Gravity Jack Inc v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Gravity Jack, Inc. (Wyoming)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff's Counsel: Miller Fair Henry PLLC; Folio Law Group PLLC
• Case Identification: 2:26-cv-00593, E.D. Tex., 07/17/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Samsung Electronics America, Inc. maintaining regular and established places of business within the district. For Samsung Electronics Co., Ltd., a foreign corporation, venue is alleged to be proper in any judicial district.
• Core Dispute: Plaintiff alleges that certain Samsung mobile electronic devices, including various models of its Galaxy smartphones and tablets, infringe two patents related to improving location accuracy for augmented reality applications.
• Technical Context: The technology concerns methods and systems for refining a device's location beyond the accuracy of standard GPS by using information from wireless communications with other nearby devices, which is critical for precise augmented reality overlays.
• Key Procedural History: The complaint details extensive pre-litigation history between the parties, beginning with a Samsung engineer allegedly contacting Gravity Jack in 2013 to discuss its AR technology. Gravity Jack alleges it disclosed its pending patent applications in 2013 and its issued patents-in-suit to Samsung by February 2017. The complaint also alleges that the U.S. Patent and Trademark Office cited the application for one of the patents-in-suit against a Samsung patent application during its prosecution, potentially establishing knowledge.

Case Timeline

Date	Event
2010-07-30	Priority Date for '659 and '844 Patents
2013-03-25	Samsung allegedly initiates contact with Gravity Jack regarding its AR technology
2013-04-23	Gravity Jack allegedly discloses its pending patent applications to Samsung
2013-08-06	U.S. Patent No. 8,502,659 Issues
2013-08-27	U.S. Patent No. 8,519,844 Issues
2016-01-27	Gravity Jack and Samsung allegedly execute a mutual non-disclosure agreement
2017-02-08	Gravity Jack allegedly informs Samsung of its issued patents, including the patents-in-suit
2017-07-24	USPTO allegedly cites '659 patent application against a Samsung patent application
2018-01-02	USPTO again cites the '659 published application against a Samsung patent application during prosecution
2020-08	Approximate launch of first-listed Accused Product (Galaxy Note 20 Ultra)
2021-01	Approximate launch of accused Galaxy S21+ and S21 Ultra
2022-02	Approximate launch of accused Galaxy S22+ and S22 Ultra
2023-02	Approximate launch of accused Galaxy S23+ and S23 Ultra
2024-01	Approximate launch of accused Galaxy S24+ and S24 Ultra
2025-02	Approximate launch of accused Galaxy S25+ and S25 Ultra
2026-03	Approximate launch of accused Galaxy S26, S26+, and S26 Ultra
2026-07-17	Complaint Filing Date

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

U.S. Patent No. 8,502,659 - "Augmented Reality and Location Determination Methods and Apparatus"

• Patent Identification: U.S. Patent No. 8,502,659, "Augmented Reality and Location Determination Methods and Apparatus," issued on August 6, 2013 Compl. ¶15

The Invention Explained

• Problem Addressed: The patent addresses the problem that conventional location-determination methods, such as GPS, are often too inaccurate or "coarse" to properly support augmented reality (AR) applications, which require precise alignment between virtual objects and the physical world Compl. ¶16 '659 Patent, col. 12:1-12
• The Patented Solution: The invention proposes a method to refine a device's location. It begins by "accessing first location information" (e.g., from GPS) and then identifies nearby wireless devices. By initiating communication with these devices and "accessing information regarding the wireless communications" (e.g., signal timing), it "determin[es] second location information" that is more accurate than the initial data '659 Patent, abstract '659 Patent, col. 2:57-3:8
• Technical Importance: This two-step refinement process-using coarse location data to find local communication partners and then using those local communications to achieve fine-grained accuracy-was designed to make mobile AR applications more robust and precise Compl. ¶16

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶38
• The essential elements of claim 1, a method, include:
  • accessing first location information regarding a location of a user interaction device in a physical world;
  • identifying a plurality of wireless communication devices which are proximately located with respect to the user interaction device;
  • initiating wireless communications between the user interaction device and the wireless communications devices;
  • after the initiating, accessing information regarding the wireless communications;
  • using the information regarding the wireless communications, determining second location information regarding the location of the user interaction device;
  • wherein the second location information has increased accuracy with respect to the location of the user interaction device in the physical world compared with the first location information.
• The complaint notes infringement of "multiple claims," including but not limited to independent claim 1 Compl. ¶38

U.S. Patent No. 8,519,844 - "Augmented Reality and Location Determination Methods and Apparatus"

• Patent Identification: U.S. Patent No. 8,519,844, "Augmented Reality and Location Determination Methods and Apparatus," issued on August 27, 2013 Compl. ¶17

The Invention Explained

• Problem Addressed: Similar to the '659 patent, this patent addresses the challenge that a single, coarse source of location information is insufficient for high-quality AR experiences Compl. ¶18 '844 Patent, col. 2:36-41
• The Patented Solution: The invention describes an "augmented reality user interaction device" itself. The device comprises a camera, a display, communications circuitry, and processing circuitry. The processing circuitry is configured to generate AR imagery and to control the communications circuitry to obtain a more accurate "second location information" to improve the AR experience, thereby solving the problem of coarse initial location data '844 Patent, col. 4:26-49
• Technical Importance: This patent claims the apparatus that embodies the location-refining AR method, providing a technical blueprint for a mobile device capable of these advanced functions Compl. ¶18

Key Claims at a Glance

• The complaint asserts independent claim 14 Compl. ¶50
• The essential elements of claim 14, an apparatus, include:
  • a camera;
  • a display system;
  • communications circuitry configured to implement wireless communications;
  • processing circuitry coupled to the other components and configured to:
    • control the display to generate images that include an AR representation;
    • control the communications circuitry to communicate first location information;
    • access second location information that has increased accuracy compared to the first.
• The complaint alleges infringement of "multiple claims," including but not limited to independent claim 14 Compl. ¶50

III. The Accused Instrumentality

Product Identification

The complaint accuses a wide range of Samsung mobile electronic devices, including the Galaxy Note 20 Ultra, various models in the Galaxy S21 through S26 series, and the Galaxy Z Fold 2 through 7 series Compl. ¶37 Compl. ¶49

Functionality and Market Context

The infringement allegations center on features within the "SmartThings Find" and "Samsung Find" applications on the accused devices Compl., Ex. 3, p. 2 Compl., Ex. 4, p. 2 These applications are alleged to use technologies like Ultra-Wideband (UWB) and Bluetooth Low Energy (BLE), in combination with the device's camera and ARCore software, to precisely locate other Samsung devices Compl., Ex. 3, p. 2 Compl., Ex. 3, p. 7 The complaint provides visual evidence of this functionality, such as a screenshot from the "SmartThings Find" app on a Galaxy S23 Ultra displaying a distance to a lost device Compl., Ex. 4, p. 4, with additional visuals showing a camera view and directional arrows guiding the user toward the device Compl., Ex. 4, p. 5 Compl., Ex. 4, p. 6 Another screenshot shows the app overlaying a "cloud of dots" on the camera view to highlight a found device's location, demonstrating an AR representation Compl., Ex. 4, p. 6 A system diagram illustrates the "Offline Finding" feature, where nearby "Helper Devices" can detect a lost device and report its location to "Samsung's Servers" Compl., Ex. 4, p. 18

IV. Analysis of Infringement Allegations

'659 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
accessing first location information regarding a location of a user interaction device in a physical world, wherein the user interaction device is configured to generate an augmented reality representation with respect to the physical world	The accused devices access initial location information from sources like GPS to display a device's location on a map Compl., Ex. 3, p. 9	¶38	col. 30:47-51
using the first location information, identifying a plurality of wireless communication devices which are proximately located with respect to the user interaction device	The accused devices use this first location to identify other nearby UWB or BLE-enabled devices, such as other phones or SmartTags Compl., Ex. 3, p. 12	¶38	col. 30:52-55
initiating wireless communications between the user interaction device and the wireless communications devices	The accused devices initiate UWB or BLE communications, a process the complaint refers to as "ranging" or "scanning," with the identified nearby devices Compl., Ex. 3, p. 14	¶38	col. 30:56-57
after the initiating, accessing information regarding the wireless communications...	The system accesses information from these communications, such as Time-of-Flight (ToF) data from UWB signals or BLE data from the "Offline Finding" feature Compl., Ex. 3, p. 15	¶38	col. 30:58-60
using the information... determining second location information regarding the location of the user interaction device...	The accused devices use UWB Time-of-Flight data to calculate a more precise, "centimeter level" location for the device, while the BLE "Offline Finding" mechanism receives and sends location updates Compl., Ex. 3, p. 17	¶38	col. 30:61-63
and wherein the second location information has increased accuracy... compared with the first location information.	The complaint alleges that the location determined via UWB is more accurate than the first location information from GPS Compl., Ex. 3, p. 17	¶38	col. 30:64-67

'844 Patent Infringement Allegations

Claim Element (from Independent Claim 14)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
An augmented reality user interaction device comprising:	The accused Samsung smartphones, when running the "SmartThings Find" application, are alleged to be an augmented reality user interaction device Compl., Ex. 4, p. 3	¶50	col. 31:61-62
a camera;	The accused devices include front and rear cameras Compl., Ex. 4, p. 6	¶50	col. 31:63
a display system;	The accused devices include a display screen Compl., Ex. 4, p. 7	¶50	col. 31:64
communications circuitry configured to implement wireless communications externally...	The accused devices include circuitry for Wi-Fi, Bluetooth, and UWB to communicate with external devices and networks Compl., Ex. 4, p. 8	¶50	col. 31:65-67
processing circuitry... configured to... control the display system to generate a plurality of images which comprise image data... and augmented data which augments the image data with an augmented reality representation	The device's CPU, running the "SmartThings Find" app, overlays virtual arrows or a cloud of dots on the live camera feed to guide the user Compl., Ex. 4, pp. 12-13	¶50	col. 32:1-6
... configured to... control the communications circuitry to communicate first location information...	The CPU controls the communication circuitry to communicate the device's initial location, for example via GPS coordinates shown on a map Compl., Ex. 4, p. 15	¶50	col. 32:7-11
... configured to access second location information... wherein the second location information has increased accuracy...	The CPU accesses a more precise location derived from UWB communications, which provides centimeter-level accuracy superior to GPS Compl., Ex. 4, p. 17	¶50	col. 32:12-18

Identified Points of Contention

• Scope Questions: The patents describe a system that may include a "management device" (i.e., a server) coordinating communications '659 Patent, Fig. 2 '844 Patent, Fig. 2 The infringement theory for the "Offline Finding" feature relies on a network of "helper devices" reporting to Samsung's servers, which then provide the location to the user Compl., Ex. 4, p. 18 This raises the question of whether a process arbitrated by a central server meets limitations like "initiating wireless communications between the user interaction device and the wireless communications devices" and "using the information... determining second location" '659 Patent, claim 1, which could be interpreted to require a more direct, peer-to-peer determination.
• Technical Questions: A key technical question will be where the "determining" of the second, more accurate location occurs. The analysis will need to distinguish between location data calculated on the user's device based on raw signal data versus a location result that is calculated on Samsung's servers and then simply sent to the device. The construction of terms like "determining" and "accessing" will be central to whether the server-based "Offline Finding" architecture falls within the scope of the claims.

V. Key Claim Terms for Construction

For the '659 Patent:

• The Term: "determining second location information" (from claim 1)
• Context and Importance: This term is critical because the infringement theory encompasses both direct UWB "ranging" and server-mediated "Offline Finding." The case may turn on whether "determining" requires the user's device to perform the calculation itself, or if it can simply receive the result of a determination made by a remote server.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses a "management device" that can "manage and/or co-ordinate" communications and "implement operations with respect to image processing to determine the location information" '659 Patent, col. 9:1-7, which may support a view that some determination steps can occur off-device.
  • Evidence for a Narrower Interpretation: The abstract states that the "user interaction device" is used for "determining second location information," and flowcharts like Figure 6 show the device itself performing the "UPDATE LOCATION" step '659 Patent, abstract '659 Patent, Fig. 6, A26 This may support an interpretation that the determination must occur locally on the user device.

For the '844 Patent:

• The Term: "access second location information" (from claim 14)
• Context and Importance: Similar to the term in the '659 patent, the meaning of "access" is pivotal. Practitioners may focus on this term because if "access" is construed to mean the device's own circuitry must perform the location calculation, the server-based "Offline Finding" feature may not infringe. If "access" can encompass a device obtaining a location result determined by a remote server, the server-based "Offline Finding" feature may fall within the term's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: "Access" is a general term, and a device can "access" data by requesting it over a network. The specification's inclusion of a "management device" in the system architecture suggests that interaction with a server is contemplated '844 Patent, Fig. 2
  • Evidence for a Narrower Interpretation: The claim requires the device's "processing circuitry" to be "configured to access" the information. This language could be read to require the processing circuitry to have the capability to derive the information, not merely receive it. The specification also states the processing circuitry is configured to "generate second location information" '844 Patent, col. 3:28-31, which suggests an active calculation role for the device itself.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Samsung induces infringement by providing the accused devices and instructing customers on how to use the allegedly infringing "SmartThings Find" features Compl. ¶40 Compl. ¶52 It also alleges contributory infringement, asserting that the accused products are especially adapted for infringing the patents and are not staple articles of commerce suitable for substantial non-infringing use Compl. ¶41 Compl. ¶53 The complaint further alleges that Samsung is liable under 35 U.S.C. § 271(f) for supplying components of the patented invention from the United States for combination outside the United States with respect to the '844 patent Compl. ¶51 Compl. ¶54

• Willful Infringement: The complaint makes detailed allegations to support willfulness, asserting that Samsung had pre-suit knowledge of the patents. The basis includes direct communications starting in 2013 where Gravity Jack allegedly disclosed its pending and later issued patents Compl. ¶31, as well as USPTO office actions on July 24, 2017, and January 2, 2018, in which the '659 patent's published application was cited as prior art against one of Samsung's own patent applications Compl. ¶39 Compl. ¶51

• Requested Relief: In its Prayer for Relief, the complaint requests a judgment that Samsung has infringed, an award of damages adequate to compensate for the infringement including at least a reasonable royalty, a permanent injunction, an accounting and supplemental damages, pre-judgment and post-judgment interest, enhanced damages, and a declaration that the case is exceptional supporting an award of reasonable attorney's fees Compl., Prayer for Relief

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

• A core issue will be one of claim scope and system architecture: can the claim terms "determining" ('659 patent) and "accessing" ('844 patent) the refined "second location information" be construed to cover a system where a remote server calculates the location and transmits the result to the device, as is allegedly done in the accused "Offline Finding" feature? Or do the claims require the location calculation to be performed on the user's device itself?
• A second central question will be one of pre-suit knowledge: the complaint lays out a detailed timeline of alleged disclosures and notices, including a USPTO action, to support its willfulness claim. The extent to which these allegations can be substantiated with evidence will be critical in determining whether Samsung acted with the knowledge or willful blindness required for an award of enhanced damages.