The parties

The case is Sensay Technologies LLC v. Samsung Electronics Co., Ltd., No. 2:26-cv-00926 (E.D. Tex.). The complaint says Sensay is a Delaware limited liability company with its principal place of business in New York, New York. It says Samsung Electronics Co., Ltd. is a Korean corporation with its principal place of business in Suwon, Republic of Korea, and that Samsung Electronics America, Inc. is a New York corporation with its principal place of business in Englewood Cliffs, New Jersey, and a regular and established place of business in Plano, Texas. On information and belief, the complaint says Samsung Electronics America has announced a move of its U.S. headquarters from New Jersey to the Plano campus, with the transition to be completed by the end of 2026. Joinder is pleaded under 35 U.S.C. 299.

The complaint says Sensay is the owner by assignment of each patent in suit. A Rule 7.1 disclosure statement filed the same day identifies corporate parents Sensoriant, Inc. and Aylus Networks, Inc.

Resource Map claims

The complaint says the Resource Map patents share a priority claim to application 12/804,448, filed July 21, 2010. It identifies representative claim 1 of each.

U.S. Patent 9,949,060, titled System allowing or disallowing access to resources based on sensor and state information, issued April 17, 2018. Claim 1 covers a user device comprising a resource registry storing capabilities lists CLs received from one or more external resources available to and in proximity with the user device, an environment map comprising resource environment information obtained from the resource registry and physical environment information obtained from one or more sensors, and a recognition unit matching access policies of the user device with the environment map to dynamically assign a profile to the user device and controlling access to a functionality of the user device based on the profile.

U.S. Patent 10,003,948, titled System and method for provisioning user computing devices based on sensor and state information, issued June 19, 2018. Claim 1 covers a method for controlling access to a functionality of a user device comprising receiving a capabilities list CL from one or more external resources, storing each of the received CLs in a resource registry associated with the user device, dynamically updating the resource registry, determining an environment map comprising resource environment information obtained from the resource registry and physical environment information obtained from one or more sensors, matching access policies of the user device with the environment map to dynamically assign a profile, and controlling access to the functionality of the user device based on the profile, wherein the one or more external resources include an external resource connected to the user device via a wireless network and configured to deliver content to a user of the user device.

U.S. Patent 10,405,157, with the same provisioning title, issued September 3, 2019. Claim 1 covers a method for controlling access to a functionality of a user device comprising receiving a capabilities list CL from one or more external resources via a wireless network, storing each of the received CLs in a resource registry, dynamically updating the resource registry, determining an environment map comprising resource environment information obtained from the resource registry, matching access policies of the user device with the environment map to dynamically assign a profile, and limiting access to mobile applications running on the user device based on the profile. That claim's environment map is resource environment information. It does not recite physical environment information.

U.S. Patent 10,609,527, titled System and method for control and management of resources for consumers of information, issued March 31, 2020. Claim 1 covers a method for activating apps on a user device comprising receiving a capabilities list from one or more external resources, storing each of the received capabilities lists in a resource registry, receiving updated capabilities lists, dynamically updating the resource registry, determining an environment map comprising resource environment information and state information for the user device, applying predefined matching rules for comparing the environment map with situational profiles, displaying one or more recommended apps, and activating one of the recommended apps based on user input.

U.S. Patent 10,791,440, again with the provisioning title, issued September 29, 2020. Claim 1 covers a method for controlling access to a functionality of a user device comprising receiving a capabilities list CL from one or more external resources via a wireless network, storing each of the received CLs in a resource registry, updating the resource registry with one or more updated CLs, determining an environment map comprising resource environment information obtained from the resource registry, matching at least one access policy of the user device with the environment map to assign a profile, and limiting access to a mobile application running on the user device based on the profile.

IMS Gateway claims

The complaint says the IMS Gateway patents share a priority claim to application 11/166,407, filed June 24, 2005. Each is titled Associated device discovery in IMS networks. The representative claims are claim 21 of the '033 patent, claim 14 of the '084 patent, claim 20 of the '291, '479, and '605 patents, and claim 18 of the '164 and '772 patents.

U.S. Patent 9,468,033 issued October 11, 2016. Claim 21 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense a plurality of devices proximate to the mobile device, create the PAN for the plurality of devices proximate to the mobile device using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway between the cellular network and the plurality of devices in the PAN, control the PAN for the plurality of devices, and invite a Mediaserver MS or an Application server AS into the cellular network session, wherein during the cellular network session the mobile device is the only device visible to or directly addressable by the cellular network and the plurality of devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the plurality of devices as an intervening device.

U.S. Patent 9,999,084 issued June 12, 2018. Claim 14 covers a first mobile device configured to act as a switch in connection with a data network comprising a first transceiver to communicate with the data network, a second transceiver to communicate using short-range radio signals, and logic stored in a computer readable medium configured to create a first session using the first transceiver with the data network, create a second session using the second transceiver, allow devices proximate to the first mobile device to become aware of and register with the second network session, provide a switch between the first and second network sessions, wherein during the first and second sessions the first mobile device allows the plurality of devices registered in the second session to be given addresses that make them addressable in the first session and/or the second session, and the first mobile device may simultaneously receive or make voice calls using a circuit switched network without disrupting the first and/or second sessions.

U.S. Patent 10,085,291 issued September 25, 2018. Claim 20 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense one or more devices proximate to the mobile device, create the PAN for the one or more devices proximate to the mobile device using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway, control the PAN for the one or more devices, and invite a Mediaserver MS or an Application server AS into the cellular network session, wherein during the cellular network session the mobile device is the only device visible to or directly addressable by the cellular network and the one or more devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the one or more devices as an intervening device.

U.S. Patent 10,194,479 issued January 29, 2019. Claim 20 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense one or more devices proximate to the mobile device, create the PAN for the one or more devices proximate to the mobile device using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway, control the PAN, and invite a Mediaserver MS or an Application server AS into the cellular network session, wherein during the cellular network session the mobile device is the only device visible to or directly addressable by the cellular network and the one or more devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the one or more devices as an intervening device.

U.S. Patent 10,477,605 issued November 12, 2019. Claim 20 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense one or more devices with the mobile device, create the PAN for the one or more devices using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway, control the PAN, and invite a media server MS or an Application server AS into the cellular network session, wherein during the cellular network session the one or more devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the one or more devices as an intervening device.

U.S. Patent 10,736,164 issued August 4, 2020. Claim 18 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense one or more devices proximate to the mobile device, create the PAN for the one or more devices proximate to the mobile device using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway, control the PAN for the one or more devices, and invite a Mediaserver MS or an Application server AS into the cellular network session, wherein during the cellular network session the mobile device is the only device visible to or directly addressable by the cellular network and the one or more devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the one or more devices as an intervening device.

U.S. Patent 11,044,772 issued June 22, 2021. Claim 18 covers a mobile device configured to act as a switch in a session with a cellular network comprising a transceiver to communicate with the cellular network and logic stored in a non-transitory computer readable medium configured to sense one or more devices proximate to the mobile device, create the PAN for at least one of the one or more devices proximate to the mobile device using a local network, create a cellular network session, use both the local network and the cellular network session to provide a gateway, control the PAN for the one or more devices, and invite a Media server MS or an Application server AS into the cellular network session, wherein during the cellular network session the mobile device is the only device visible to and/or directly addressable by the cellular network and the one or more devices access the cellular network through the mobile device while the mobile device simultaneously maintains a voice call over a circuit switched network with which the mobile device communicates without use of any of the one or more devices as an intervening device.

What the complaint alleges about the phones

The complaint defines the accused products as Samsung smartphones and tablets, including the Galaxy S series, Galaxy Z Fold and Z Flip series, Galaxy Note series, Galaxy A series, and Galaxy Tab series, and variants and successors. On information and belief, the complaint says the Resource Map features include Extend Unlock, Do Not Disturb While Driving, Driving Mode, and Android Auto, and it notes a predecessor name, Smart Lock. It points to Bluetooth pairing, an accelerometer, and location. For the IMS Gateway patents, it points, on information and belief, to Mobile Hotspot and Bluetooth Tethering, SIP signaling for RCS and VoLTE, and circuit-switched voice calls such as 2G GSM or 3G UMTS. Charts are Exhibits M through X.

The Resource Map counts allege direct infringement under 35 U.S.C. 271(a), induced infringement under 35 U.S.C. 271(b), and willfulness, with knowledge alleged since at least the filing and service of the complaint. The IMS Gateway counts, Counts VI to XII, allege only past direct infringement under 35 U.S.C. 271(a) and seek damages; they do not plead inducement or willfulness. Google Patents lists each of the seven IMS Gateway patents as expired. The prayer asks for a judgment of direct infringement of each patent, inducement and willfulness of the Resource Map patents, damages under 35 U.S.C. 284 of no less than a reasonable royalty, enhanced damages up to three times on the Resource Map patents, an exceptional-case finding under 35 U.S.C. 285, and a permanent injunction, or in the alternative an ongoing royalty, on the Resource Map patents. Sensay alleges that it has not made or sold a covered product and, on information and belief, that no predecessor in interest or licensee has done so, so 35 U.S.C. 287(a) does not limit damages, and in the alternative that Samsung had notice no later than the complaint. Sensay demands a jury.

What to watch next

Watch for Samsung's answer or an early motion.