Pictiva Displays International Ltd. v. SAMSUNG ELECTRONICS CO., LTD.
2:23-cv-00495
E.D. Tex.Jun 27, 2025Background:
- Plaintiffs Pictiva Displays International, Ltd. and Key Patent Innovations Limited alleged that Samsung Electronics Co. and Samsung Electronics America infringed six patents related to OLED technology.
- The case focused on claim construction disputes across multiple patents, primarily regarding the interpretation of technical terms in the context of OLED encapsulation, optoelectronics, organic electronics, device structures, and methods of manufacture.
- The court considered parties’ briefing, hearings, and additional evidence, applying standard claim construction principles based on ordinary and customary meanings from the perspective of a skilled artisan at the time of invention.
- Key factual disputes included the meaning of terms like “upon,” “planarization layer,” “selectively depositing,” and others, as well as potential indefiniteness of certain claims.
- Prosecution history and technical context were heavily relied upon, with both parties citing prior patents, prosecution arguments, and scientific definitions.
- The opinion resolved nearly two dozen terms, providing detailed analysis of technical meanings, the scope of disclaimer during prosecution, and situations warranting plain and ordinary meaning.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of "upon" (’389 Patent) | "Upon" means either directly or indirectly on devices | "Upon" requires direct contact; prior art and prosecution history support this | Plain and ordinary meaning; does not require direct contact |
| "Planarization layer" definition | Should provide a planar surface | Must interrupt propagation of defects and not reproduce underlying topography | Construed as interrupting defects and not reproducing topography |
| "Selectively depositing" scope | Depositing in desired areas; can allow subsequent removal | Must exclude subsequent removal; only depositing in selected areas | Means depositing a material in desired areas (removal not excluded) |
| Potential indefiniteness of "an encapsulation one of disposed upstream and disposed downstream" (’547 Patent) | Requires either position, not both; no indefiniteness | Language requires both positions, thus indefinite | Term is not indefinite; requires either upstream or downstream, not both |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (standard for claim construction is ordinary and customary meaning in the context of the intrinsic evidence)
- Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996) (claim construction is a court’s responsibility)
- Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898 (2014) (standard for indefiniteness is reasonable certainty for skilled artisans)
- U.S. Surgical Corp. v. Ethicon, Inc., 103 F.3d 1554 (Fed. Cir. 1997) (claim construction clarifies but need not restate every term)