Tasktime Texas LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TaskTime Texas LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff's Counsel: Fabricant, Rubino & Lambrianakos LLP
• Case Identification: 2:26-cv-00436, E.D. Tex., 05/28/2026
• Venue Allegations: Venue is alleged to be proper based on Defendants having a regular and established place of business within the Eastern District of Texas and having committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that the Samsung Reminder application, when integrated with the Samsung Calendar application on Defendant's electronic devices, infringes three patents related to systems and methods for calendar-based task and time management.
• Technical Context: The technology concerns the software-based integration of task management ("to-do lists") with electronic calendars, aiming to improve computational efficiency through rules-based organization, filtering, and dynamic scheduling of tasks.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent family since at least June 10, 2019, when the application for the lead patent was cited as a reference by the USPTO during the prosecution of one of Defendant's own patent applications. This allegation forms the basis for the willfulness claim.

Case Timeline

Date	Event
2011-03-15	Earliest Priority Date for '260, '523, and '638 Patents
2017-05-23	U.S. Patent No. 9,659,260 Issues
2019-06-10	Date of alleged notice to Samsung of the '260 Patent via patent prosecution file
2021-07-27	U.S. Patent No. 11,074,523 Issues
2024-07-02	U.S. Patent No. 12,026,638 Issues
2026-05-28	Complaint Filed

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

U.S. Patent No. 9,659,260 - "Calendar Based Task and Time Management Systems and Methods"

• Patent Identification: U.S. Patent No. 9,659,260, "Calendar Based Task and Time Management Systems and Methods," issued May 23, 2017. Compl. ¶8

The Invention Explained

• Problem Addressed: The patent addresses the inefficiency of conventional task management software where users must manually coordinate between separate task and calendar applications, which lack automated mechanisms for associating task records with time-based data Compl. ¶11 '260 Patent, col. 1:47-59
• The Patented Solution: The invention proposes a computer-implemented method for organizing tasks using a "cascading structured query technique" Compl. ¶13(b) This method iteratively parses a large set of task records through a series of queries; each query generates a task subset that matches the criteria and a "remainder subset" that becomes the input for the next query in the sequence, thereby efficiently organizing the tasks for display '260 Patent, col. 6:46-64
• Technical Importance: This approach claims to improve the functioning of the computing device by reducing the computational steps and database queries required to organize and filter large numbers of task records Compl. ¶13(b)

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 of the '260 Patent Compl. ¶28
• Independent Claim 1 of the '260 Patent includes the essential elements of a computer-implemented method for organizing task records, comprising:
  • Receiving data for a plurality of task records with corresponding attributes.
  • Storing a superset of the task records in a database.
  • Receiving a series of structured queries to filter the superset.
  • In response to a first structured query, parsing the superset, dynamically assembling a first task subset and a first remainder task subset.
  • In response to a second structured query, parsing the first remainder task subset, and dynamically assembling a second task subset and a second remainder task subset.
  • Determining an order of the subsets.
  • Outputting the organized task records to a display.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,074,523 - "Calendar Based Task and Time Management Systems and Methods"

• Patent Identification: U.S. Patent No. 11,074,523, "Calendar Based Task and Time Management Systems and Methods," issued July 27, 2021. Compl. ¶9

The Invention Explained

• Problem Addressed: The patent identifies the limitations of conventional systems that require manual, user-initiated association of individual tasks with specific time slots, which is computationally inefficient and difficult to manage dynamically Compl. ¶13(a) '523 Patent, col. 2:21-28
• The Patented Solution: The invention describes a rules-based system that uses defined "trigger conditions" and "corresponding actions" to automatically and dynamically affiliate task records with time records in a database '523 Patent, abstract The system continuously monitors for these triggers (e.g., passage of time, user input) and, when a trigger is satisfied, executes an action to update the affiliation between a task and a time record, outputting the result to a user interface '523 Patent, col. 4:26-34
• Technical Importance: This method claims to improve computer efficiency by enabling real-time dynamic updates of task-time affiliations without requiring a full re-computation of the entire task dataset Compl. ¶14

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 of the '523 Patent Compl. ¶40
• Independent Claim 1 of the '523 Patent includes the essential elements of a computer-implemented method for affiliating task records with time records, comprising:
  • Receiving data representing task records with attributes.
  • Storing a superset of task records in a database.
  • Creating time records corresponding to periods of time.
  • Maintaining at least one "handling rule" comprising a "trigger condition" and a "corresponding action" for dynamically affiliating task records with time records.
  • Continuously monitoring for trigger conditions.
  • When a trigger condition is met, performing the corresponding action.
  • Providing an output to an interface or display indicating the result of the action.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,026,638 - "Calendar Based Task and Time Management Systems and Methods" (Multi-Patent Capsule)

• Patent Identification: U.S. Patent No. 12,026,638, "Calendar Based Task and Time Management Systems and Methods," issued July 2, 2024 Compl. ¶10
• Technology Synopsis: The patent describes a method to improve computational efficiency by classifying task records based on their "schedule type" (e.g., day-and-time specific, day-only, or unscheduled) Compl. ¶13(c) The system then applies distinct handling rules to each classification to determine how and when to present the tasks, which is alleged to reduce redundant processing of tasks that lack specific temporal constraints Compl. ¶13(c) Compl. ¶53
• Asserted Claims: At least Claim 1 is asserted Compl. ¶52
• Accused Features: The complaint alleges that the Samsung Reminder application infringes by classifying task records by schedule type (e.g., day-and-time specific reminders, day-only reminders, unscheduled reminders) and applying distinct handling rules to each type Compl. ¶54 A screenshot in the complaint shows the Reminder application's user interface categorizing tasks as "Type = Day+Time," "Type = Day," and "Type = Unscheduled" Compl. p. 24

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are numerous Samsung electronic devices (including Galaxy smartphones, tablets, and watches) that are pre-configured with Samsung's Reminder application integrated with the Samsung Calendar application (collectively, the "Accused Products") Compl. ¶21

Functionality and Market Context

The Samsung Reminder application provides task management functionality, allowing users to create, organize, and manage "reminders" (i.e., task records) with various attributes like title, category, and scheduling information Compl. ¶22 These task records are stored in a database and can be synchronized across devices Compl. ¶22 The complaint alleges the application integrates with the Samsung Calendar to "dynamically affiliat[e] task records with time records for unified presentation to the user" Compl. ¶23 It is further alleged to employ functionalities corresponding to each of the asserted patents: cascading structured queries for filtering Compl. ¶25, monitoring trigger conditions to execute actions Compl. ¶23, and parsing tasks by schedule type Compl. ¶24

IV. Analysis of Infringement Allegations

'260 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an improved iterative computer-implemented method for continuously organizing and updating a plurality of task records for output in a rules-based sequence...	The Accused Products implement the Samsung Reminder application, which provides an iterative method for organizing and updating task records Compl. ¶29	¶29	col. 5:46-54
electronically stores a superset of the task records with their corresponding task attributes in a database...	Reminder task records are stored in a database on the Accused Products Compl. ¶22	¶22	col. 5:15-17
receives a series of structured queries corresponding to a request to filter the superset based on task attributes;	The Reminder application allows users to filter task records by user-defined categories such as "My Reminders," "Important," and "Groceries" Compl. ¶30	¶30	col. 5:29-39
responsive to the structured queries, parses the superset, dynamically assembles task subsets and remainder task subsets,	The complaint alleges this is performed when users filter by categories, thereby "dynamically assembling task subsets and remainder subsets" for display Compl. ¶30	¶30	col. 6:46-55
determines an order of those subsets according to sorting rules,	The Reminder application applies user-selectable sorting rules, such as sorting by "Alert time," to determine the order of the resulting subsets Compl. ¶31	¶31	col. 5:40-45
and outputs the organized task records to the display of the device.	The organized task records are outputted to the device display, as shown in a screenshot of the "My reminders" screen Compl. p. 14	¶30; ¶31	col. 6:4-11

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the user-initiated filtering by categories in the Samsung Reminder application constitutes the claimed "series of structured queries." The defense might argue that selecting a single category is not a "series" of queries.
  • Technical Questions: A key technical question will be whether the accused application "dynamically assembles... remainder task subsets" as required by the claim. The court may need to determine if showing items that do not belong to a selected category is functionally equivalent to creating a "remainder subset" that serves as the input for a subsequent query, as the patent describes '260 Patent, col. 6:49-55

'523 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
An improved iterative computer-implemented method for continuously organizing and affiliating a plurality of task records with time records...	The Accused Products implement the Samsung Reminder application integrated with Samsung Calendar for organizing and affiliating task records with time records Compl. ¶41	¶41	col. 1:21-25
creates time records corresponding to periods of time defined by at least two of a specific start time, a specific end time, and a duration of time;	The complaint alleges that when a user creates or modifies a reminder, the application creates time records and dynamically updates the calendar display Compl. ¶43	¶43	col. 3:9-14
electronically maintains at least one handling rule comprising at least one trigger condition and at least one corresponding action for dynamically affiliating task records with time records;	The complaint alleges the system employs handling rules with trigger conditions and corresponding actions to affiliate task and time records Compl. ¶12 Compl. ¶41	¶12; ¶41	col. 4:56-62
continuously monitors trigger conditions;	The application "continuously monitors trigger conditions-such as the passage of time and user modifications to reminder items" Compl. ¶23	¶23	col. 30:11-12
and, when a trigger condition is satisfied, performs the corresponding action to dynamically update the affiliation... and output the result...	The application is alleged to execute actions like generating alerts and updating the calendar display when triggers are met Compl. ¶23 A visual shows the app "Syncing reminders..." Compl. p. 19	¶23; ¶43	col. 30:13-20

• Identified Points of Contention:
  • Scope Questions: The interpretation of "handling rule" will be critical. The court will need to decide if this term requires a specific, formally defined rule structure (e.g., a user-configured if-then statement) or if it can be read more broadly to encompass the application's inherent, pre-programmed logic for updating the display.
  • Technical Questions: An evidentiary question may arise regarding whether the accused application's general background "syncing" process Compl. p. 19 performs the specific claimed function of "dynamically updat[ing] the affiliation of task records with time records" in response to a discrete "trigger condition," or if it is a more general data synchronization mechanism.

V. Key Claim Terms for Construction

For U.S. Patent No. 9,659,260:

• The Term: "dynamically assembles task subsets and remainder task subsets"
• Context and Importance: This term is central to the claimed invention's novelty, which is described as a "cascading structured query technique" Compl. ¶13(b) The infringement analysis will turn on whether the accused filtering functionality, which allows users to select categories, creates a "remainder task subset" that is then operated upon by a subsequent query, or if it performs a more conventional database filter.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the process in terms of "Fills" and "Cascades," where "each Fill draws from the pool of Tasks not included in previous Fills" '260 Patent, col. 6:49-51 This language could support a view that any process that filters a set and leaves a remainder for subsequent operations meets the limitation.
  • Evidence for a Narrower Interpretation: Figure 3.4 and the accompanying text describe a specific, ordered sequence where a first filter produces "Subset 1" and a remainder pool of tasks, and a second filter operates only on that remainder pool to produce "Subset 2" '260 Patent, col. 7:40-49 This may support a narrower construction requiring a specific, iterative parsing of a dynamically shrinking dataset, not just parallel filters applied to a master set.

For U.S. Patent No. 11,074,523:

• The Term: "handling rule comprising at least one trigger condition and at least one corresponding action"
• Context and Importance: This term defines the core mechanism for the claimed dynamic affiliation of tasks and time. Practitioners may focus on this term because its construction will determine whether the accused product's routine, automated behaviors (e.g., moving a past-due item to a "Past" category) qualify as executing a "handling rule," or if the term requires a more explicit, pre-defined logical structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that "Handling rules can take many forms, but in all cases can be expressed as actionable if-then statements" '523 Patent, col. 4:56-58 This broad definition may support an argument that any coded if [condition], then [update display] logic within the accused software constitutes a "handling rule."
  • Evidence for a Narrower Interpretation: The specification provides numerous examples of handling rules that involve "exogenous" factors like "weather," "economic indicators," or "location (in GPS coordinates)," which are distinct from simple time passage or direct user input '523 Patent, col. 9:31-43 A party could argue these examples suggest that a "handling rule" is intended to be a more complex, context-aware instruction than the general operational logic of a basic reminder application.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Samsung provides instructions, user guides, and training videos that encourage users to operate the Accused Products in an infringing manner Compl. ¶33 Compl. ¶45 Compl. ¶57 Contributory infringement is based on the allegation that the Samsung Reminder application is a material component of the invention, is especially made for infringement, and is not a staple article of commerce suitable for substantial non-infringing use Compl. ¶34 Compl. ¶46 Compl. ¶58
• Willful Infringement: Willfulness is alleged based on pre-suit knowledge of the patents-in-suit. For the '260 Patent, knowledge is alleged as of June 10, 2019, from a Notice of References Cited issued during the prosecution of Samsung's own patent application that identified the application which matured into the '260 Patent Compl. ¶¶17-18 For the '523 and '638 Patents, knowledge is alleged as of their respective issue dates, based on their belonging to the same patent family of which Samsung was allegedly already on notice Compl. ¶20

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

1. A central issue will be one of technical equivalence: Does the Samsung Reminder application's method of filtering tasks into categories function in the same way as the '260 patent's claimed "cascading structured query" method, which requires the specific, iterative creation of "remainder task subsets" that serve as the input for subsequent queries?

2. A second key issue will be one of definitional scope: Can the term "handling rule" in the '523 patent, which comprises a "trigger condition" and a "corresponding action," be construed to encompass the routine, time-based sorting and display updates inherent in the accused reminder application, or does the patent's specification require a more discrete, formally defined logical construct?

3. A determinative question for willfulness and damages will be one of knowledge: Can the plaintiff demonstrate that a 2019 citation to a patent application during a separate patent's prosecution is sufficient to establish that the defendant had actual knowledge of the subsequently issued '260 Patent and its alleged infringement, and further, that this created an affirmative duty for the defendant to monitor that patent family for future patents like the '523 and '638?