2:26-cv-00656
Crispera J1 Assets LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Crispera J1 Assets LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff's Counsel: Cherry Johnson Siegmund James PLLC
- Case Identification: 2:26-cv-00656, E.D. Tex., 08/06/2026
- Venue Allegations: Venue for Samsung Electronics America, Inc. (SEA) is based on its regular and established places of business in the Eastern District of Texas, including its flagship campus in Plano, which is slated to become its new U.S. headquarters. Venue for Samsung Electronics Co., Ltd. (SEC) is based on its status as a foreign defendant.
- Core Dispute: Plaintiff alleges that Defendant's consumer electronics and smart home products, which use scannable codes to link devices to accounts for functions like Wi-Fi sharing and appliance registration, infringe six patents related to connecting physical or displayed items to user-configured, server-side computerized actions.
- Technical Context: The technology concerns systems that use scannable codes to link an item to a network account, which then triggers customized, server-generated responses, evolving beyond the conventional use of codes to deliver static information.
- Key Procedural History: The six patents-in-suit are members of a single family descending from provisional applications filed in 2011 and 2012. The complaint notes that in prior patent litigation, Defendants have taken the position that venue is proper in the Eastern District of Texas for matters involving their mobile devices.
Case Timeline
| Date | Event |
|---|---|
| 2011-10-15 | Earliest Priority Date for all Patents-in-Suit |
| 2020-02-04 | Issue Date for U.S. Patent No. 10,552,715 (Parent Patent) |
| 2021-11-02 | U.S. Patent No. 11,164,054 Issues |
| 2023-04-18 | U.S. Patent No. 11,630,976 Issues |
| 2023-10-10 | U.S. Patent No. 11,783,147 Issues |
| 2024-09-17 | U.S. Patent No. 12,093,760 Issues |
| 2024-12-10 | U.S. Patent No. 12,164,983 Issues |
| 2025-08-19 | U.S. Patent No. 12,393,809 Issues |
| 2026-08-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,164,054
- Patent Identification: U.S. Patent No. 11,164,054 (System linked item), issued November 2, 2021 (the "'054 Patent"). Compl. ¶30
The Invention Explained
- Problem Addressed: The patent specification describes the problem that conventional advertising or information products, like for-sale signs, contained static information that was difficult to update Compl. ¶41 '054 Patent, col. 2:5-9 Linking such items to powerful computer applications involved "many complicated steps," leading item owners to simply place their own static contact information on the item, which forced them to field all inquiries directly '054 Patent, col. 2:10-24
- The Patented Solution: The invention is a "for information product" or "FIP" that is pre-configured with "system linked contact information" '054 Patent, abstract An owner of the FIP can associate it with settable system applications, allowing the FIP to be "repeatedly used, advertising different information... by simply updating said settable system-applications" without physically altering the item '054 Patent, col. 3:30-40 This allows an owner to advertise and receive inquiries without revealing their actual contact information publicly '054 Patent, col. 3:41-48
- Technical Importance: The claimed architecture provided a mechanism to link physical items to dynamic, account-based digital services before the widespread adoption of QR-code-based commerce and device provisioning Compl. ¶43
Key Claims at a Glance
- The complaint asserts at least independent claim 1 Compl. ¶58
- The essential elements of Claim 1, a method claim, are:
- acquiring a system linked item comprising a physical item and system linked contact information, with the contact information being physically displayed on the item;
- setting personalized action settings (comprising personalized information) in a computer system, where the settings are linked to the system linked contact information;
- configuring the computer system to perform a response to user input of an action request representing the system linked contact information; and
- the response comprising one or more computerized actions defined by the personalized action settings, which includes retrieving and transmitting the personalized information.
- The complaint reserves the right to assert additional claims Compl. ¶67
U.S. Patent No. 11,630,976
- Patent Identification: U.S. Patent No. 11,630,976 (System linked item), issued April 18, 2023 (the "'976 Patent"). Compl. ¶31
The Invention Explained
- Problem Addressed: The shared patent specification identifies the challenge of connecting physical items to dynamic, user-configured computerized actions, as conventional methods relied on static data payloads or complex setup processes Compl. ¶41 '976 Patent, col. 2:8-12 '976 Patent, col. 2:13-27
- The Patented Solution: The patent describes a system comprising a physical item displaying "system linked contact information" and a computer system that manages user interactions '976 Patent, abstract The computer system verifies user access requests, allows users to define "personalized action settings," and, upon receiving subsequent user input related to the item, executes computerized actions based on those settings, such as retrieving and transmitting the user's personalized information '976 Patent, abstract '976 Patent, col. 3:31-40
- Technical Importance: The invention provides a complete system architecture for linking physical objects to network-based accounts that can trigger configurable, personalized digital actions Compl. ¶43
Key Claims at a Glance
- The complaint asserts at least independent claim 13 Compl. ¶71
- The essential elements of Claim 13, a system claim, are:
- A system linked item comprising a physical item displaying system linked contact information; and
- A computer system configured to perform acts including:
- verifying a user access request is linked to the system linked contact information;
- permitting a user to set personalized action settings;
- receiving user input representing the system linked contact information; and
- in response, performing personalized computerized actions, including retrieving and transmitting the personalized information.
- The complaint reserves the right to assert additional claims Compl. ¶81
Multi-Patent Capsules
U.S. Patent No. 11,783,147: Issued October 10, 2023, and titled System linked item (the "'147 Patent"), this patent describes a method for linking a physical item with a scannable code to a computer system Compl. ¶32 The system receives a user request to set customized action settings, associates those settings with a services-account, and upon a subsequent scan of the code, performs a customized action that retrieves and transmits information derived from the customized information Compl. ¶85
- Asserted Claims: At least independent claim 23 Compl. ¶85
- Accused Features: Samsung Galaxy Smartphones and Samsung Home Appliances that carry or display a scannable code registered to a Samsung Account Compl. ¶84
U.S. Patent No. 12,093,760: Issued September 17, 2024, and titled System linked item (the "'760 Patent"), this patent claims a system comprising an item with a scannable code and a computer system Compl. ¶33 The computer system is configured to set customized action settings based on user input and, in response to a scan of the code, to perform an action that retrieves and transmits derived information Compl. ¶98
- Asserted Claims: At least independent claim 29 Compl. ¶98
- Accused Features: Samsung Galaxy Smartphones and Samsung Home Appliances that carry or display a scannable code registered to a Samsung Account Compl. ¶97
U.S. Patent No. 12,164,983: Issued December 10, 2024, and titled System linked item (the "'983 Patent"), this patent claims a system including an item with a "system-linked readable code" that itself comprises a customized action setting Compl. ¶34 A computer system receives customized information from a user, generates the action setting, generates the readable code, and is configured so that a scan of the code activates a response that generates information derived from, and not the same as, the user's customized information Compl. ¶112
- Asserted Claims: At least independent claim 1 Compl. ¶112
- Accused Features: Samsung Galaxy Smartphones that generate and act upon a system-linked readable code Compl. ¶111
U.S. Patent No. 12,393,809: Issued August 19, 2025, and titled System linked item including readable code (the "'809 Patent"), this patent claims a system with an item having a readable code associated with an action setting Compl. ¶35 A computer system receives customized information, generates the action setting and the code, and activates a computerized response upon receiving the code to generate information derived from the customized information Compl. ¶126
- Asserted Claims: At least independent claim 1 Compl. ¶126
- Accused Features: Samsung Galaxy Smartphones that carry a system-linked readable code associated with an action setting Compl. ¶125
III. The Accused Instrumentality
Product Identification
The complaint identifies a range of "Accused Products" including Samsung Galaxy Smartphones, Galaxy SmartTags, Samsung Smart TVs, Samsung Home Appliances, the SmartThings application and platform, Samsung Account services, Samsung Wallet, Samsung Digital Key, and Samsung Smart Switch Compl. ¶16 Compl. ¶46
Functionality and Market Context
The complaint alleges these products implement the patented architecture through features that generate, display, and act upon scannable codes Compl. ¶46 Examples cited include generating a QR code on a Galaxy smartphone to share Wi-Fi credentials without typing a password, registering a home appliance to a user's Samsung Account by scanning a QR code on the appliance, and inviting a guest to a SmartThings location via a temporary QR code Compl. ¶¶3, 47, 50-51 The core allegation is that these features operate with the Samsung Account and SmartThings services to generate dynamic, server-side responses based on user account settings, rather than returning static data from the code itself Compl. ¶47 Compl. ¶51
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint incorporates by reference claim chart exhibits that were not attached to the publicly filed document Compl. ¶40 The following analysis is based on the narrative infringement allegations provided in the complaint body.
'054 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method comprising: acquiring a system linked item comprising a physical item and system linked contact information, the system linked contact information being physically displayed on the physical item; | A Samsung Galaxy Smartphone is alleged to be a physical item that is acquired with system linked contact information physically displayed on it when it generates and displays a machine-readable code on its screen. | ¶59 | col. 3:30-40 |
| setting personalized action settings comprising personalized information in a computer system... the personalized action settings being linked to the system linked contact information in the computer system; | Personalized action settings (e.g., Wi-Fi credentials) are allegedly set in a computer system (Samsung's backend services) through user input and are linked to the contact information (the generated code). | ¶60 | col. 3:41-48 |
| and configuring the computer system to perform a response to user input of each of one or more action requests into the computer system, the one or more action requests representing the system linked contact information, | The computer system is allegedly configured to perform a response when a user input (e.g., scanning the code) representing the contact information is made. | ¶60 | col. 3:30-35 |
| the response to user input... comprising one or more computerized actions defined by the personalized action settings... comprising retrieving the personalized information and transmitting the personalized information... | The response allegedly includes retrieving and transmitting the personalized information (e.g., the network credentials) to connect a guest device. | ¶60 | col. 3:58-62 |
'976 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A linked item system comprising: a system linked item comprising a physical item displaying system linked contact information; | A Galaxy Smartphone is alleged to be a physical item that displays system linked contact information on its screen as a machine-readable code encoding user contact or network data. | ¶72 | col. 3:31-40 |
| and a computer system configured to perform the following acts: verifying a user access request in the computer system, the verifying comprising verifying that data from the user access request is linked to the system linked contact information in the computer system; | The computer system (Samsung Account and SmartThings services) allegedly verifies a user access request by verifying that data from the request is linked to the contact information. | ¶73 | col. 3:41-48 |
| in response to the verifying, permitting a user input request to set personalized action settings in the computer system...; receiving the user input request to set personalized action settings...; setting the personalized action settings...; | In response to verification, the system allegedly permits and receives a user's request to set personalized action settings linked to the contact information and sets them. | ¶73 | col. 3:58-62 |
| receiving user input representing the system linked contact information in the computer system; and | The system allegedly receives user input representing the system linked contact information (e.g., when another device scans the code). | ¶73 | col. 4:1-5 |
| in response to receiving the system linked contact information in the computer system, performing one or more personalized computerized actions defined by the personalized action settings... comprising retrieving the personalized information and transmitting the personalized information... | In response, the system allegedly performs actions defined by the personalized settings, including retrieving and transmitting the personalized information. | ¶73 | col. 4:5-10 |
- Identified Points of Contention:
- Scope Question: A potential issue for the '054 Patent is whether a transient, electronically-generated QR code on a smartphone screen meets the claim limitation "system linked contact information being physically displayed on the physical item." A defendant may argue this language requires a static, physically printed or affixed element as shown in many of the patent's figures '054 Patent, Fig. 1, whereas the plaintiff may argue a screen display on a physical device qualifies.
- Technical Question: A point of contention for the '054 Patent may be whether the accused system "retriev[es] the personalized information and transmitt[s] the personalized information." The complaint alleges the inventions involve generating "derived information that is not the same as the stored customized information" Compl. ¶2 If the accused system transmits derived data (e.g., a temporary access token) instead of the original personalized data (e.g., the user's Wi-Fi password), it raises the question of whether this specific claim element is met.
V. Key Claim Terms for Construction
The Term: "system linked contact information" (asserted in '054 claim 1; '976 claim 13)
Context and Importance: This term is the technological lynchpin of the asserted claims, representing the data that connects the physical item to the backend system. Its construction will determine the types of identifiers and codes covered by the patents and will be central to the infringement analysis for features like QR codes.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this information as a "contact-element(s) group" which can include a wide array of data types, such as phone numbers, web addresses, barcodes, reference IDs, and call-IDs, suggesting a broad scope beyond traditional contact details '054 Patent, col. 10:41-61
- Evidence for a Narrower Interpretation: The term itself contains the word "contact," and many primary embodiments show it as a phone number or web address on a for-sale sign '054 Patent, Fig. 1 A defendant may argue that the term should be limited to information that facilitates human or system contact, rather than any arbitrary data payload.
The Term: "physically displayed on the physical item" ('054 claim 1)
Context and Importance: The infringement theory for smartphones relies on a generated QR code on a screen meeting this limitation. Practitioners may focus on this term because the core infringement allegation (a transient, on-screen code) appears to differ from the patent's primary embodiments (static, printed information).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification includes an embodiment where contact information is displayed on a PDA screen, which could support the argument that an electronically generated image on a physical device screen is "physically displayed" ('054 Patent, col. 45:6-9, discussing FIG. 70).
- Evidence for a Narrower Interpretation: The patent's abstract and main figures consistently depict physical items like a "for sale sign" with pre-configured or written information '054 Patent, abstract '054 Patent, Fig. 1 '054 Patent, Fig. 46 This could support an interpretation that requires a more permanent or static physical marking, not a transient electronic display.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement.
- Inducement: The allegations are based on Defendants providing "product manuals, user guides, support articles, tutorials," and other materials that allegedly instruct and encourage customers to use the accused features in an infringing manner Compl. ¶63 Compl. ¶76
- Contributory Infringement: For the asserted system claims, the complaint identifies the "SmartThings application and platform software and the Samsung Account service software" as the material component supplied by Defendants Compl. ¶77 It is alleged this component has no substantial non-infringing use because it "operates only with Defendants' own devices and account services" Compl. ¶77
- Willful Infringement: Willfulness is alleged based on Defendants' knowledge of the patents as of the filing and service of the complaint Compl. ¶52 The complaint also pleads in the alternative that Defendants were willfully blind, alleging they are sophisticated participants who monitor patent activity in the field Compl. ¶53 Compl. ¶54
VII. Analyst's Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "physically displayed on the physical item," rooted in patent embodiments showing static, printed signs, be construed to cover a transient QR code generated on the screen of a smartphone, as alleged in the complaint?
- A key evidentiary question will be one of functional operation: do the accused Samsung systems perform the claimed step of "retrieving... and transmitting the personalized information" itself (as required by the '054 and '976 claims), or do they transmit different, "derived information" (as described in the complaint's technology overview and other asserted patents), and would such a distinction place them outside the scope of the asserted claims?
- A central legal question for the system claims will be one of attribution: has the Plaintiff alleged sufficient facts to show that Samsung "puts into service" and controls the entire claimed system-which includes both the end-user device and the backend server-such that Samsung can be held liable for direct infringement of the system claims as a single actor?