Dynamics Inc. v. Samsung Electronics Co., Ltd.

Background

Dynamics brought a patent-infringement action against Samsung Electronics Co., Ltd. and certain subsidiaries. Four patents were originally at issue, but the parties jointly stipulated that only U.S. Patent No. 8,827,153 (the “’153 Patent”) remained. The patent concerns technology for emulating the magnetic stripe of a credit or debit card by storing digital waveforms, converting them into an analog waveform, and running the resulting waveform through a wire coil.

The parties disputed the meanings of five claim terms or phrases. The court held a hearing to determine their proper construction. Claim construction is the court’s interpretation of patent-claim language, based primarily on the claims, the patent specification, and the patent’s prosecution history.

Court’s Analysis and Constructions

1. “Analog waveform”

Samsung proposed a definition involving a continuous wave with negative and positive peaks and movement through intervening values. Dynamics proposed the plain and ordinary meaning and argued that a real-world square wave falls within the term.

The court held that “analog waveform” means “a wave shape whose amplitude changes in a continuous fashion,” and that this construction includes real-world square waveforms. The court explained that although an ideal digital waveform may jump between two values, physical conditions mean that a real-world square wave necessarily passes through intervening values. It rejected Samsung’s proposed wording because it improperly focused on how the wave is created and could exclude wave shapes that the patent does not exclude.

2. “At least one track of magnetic stripe data” and its digital representation

Samsung proposed adding the word “complete,” defining the phrase as “at least one complete track of magnetic stripe data as defined by the ISO standards.” Dynamics proposed the plain and ordinary meaning, with the track defined by those standards.

The court adopted Samsung’s proposed construction. It found that both parties agreed the ISO standards define one track of magnetic-stripe data in a way that does not include partial tracks. Although the word “complete” was redundant, the court concluded that it was clarifying and consistent with Dynamics’ earlier descriptions of the patent as involving complete or entire tracks.

3. “A waveform generator operable to generate said analog waveform from a digital representation of said at least one track of magnetic stripe data”

Samsung proposed defining the term as a component that generates the analog waveform by converting a digital representation received as an input. Dynamics proposed the plain and ordinary meaning.

The court adopted the plain and ordinary meaning. It concluded that Samsung’s additions—“component” and the requirement that the digital representation be received as an input—would add confusion and improperly limit the term’s scope. The court also noted that Samsung had not previously sought construction of this phrase in the earlier proceedings it identified.

4. Retrieving a digital representation from multiple digital representations

Samsung proposed language stating that the representation must already exist in memory rather than be generated or built dynamically. Dynamics proposed the plain and ordinary meaning, specifying that the device reads the representation from memory.

The court adopted Dynamics’ proposed construction. It explained that “retrieve” ordinarily means obtaining something that already exists, including locating and bringing back information stored in memory. Because that meaning was already captured by “retrieve from memory,” the court found Samsung’s additional “on the fly” language unnecessary.

5. Retrieving a digital representation based on a button signal

Samsung proposed language stating that a button signal causes the device to read the representation from a memory location where it was stored before the button was selected. Dynamics proposed the plain and ordinary meaning.

The court construed the term according to its plain and ordinary meaning. It found that the phrase’s meaning was clear from its language, including the statement that the digital representation is retrieved from the device’s memory.

Disposition

The court adopted the claim constructions set out in the opinion. This opinion resolved the meaning of the disputed patent terms; it did not, in the text provided, decide infringement or validity.