DCT

2:26-cv-00584

Crestone IP Management LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00584, E.D. Tex., 07/16/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Samsung maintains a regular and established place of business in the district, located at 6625 Excellence Way, Plano, Texas, and has previously conceded venue in the Eastern District of Texas in other litigation.
  • Core Dispute: Plaintiff alleges that Defendant's smartphones, tablets, laptops, and solid-state drives infringe four patents related to semiconductor and telecommunications technologies.
  • Technical Context: The patents-in-suit address core functionalities in modern electronics, including hybrid oscillator clock generation, secure trusted platform modules, remote media device control, and adaptive voltage regulation for memory circuits.
  • Key Procedural History: The asserted patents originate from a portfolio developed by Microchip Technology Incorporated and its affiliates. The complaint alleges that Plaintiff provided Defendant with actual notice of infringement for all four patents prior to filing suit, forming the basis for allegations of willful infringement.

Case Timeline

Date Event
2006-03-24 '072 Patent Priority Date
2006-10-11 '231 Patent Filing Date
2006-11-30 '072 Patent Filing Date
2009-10-07 '231 Patent Issue Date
2010-05-12 '534 Patent Priority Date
2011-05-12 '534 Patent Filing Date
2012-09-04 '072 Patent Issue Date
2016-03-15 '534 Patent Issue Date
2017-04-19 '012 Patent Priority Date
2020-09-08 '012 Patent Issue Date
2025-08-08 Alleged notice of infringement for '012, '072, and '534 patents
2026-05-29 Alleged notice of infringement for '231 patent
2026-07-16 Complaint Filing Date

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

U.S. Patent No. 10,771,012 - "Hybrid RC/crystal oscillator", issued September 8, 2020

The Invention Explained

  • Problem Addressed: The patent's background section notes that modern integrated circuits require a clock source, but conventional options present a trade-off: external crystal-based clocks are accurate but can be slow to start and less flexible, while internal tunable oscillators are flexible but less accurate Compl. ¶32
  • The Patented Solution: The invention proposes a hybrid system that uses an accurate external crystal as a reference element to continuously adjust the frequency of a flexible, internal tunable oscillator Compl. ¶33 As described in the specification, this approach uses a phase detector and an oscillator controller to compare the two signals and maintain a phase lock, thereby combining the stability of a crystal with the fast start-up and reliability of an internal oscillator '012 Patent, col. 5:26-34 '012 Patent, abstract
  • Technical Importance: This hybrid approach provides improved reliability, particularly during start-up, and enhanced accuracy over purely internal oscillators, while maintaining operational flexibility Compl. ¶35

Key Claims at a Glance

  • The complaint asserts independent claim 19 Compl. ¶34
  • The essential elements of claim 19, a system claim, include:
    • A semiconductor device with a first external pin and an internal oscillator.
    • An external resonant element (e.g., a crystal) coupled to the device via the pin.
    • The internal oscillator comprising a tunable oscillator, a phase detector circuit, and an oscillator controller circuit.
    • The oscillator controller circuit is configured to use the output of the external resonant element to adjust the frequency of the tunable oscillator "during the entire operation of the tunable oscillator."

U.S. Patent No. 8,261,072 - "Method and system for secure external TPM password generation and use", issued September 4, 2012

The Invention Explained

  • Problem Addressed: The complaint states that even with the use of Trusted Platform Modules (TPMs) for enhanced security, communication with external devices creates vulnerabilities where secrets and codes can be intercepted Compl. ¶¶41-43
  • The Patented Solution: The patent describes a method where a secure code is generated on a remote device and securely conveyed to the TPM Compl. ¶44 The system attaches "usage authorization information" to the secure code, which is then sent to the TPM; the TPM can then recognize the code and use it as a parameter for trusted commands, enabling secure authentication for subsequent uses of the key '072 Patent, abstract Compl. ¶44
  • Technical Importance: This technique aims to improve system security during normal operation by securing the transmission of credentials, without decreasing the system's usability or accessibility for the user Compl. ¶46

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶45
  • The essential elements of claim 1, a computer system claim, include:
    • Standard computer components (CPUs, memory, I/O adapters).
    • A trusted platform module (TPM) configured to perform operations.
    • The TPM's operations comprise:
      • receiving a secure access code from a remote device outside of the trusted platform module;
      • receiving usage authorization information generated by a secure generator, with this information being attached to the secure access code;
      • recognizing the secure access code; and
      • using the secure access code as a parameter for various trusted platform module commands.

U.S. Patent No. 9,288,534 - "Systems and methods for operating media devices", issued March 15, 2016

  • Patent Identification: U.S. Patent No. 9,288,534, "Systems and methods for operating media devices", issued March 15, 2016 Compl. ¶47 Compl. ¶48
  • Technology Synopsis: The patent addresses the difficulty of controlling various consumer media players and accessing media from different sources Compl. ¶¶52-53 The invention describes a mobile computing device acting as a "remote controller" that communicates separately with a media player and a media source, determines compatible content, and builds a unified user interface to control the system Compl. ¶54
  • Asserted Claims: The complaint quotes independent claim 6 Compl. ¶55
  • Accused Features: The complaint accuses numerous Android-based smartphones and tablets, such as the Samsung Galaxy S25 Ultra, of infringing by implementing functionality to act as remote controllers for media devices Compl. ¶89

U.S. Patent No. 7,599,231 - "Adaptive regulator for idle state in a charge pump circuit of a memory device", issued October 7, 2009

  • Patent Identification: U.S. Patent No. 7,599,231, "Adaptive regulator for idle state in a charge pump circuit of a memory device", issued October 7, 2009 Compl. ¶57 Compl. ¶58
  • Technology Synopsis: The patent addresses performance degradation in memory devices caused by voltage spikes or drops when switching between high-voltage operations like programming and reading Compl. ¶62 The solution involves using an "intermediate idle voltage state" to create a controlled transition, which reduces these electrical disturbances Compl. ¶63
  • Asserted Claims: The complaint quotes independent claim 12 Compl. ¶64
  • Accused Features: The complaint accuses smartphones containing TLC 3D NAND flash memory, exemplifying the Samsung Galaxy S25 Ultra, of infringing by using an adaptive voltage regulation scheme during memory operations Compl. ¶99

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as a broad category of Samsung devices including smartphones, tablets, laptops, and solid-state drives Compl. ¶1 Specific exemplary products are named for each asserted patent, including the Samsung Galaxy S25 Ultra, Z-SSD 983 ZET, and Galaxy Book6 Compl. ¶69 Compl. ¶79

Functionality and Market Context

The complaint alleges that these products incorporate the patented technologies as part of their core functionality. For the '012 patent, the accused functionality is the hybrid clocking system in microcontrollers (Compl. ¶31; Compl. ¶32; Compl. ¶33). For the '072 patent, it is the use of a trusted platform module for secure operations Compl. ¶¶79-80 For the '534 patent, it is the capability of smartphones and tablets to act as remote controllers for media devices Compl. ¶¶89-90 For the '231 patent, it is the voltage regulation circuitry within NAND flash memory Compl. ¶¶99-100 The complaint positions these as commercially significant products incorporating advanced technologies Compl. ¶8

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint repeatedly references claim chart exhibits (Exhibits E, F, G, H) that demonstrate infringement but does not include them in the body of the filing Compl. ¶70 Compl. ¶80 Compl. ¶90 Compl. ¶100 As these exhibits are not provided, the infringement allegations are summarized below in prose.

  • '012 Patent Infringement Allegations: The complaint asserts that products like the Samsung Galaxy S25 Ultra and Z-SSD 983 ZET directly infringe one or more claims of the '012 patent Compl. ¶69 The narrative theory is that these devices contain a hybrid oscillator system that meets the elements of claim 19 by using an external crystal as a reference to adjust and control the frequency of an internal tunable oscillator throughout its operation, thereby providing a stable and reliable clock source Compl. ¶¶33-34
  • '072 Patent Infringement Allegations: The complaint asserts that a wide range of Samsung smartphones, tablets, and laptops containing a trusted platform module (TPM) infringe the '072 patent, with the Galaxy Book6 cited as an example Compl. ¶79 The narrative theory is that these devices embody the system of claim 1 by employing a TPM that receives a secure access code and associated usage authorization information from a "remote device" (such as a biometric sensor) to securely manage and execute trusted commands Compl. ¶¶44-45

Identified Points of Contention

  • Scope Questions: A central question for the '072 patent will be the interpretation of a "remote device outside of the trusted platform module." The court may need to determine if this language, potentially written with physically separate peripherals in mind, can be construed to cover components that are logically separate but physically integrated within the same System-on-a-Chip (SoC), as is common in modern smartphones.
  • Technical Questions: For the '012 patent, a key factual dispute may arise over the phrase "during the entire operation of the tunable oscillator." The analysis may turn on whether evidence shows the accused clocking system uses the external crystal for continuous or recurring frequency adjustment, as the claim requires, or for a more limited purpose such as initial calibration.

V. Key Claim Terms for Construction

  • Term from '012 Patent, Claim 19: "oscillator controller circuit is configured to use the output of the external resonant element to adjust frequency of the tunable oscillator during the entire operation of the tunable oscillator"

    • Context and Importance: Practitioners may focus on this term because the temporal limitation "during the entire operation" is a critical qualifier. Its construction will determine whether an infringing system must perform continuous feedback-based adjustment or if intermittent or startup-only calibration suffices.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the external crystal as a "supplementary clock source" and a "reference sensor," which may suggest its use is not necessarily continuous but occurs as needed to augment the primary internal oscillator '012 Patent, col. 4:61-64
      • Evidence for a Narrower Interpretation: The claim language itself is restrictive. Furthermore, the specification's discussion of achieving and maintaining "phase lock" between the internal oscillator and the crystal implies a continuous or frequently recurring comparison and adjustment process to maintain equilibrium '012 Patent, col. 5:32-34

  • Term from '072 Patent, Claim 1: "remote device outside of the trusted platform module"

    • Context and Importance: Practitioners may focus on this term because its scope is central to whether the claim reads on highly integrated modern devices like smartphones. The definition of "remote" and "outside" will be pivotal in a context where components (e.g., a CPU, a TPM, a fingerprint sensor) may be architecturally distinct but co-located on the same silicon die.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's background focuses on the security risks of communication between system components, which could support a functional interpretation where any component communicating with the TPM over a bus is considered "remote" or "external," regardless of physical proximity '072 Patent, col. 2:42-49
      • Evidence for a Narrower Interpretation: The patent abstract refers to generating a code at a "remote device" and conveying it "to the system," suggesting two distinct entities '072 Patent, abstract Figure 4 of the patent depicts a PC, a Smart Card ("SC"), and a TPM as separate block-level components, which may support an interpretation requiring physical or structural separation '072 Patent, Fig. 4

VI. Other Allegations

  • Indirect Infringement: The complaint focuses on direct infringement under 35 U.S.C. § 271(a) for all counts and does not contain specific factual allegations to support claims of induced or contributory infringement Compl. ¶69 Compl. ¶79 Compl. ¶89 Compl. ¶99
  • Willful Infringement: Plaintiff alleges that Defendant's infringement was and is willful for all four asserted patents Compl. ¶72 Compl. ¶82 Compl. ¶92 Compl. ¶102 The basis for this allegation is Defendant's alleged knowledge of the patents, stemming from actual notice provided by a representative of Plaintiff on or about August 8, 2025, for the '012, '072, and '534 patents, and on or about May 29, 2026, for the '231 patent Compl. ¶72 Compl. ¶82 Compl. ¶92 Compl. ¶102

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

The resolution of this case may depend on the court's findings regarding the following key questions:

  1. A question of architectural interpretation: Can the term "remote device outside of the trusted platform module" in the '072 patent, conceived in an era of more discrete components, be construed to encompass logically separate but physically integrated functions (like a biometric sensor) within a modern, highly integrated System-on-a-Chip?

  2. A question of operational functionality: Does the evidence show that Samsung's accused clocking systems perform frequency adjustment "during the entire operation" of the oscillator as required by the '012 patent, or is the external crystal's role more limited? Similarly, for the '231 patent, does Samsung's memory circuitry employ the specific "intermediate idle voltage state" transition scheme recited in the claim?

  3. A question of system-level mapping: For the '534 patent, can the plaintiff demonstrate that an accused smartphone simultaneously functions as the claimed "remote controller" while communicating with distinct external "media players" and "media sources" via separate communication links in the precise architecture required by the claims?

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