On January 9, plaintiff Princeps Secundus LLC filed a complaint against defendant Samsung (Princeps Secundus LLC v. Samsung Electronics Co., Ltd. et al 3:20-cv-00201-JSC) for patent infringement in the California Northern District Court. Princeps Secundus is represented by the Law Offices of Seth W. Wiener and Devlin Law Firm.
The patent-in-suit is registered U.S. Patent No. 6,703,963 (the ’963 Patent), issued in 2004. The patent is for “small-profile multifunctional input devices.” The inventor, Timothy B. Higgins, created “novel input devices and methods for operating them. The input devices utilize one or more functional modes and one or more domain levels associated with entering input values into the devices.” The patent addresses the shortcomings and drawbacks of the standard two-hand QWERTY keyboard for smaller electronic devices, where the keyboard is too big and the device is too small for two hands to be used. The patent adds level values to the input keys for different functional output.
According to the complaint, “[t]he present invention provides a multifunctional input device. The input device includes a functional mode which defines the mode of operation of the input device. Each functional mode includes one or more domain levels with each domain level containing one or more domain-level values. Each domain level-value within each functional mode is assigned to one of a plurality of programmable input keys. The domain-level value assigned to each input key controls the function of that input key within a given functionality and domain level. The present invention also includes a display to indicate the domain-level value associated with each of the programmable input keys within a given functionality.” This innovation is an improvement upon previous attempts to adapt QWERTY keyboards to portable electronic devices.
The patent fixes the size issue of the standard QWERTY keyboard for small electronic devices, the ability to use with a single hand, as well as increased versatility and utility in comparison to the QWERTY keyboard. The patent “provide[s] a new and novel solution to specific problems related to automating and customizing the process of entering data into small profile input devices by dynamically utilizing user specified control combinations. The claims of the patent in suit thus specify how interfaces for entering user data are manipulated to yield a desired result.” The complaint stated that this improves user experience and technology.
The complaint alleged that Samsung infringed and continues to infringe upon at least claims 1, 2, 3, 9, 12, and 60 of the ’963 Patent. Samsung phones with Samsung or third-party apps with keyboard components and the Android operating system. Samsung was previously made aware of this issue and had been sued by Princeps Secundus in another district court, which was dismissed without prejudice.
The complaint stated that Samsung has helped others infringe. “Samsung’s actions that aid and abet others such as their partners and customers to infringe include distributing the Accused Instrumentalities and providing instructional materials and/or services related to the Accused Instrumentalities.” Samsung also infringes by offering to sell, selling, importing and manufacturing of said infringing devices. The complaint alleged that Samsung has financially benefitted from this infringement. The complaint does not give any specific examples of Samsung’s infringement.
Princeps Secundus seeks an adjudication of infringement, compensation for damages and declaratory judgment.
Princeps Secundus has not only sued Samsung in relation to this patent, but it has also sued Apple, Google, Lenovo, and other companies under the name Princeps Interface Technologies. Some of those companies, including Apple and Google have countersued Princeps for declaratory judgment. These cases have either been in the Delaware District Court of the California Northern District Court.
