Plaintiff Nanoco Technologies filed a complaint against Samsung for patent infringement last Friday. The complaint was filed before the Texas Eastern District Court. Nanoco is represented by Ward, Smith & Hill.
The patents-in-suit are U.S. Patent Nos. 7,588,828 (“the ’828 patent”); 7,803,423 (“the ’423 patent”); 7,867,557 (“the ’557 patent”); 8,524,365 (“the ’365 patent”); and 9,680,068 (“the ’068 patent”). Nanoco developed nanoparticle and quantum dot technology. “Quantum dots created using Nanoco’s patented innovations have improved the visual aspects of consumer electronic display devices and made their large-scale synthesis and implementation commercially viable. Accordingly, quantum dots created by Nanoco’s patented innovations have become fundamental components of many premium LED TV models.” The technologies in the patents “generally relate to heavy metal-free quantum dots, synthesis of quantum dots, and use of quantum dot film resins in electronic display devices.”
Nanoco stated that many companies have licensed its patented technology or entered a joint development or supply agreements, however, Samsung has not and has thus infringed on Nanoco’s patents as a result of its use of this technology. Nanoco alleged that “Samsung also engaged with Nanoco as early as 2010 in order in order to evaluate Nanoco’s quantum dot technology for use in the emission material of Samsung’s LCD modules…Nanoco provided samples of its quantum dots to Samsung.” Samsung did not license Nanoco’s patented technology nor enter into an agreement with the company. Nanoco alleged that after it “disclosed its technology to Samsung, Samsung debuted a TV comprising quantum dots for the first time at Consumer Electronics Show in 2015…Samsung began incorporating cadmium-free quantum dot technology in its TV displays when it launched its newly-branded, premium QLED TV in 2017.” Samsung has claimed dominance as a result of its QLED TVs, a success that Nanoco claimed was due to the use of its patented technology.
Quantum dot technology improves the color quality for LED TVs. The patents discuss various aspects of this technology. For example, Samsung allegedly infringed upon at least claim 1 and 14 of the ’828 patent by “unlawfully importing into the United States or offering to sell, selling, or using within the United States, at least, QLED TV products incorporating quantum dots made by a process that infringes independent claim 14 of Nanoco’s ’828 patent.” Infringing Samsung products listed by the plaintiff included, for example, various sizes of the Class Q900 QLED Smart 8K UHD TV, Class Q60R QLED 4K UHD TV, Class Q70R QLED 4K UHD TV, Class Q60T QLED 4K HDR TV. Samsung also allegedly infringed the ’828 patent through the use of nanoparticles that contain molecular ion clusters. Samsung’s Quantum Dots contain “an InP core that is surrounded by an oxide layer and two Zn-based outer shells.” Nanoco provided numerous examples of Samsung’s infringement based on patent claims.
Nanoco has sought a judgment of willful, direct infringement, an award for damages, and an injunction to prevent Samsung from further infringement.