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Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 1 of 11
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`CONTEXT DIRECTIONS LLC
`
`Plaintiff,
`
`Civil Action No. 6:20-cv-1063
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Context Directions LLC (“CONTEXT” or “Plaintiff”), for its Complaint against
`
`Defendant Samsung Electronics Co., Ltd., (referred to herein as “SAMSUNG” or “Defendant”),
`
`alleges the following:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2. Plaintiff CONTEXT is a limited liability company organized under the laws of the
`
`State of Delaware with a place of business at 261 West 35th Street, Suite 1003, New York, NY
`
`10001.
`
`3. Upon information and belief, SAMSUNG is a corporation organized under the laws
`
`of South Korea, with a place of business at 1-1, Samsungjeonja-ro, Hwaseong-si, Gyeonggi-do,
`
`South Korea. Upon further information and belief, SAMSUNG sells, offers to sell, and/or uses
`
`products and services throughout the United States, including in this judicial district, and
`
`
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`

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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 2 of 11
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`introduces infringing products and services into the stream of commerce knowing that they
`
`would and will be sold and/or used in this judicial district and elsewhere in the United States.
`
`JURISDICTION AND VENUE
`
`4.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, Title 35 of the United States Code.
`
`5.
`
`6.
`
`7.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`Venue is proper in this judicial district under 28 U.S.C. § 1400(b).
`
`Venue is proper as to SAMSUNG in this judicial district under 28 U.S.C.
`
`§1391(c)(3). On information and belief, SAMSUNG is not resident in the United States and may
`
`be sued in any judicial district.
`
`8.
`
`This Court has personal jurisdiction over the SAMSUNG under the laws of the
`
`State of Texas, due at least to its substantial business in Texas and in this judicial district,
`
`directly or through intermediaries, including: (i) at least a portion of the infringing activity
`
`alleged herein; and (ii) regularly doing or soliciting business, engaging in other persistent courses
`
`of conduct and/or deriving substantial revenue from goods and services provided to individuals
`
`in the State of Texas.
`
`The Invention
`
`BACKGROUND
`
`9.
`
`Pawel Aksamit is the inventor of U.S. Patent No. 10,142,791 (“the ’791 patent”).
`
`A true and correct copy of the ’791 patent is attached as Exhibit A. The ’791 patent resulted
`
`from the pioneering efforts of Mr. Aksamit (hereinafter, “the Inventor”) in the area of methods of
`
`detecting context in mobile devices, such as mobile phones, laptops, PDAs, tablets, watches,
`
`music players, satellite navigation devices and cameras, as well as the devices themselves having
`
`such context detection capability. Detecting context in mobile devices includes, for example, the
`
`
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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 3 of 11
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`awareness of a device regarding the environment in which it is located, the activity of the user
`
`and/or the circumstances of the user of the device, all of which can help to improve the usability
`
`of the device, as well as the comfort and safety of its use. (See ’791 patent at 1:28-36.)
`
`10.
`
`The ‘791 patent includes claims directed to a method for detecting the context of a
`
`mobile device, as well as a mobile device having such detection capability, where the mobile
`
`device has a plurality of sensors assigned to sensor groups arranged in a hierarchy, along with
`
`classifiers assigned to the sensor groups and a context detection module that activates and adapts
`
`the classifiers to evaluate the context of the mobile device based on signals from one or more of
`
`the sensors.
`
`11.
`
`At the time of the Inventor’s pioneering efforts, there were other methods known
`
`for addressing the problem of context detection in a mobile device. One of the most widely
`
`implemented technologies employed the device’s sensors to detect context by indirect means
`
`only. In that type of system, for example, one could detect that a mobile device is located in a
`
`moving vehicle by determining its approximate position from signals of base stations for cellular
`
`phones, and then calculating the average speed of the device. However, those types of systems
`
`were not very accurate and resulted in uncertainty as to the position of the device on the order of
`
`a few hundred meters to several kilometers, as well as frequent false classifications indicating the
`
`movement of the device when that was not the case. (See ’791 patent at 1:57-2:4.)
`
`12.
`
`Other methods could be used to detect whether a mobile device is in a moving
`
`vehicle by analyzing the speed of the device using a global satellite positioning (“GPS”) system.
`
`While this provided more accurate positioning than using the signals of mobile phone cell
`
`towers, the GPS receiver consumed significant amounts of energy and unacceptably reduced the
`
`life of the mobile device’s battery. (See ’791 patent at 2:5-14.)
`
`
`
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`13.
`
`Another system used on an industrial scale utilized a vehicle-mounted, short-
`
`range radio transmitter and a mobile device equipped with a receiver that was compatible with
`
`the transmitter. The system assumed the mobile device was in a vehicle when it was in range of
`
`the transmitter, but an obvious disadvantage of this system was the need for the transmitter in the
`
`vehicle. (See ’791 patent at 2:30-45.)
`
`14.
`
` Yet another method for specifying a device’s context was based on analysis of
`
`signals from different sensors in the device, such as microphones, accelerometers, light sensors,
`
`magnetic field sensors, compasses, cameras and others. However, information from the signals
`
`of an individual sensor often was not sufficient to accurately determine the device’s context, so
`
`most of the known methods of this sort used parallel analysis of signals from multiple sensors.
`
`While that increased the effectiveness of the classification, it also increased power consumption
`
`and caused a shorter battery life for the mobile device. (See ’791 patent at 2:54-3:4.)
`
`15.
`
`The’791 patent describes technical improvements and addressed technical
`
`problems with other prior systems. The ‘791 patent describes an accurate and efficient method
`
`for determining the context of a mobile device based on signals from sensors found in such
`
`mobile devices.
`
`16.
`
`As one example, the ‘791 patent describes a mobile device having a plurality of
`
`sensors assigned to groups arranged in a hierarchy, along with classifiers assigned to the sensor
`
`groups, and a context detection module configured to activate and adapt the classifiers to
`
`evaluate the context of the mobile device based on signals from one or more of the sensors.
`
`Each classifier is adapted to detect the context of the device based on readings from the sensors
`
`belonging to its given group. The context detection module is configured to evaluate the context
`
`of the mobile device by reading the result of the classification indicated by an active group
`
`
`
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`classifier. The context detection module may also, for example, adapt the configuration of the
`
`classifiers associated with a given sensor group based on the results of classifications indicated
`
`by the classifiers associated with a higher level sensor group. (See ’791 patent at 5:19-41.)
`
`Advantages
`
`17.
`
`The ’791 patent describes a number of advantages over certain prior systems and,
`
`in particular, improves the operation of context detection in a mobile device (e.g. by making it
`
`more accurate and efficient). The improvements in context detection may be achieved by a
`
`variety of features that correspond to features recited in the claims, aspects of which are forth in
`
`this Complaint.
`
`18.
`
`The ’791 patent also describes equipping a mobile device with a context detection
`
`module and classifiers, where the sensors of the mobile device are assigned to at least two sensor
`
`groups, each of which comprises at least one sensor, and each such group is allocated a classifier
`
`adapted to detect the context of the device based on the indications of the sensors belonging to
`
`the given sensor group. The groups of sensors are ordered hierarchically, and the context of the
`
`mobile device is detected by reading a classification result indicated by the classifier of the
`
`currently active group of sensors in the mobile device. When an identified context is detected,
`
`the power supply of the sensors in the lower group may be switched on and classification in a
`
`group with a higher level activated. The context of the mobile device is read based on the higher
`
`group’s classifier, and based on the results of the classification indicated by the higher group’s
`
`classifiers, the configuration of the lower group’s classifiers is adapted. (See ’791 patent at 3:67-
`
`4:18.)
`
`19.
`
`Another advantage of the ’791 patent relates to detecting the context of a mobile
`
`device when a user is driving a car. It is inadvisable in such circumstances, for example, to send
`
`
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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 6 of 11
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`and receive text messages. On the other hand, in those same circumstances, it might be
`
`advantageous to activate other functions, like navigation, or download information from an
`
`external database on known hazards on the roads and to inform the user when he is approaching
`
`them, through a message of a tone, voice, visual, or any combination thereof. (See ’791 patent at
`
`1:37-56.) The use of certain embodiments described by the ‘791 patent enables this to occur by
`
`effectively detecting the context of the mobile device so that the appropriate sensors in the
`
`mobile device are activated in an efficient manner.
`
`20.
`
`Yet another advantage of the ’791 patent concerns efficiency. The sensor groups
`
`in the mobile device are ordered hierarchically, such that the total amount of energy required to
`
`determine a classification result in lower level groups is less than the amount of energy required
`
`to determine the result of the classification in groups of higher levels. That arrangement,
`
`coupled with the context detection module’s adapting of the configuration of the lower level
`
`classifier based on classification results returned by classifiers of a higher level, results in greater
`
`energy efficiency as the adaptations proceed. (See ’791 patent at 6:1-14.)
`
`21.
`
`CONTEXT believes that the ’791 patent presents significant commercial value for
`
`companies like SAMSUNG. Indeed, today's mobile devices, including SAMSUNG’s products
`
`at issue in this case, are equipped with a large number of different types of sensors, which allow,
`
`inter alia, automatic activation and deactivation of individual functions or to change
`
`configuration of mobile devices, depending on the context. Awareness of the context improves
`
`the usability of these devices.
`
`Technological Innovation
`
`22.
`
`The ’791 patent describes embodiments that address technical problems related to
`
`context detection for mobile devices. The ’791 patent describes effective and efficient methods
`
`
`
`Page 6 of 11
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`

`

`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 7 of 11
`
`for determining the context of a mobile device by using a context detection module and
`
`associated classifiers to evaluate that context based on signals from various types of sensors in
`
`that mobile device.
`
`23.
`
`As the ’791 patent explains, a major limitation of some prior art systems for
`
`detecting the context of a mobile device was the indirect means of that detection, such as
`
`detecting that a mobile device is located in a moving vehicle by determining its approximate
`
`position from signals of base stations for cellular phones or through a GPS system, which were
`
`either inaccurate (as with cell tower system) and/or inefficient (as with the GPS system, which
`
`more rapidly drained the battery of the mobile device). (See ’791 patent at 1:57-2:4 and 2:5-14.)
`
`Other known methods consisted of parallel analysis of signals from multiple sensors in the
`
`mobile device, which resulted in a substantial increase in the effectiveness of the classification.
`
`However, that increase in effectiveness was only achieved at the expense of increased power
`
`consumption, and thus a shorter time of operation of a battery-powered mobile device. (See
`
`’791 patent at 2:54-3:4.) The ‘791 patent describes embodiments that overcome the limitations
`
`of such prior systems and addresses technical problems.
`
`24.
`
`The claims of the ’791 patent do not merely recite the performance of some well-
`
`known business practice from the pre-Internet world, along with the requirement to perform it on
`
`the Internet or through the mobile device. Instead, the claims of the ’791 patent recite inventive
`
`concepts that are deeply rooted in engineering technology, and overcome problems specifically
`
`arising out of how to ascertain the context of a mobile device based on signals from its various
`
`sensors.
`
`25.
`
`In addition, the claims of the ’791 patent recite inventive concepts related to
`
`improved functioning of the mobile device itself, particularly by assigning the plurality of
`
`
`
`Page 7 of 11
`
`

`

`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 8 of 11
`
`sensors in the mobile device to groups arranged in a hierarchy, while utilizing classifiers
`
`assigned to the sensor groups and a context detection module configured to activate and adapt
`
`the classifiers to evaluate the context of the mobile device based on signals from one or more of
`
`the sensors. More specifically, each classifier is adapted to detect the context of the device based
`
`on readings from the sensors belonging to its given group, while the context detection module is
`
`configured to evaluate the context of the mobile device by reading the result of the classification
`
`indicated by the currently active sensor group's classifier. The context detection module also
`
`adapts the configuration of the classifiers associated with a given sensor group based on the
`
`results of classifications indicated by the classifiers associated with a higher level sensor group.
`
`(See ’791 patent at 5:19-41.) The foregoing, particular configuration used in the system of
`
`context detection improves the accuracy and efficiency of that detection in mobile devices. (See
`
`’791 patent at 6:44-7:17.)
`
`26. Moreover, the claims of the ’791 patent recite inventive concepts that are not
`
`merely routine or conventional use of mobile device or context detection technology. Instead,
`
`the patented invention of the ’791 patent is directed to a novel solution to specific problems
`
`related to methods of context detection.
`
`27.
`
`The ’791 patent does not preempt all the ways of detecting the context of a mobile
`
`device based on signals from its sensors. Nor does the ’791 patent preempt any other well-
`
`known or prior art technology.
`
`28.
`
`Accordingly, the claims in the ’791 patent recite a combination of elements that
`
`amounts to significantly more than a patent-ineligible abstract idea.
`
`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 9,807,791
`
`29.
`
`The allegations set forth in the foregoing paragraphs 1 through 28 are
`
`incorporated into this First Count for Relief.
`
`
`
`Page 8 of 11
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`

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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 9 of 11
`
`30.
`
`On October 31, 2017, the ’791 patent was duly and legally issued by the United
`
`States Patent and Trademark Office under the title “Method of Detecting Context of a Mobile
`
`Device and a Mobile Device with a Context Detection Module.”
`
`31.
`
`CONTEXT is the assignee and owner of the right, title and interest in and to the
`
`’791 patent, including the right to assert all causes of action arising under said patent and the
`
`right to any remedies for infringement of it.
`
`32.
`
`Upon information and belief, SAMSUNG has and continues to directly infringe
`
`one or more claims of the ’791 patent by selling, offering to sell, making, using, importing and/or
`
`providing and causing to be used SAMSUNG’s mobile phone products, including, for example,
`
`the SAMSUNG Galaxy S10, S10+, S10e, Note 10, Note 10+, S20, S20+, S20 Ultra (see, e.g.,
`
`https://www.samsung.com/us/mobile/galaxy) (the “Accused Phones”), as well as SAMSUNG’s
`
`smart watch products, including, for example, the SAMSUNG Galaxy Watch, Galaxy Watch
`
`Active and Galaxy Watch Active2 (see, e.g., https://www.samsung.com/us/mobile/galaxy) (“the
`
`Accused Watches, and together with the Accused Phones, referred to in this Complaint as “the
`
`Accused Instrumentalities”).
`
`33.
`
`Upon information and belief, the Accused Instrumentalities include a mobile
`
`device and perform a method for detecting the context of the mobile device, where the mobile
`
`device has a plurality of sensors assigned to sensor groups arranged in a hierarchy, along with
`
`classifiers assigned to the sensor groups, and a context detection module that activates and adapts
`
`the configuration of the classifiers, and evaluates the context of the mobile device based on
`
`signals from one or more of the sensors.
`
`34.
`
`An exemplary infringement analysis showing a representative mapping of claims
`
`1 and 14 of the ’791 patent to an illustrative Accused Instrumentality of the ’791 patent is set
`
`
`
`Page 9 of 11
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`

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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 10 of 11
`
`forth in Exhibit B. This infringement analysis is necessarily preliminary, as it is provided in
`
`advance of any discovery provided by SAMSUNG with respect to the ’791 patent. CONTEXT
`
`reserves all rights to amend, supplement and modify this preliminary infringement analysis.
`
`Nothing in the attached chart should be construed as any express or implied contention or
`
`admission regarding the construction of any term or phrase of the claims of the ’791 patent.
`
`35.
`
`The Accused Instrumentalities infringed and continue to infringe at least claims 1
`
`and 14 of the ’791 patent during the pendency of the ’791 patent.
`
`36.
`
`CONTEXT has been and continues to be harmed by Defendant SAMSUNG’s
`
`infringing activities.
`
`JURY DEMAND
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, CONTEXT demands a trial
`
`by jury on all issues triable as such.
`
`
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff CONTEXT demands judgment for itself and against Defendant
`
`SAMSUNG as follows:
`
`A.
`
`B.
`
`An adjudication that the Defendant SAMSUNG has infringed the ’791 patent;
`
`An award of damages to be paid by SAMSUNG adequate to compensate
`
`CONTEXT for SAMSUNG’s past infringement of the ’791 patent, and any continuing or future
`
`infringement through the date such judgment is entered, including interest, costs, expenses and
`
`an accounting of all infringing acts including, but not limited to, those acts not presented at trial;
`
`C.
`
`A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of
`
`CONTEXT’s reasonable attorneys’ fees; and
`
`
`
`Page 10 of 11
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`

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`Case 6:20-cv-01063-ADA Document 1 Filed 11/17/20 Page 11 of 11
`
`D.
`
`An award to CONTEXT of such further relief at law or in equity as the Court
`
`deems just and proper.
`
`Dated: November 17, 2020
`
`
`
`
`DEVLIN LAW FIRM LLC
`
`
`
`/s/ James M. Lennon
`James M. Lennon
`jlennon@devlinlawfirm.com
`Timothy Devlin (pro hac vice forthcoming)
`tdevlin@devlinlawfirm.com
`Paul Richter (pro hac vice forthcoming)
`1526 Gilpin Ave.
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`
`Attorneys for Plaintiff Context Directions LLC
`
`
`
`
`
`
`Page 11 of 11
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`

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