

  • '156 Patent Infringement Allegations: The infringement theory for the '156 patent also targets the laser AF feature in Samsung smartphones (Compl. ¶177). The complaint alleges these devices embody the claimed remote sensing system, which includes a modulated, pulsed laser array with specific pulse durations and repetition rates, a beam splitter, a detector, and a camera system (Compl. ¶¶64, 177). The applicability of elements like "Bragg reflectors" and the specific pulse characteristics to the accused devices is asserted but not detailed in the complaint's main body.

  • Identified Points of Contention:

    • Scope Questions: A central question for many of the asserted patents will be whether the general-purpose "laser AF" or "dToF" functionality in Samsung's consumer products falls within the scope of claims that describe more specific applications, such as "physiological measurements" ('156 patent) or sensing "atmospheric gases" (’788 patent). The court will need to determine if the claims are limited to their exemplary embodiments or cover the broader underlying ToF technology.
    • Technical Questions: For the '283 patent, a key question will be whether the accused devices perform the specific "differencing" of signals (laser-on vs. laser-off) as required by claim 1. For the '156 patent, a critical factual question is whether the laser diodes in Samsung's devices actually contain "Bragg reflectors" and operate at the specific pulse durations and repetition rates recited in claim 16.

V. Key Claim Terms for Construction

  • U.S. Patent No. 10,126,283:

    • The Term: "a smart phone or tablet"
    • Context and Importance: This term appears in the preamble of the independent claims and is critical for defining the scope of the device itself. Samsung might argue its XR Headset is not "a smart phone or tablet," potentially avoiding infringement of this patent for that product line.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification frequently refers to coupling the system to a "computer," "smart phone," or "tablet" interchangeably, suggesting the term is not meant to be restrictive but rather an example of a portable computing device with a display (e.g., '283 Patent, col. 20:64-67). Plaintiff may argue "tablet" can encompass a head-mounted display device.
      • Evidence for a Narrower Interpretation: The claims consistently and exclusively recite "smart phone or tablet." The abstract and summary explicitly frame the invention in this context ('283 Patent, abstract; '283 Patent, col. 2:35-37). Defendant may argue that if the inventor intended to cover other devices like headsets, the claims would have said so.

  • U.S. Patent No. 11,241,156:

    • The Term: "Bragg reflectors"
    • Context and Importance: This is a specific hardware limitation in independent claim 16. Whether the laser arrays in Samsung's devices include this specific component will be a determinative issue for literal infringement. It is a highly technical term that suggests a particular physical structure.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The plaintiff might argue that any wavelength-selective feedback mechanism within the laser diode that performs the function of a Bragg reflector meets the claim limitation, even if not explicitly named as such by Samsung.
      • Evidence for a Narrower Interpretation: The specification mentions "Distributed Bragg Reflector (DBR) lasers" as an example of a laser diode type ('156 Patent, col. 30:25-27). Practitioners may focus on this term because it is a potential bright-line distinction; defendants will likely argue this requires a specific, layered, periodic structure common to DBRs and that alternative laser technologies do not meet this limitation.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges both induced and contributory infringement. The inducement allegations are based on Samsung providing user manuals, technical support, marketing materials, and other instructions that allegedly direct end-users to operate the accused devices (e.g., the camera's laser AF) in an infringing manner (e.g., Compl. ¶171; Compl. ¶182). The contributory infringement allegations assert that the accused ToF hardware and software components are not staple articles of commerce and are specially adapted for infringing the patents (e.g., Compl. ¶173; Compl. ¶184).
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents, based on both pre- and post-suit knowledge. The allegations of pre-suit knowledge are detailed, citing a multi-year history of meetings and communications between Plaintiff's founder and Samsung personnel, during which the patented technology was allegedly discussed and specific patents were identified (Compl. ¶¶145-160). Post-suit willfulness is based on Samsung's continued alleged infringement after the filing of the complaint (e.g., Compl. ¶175).

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

  • A primary issue will be one of evidentiary proof: can Plaintiff demonstrate that the internal components of Samsung's mass-market consumer devices, particularly the laser arrays and photodetectors, contain the specific structures (e.g., "Bragg reflectors") and operate according to the specific methods (e.g., signal "differencing," specific pulse durations) recited in the various claims?
  • A second core issue will be one of claim scope: will the court construe claims mentioning specific applications, such as "physiological measurements" or "atmospheric gas" sensing, as being limited to those fields, or will the claims be interpreted more broadly to cover the fundamental time-of-flight technology allegedly used in Samsung's general-purpose camera autofocus and spatial awareness systems?
  • A third critical question will center on knowledge and intent: given the extensive pre-suit communications alleged in the complaint, the court will need to evaluate the substance of those discussions to determine if Samsung had actual knowledge of the patents and acted with the requisite intent to support the claims for willful and indirect infringement.
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