U.S. District Judge Haywood Gilliam, Northern District of California. Photo: Jason Doiy/ALM

Samsung has succeeded in beating back a non-practicing entity where Apple failed.

Samsung Electronics Co. Ltd. and Ironworks Patents LLC stipulated to noninfringement and invalidity of two Ironworks smartphone patents last week following a claim construction order from U.S. District Judge Haywood Gilliam of San Francisco last month.

Ironworks' predecessor, MobileMedia Ideas LLC, had asserted the same patents and many others against Apple Inc. a few years ago and wound up winning a $10.7 million judgment in Delaware federal court, albeit on one of the patents not asserted against Samsung.

MobileMedia is an entity formed by MPEG LA, Nokia and Sony in 2010 to license some of their technology. Ironworks acquired the MobileMedia portfolio and took over the Apple and Samsung litigation last year.

Ironworks claimed that Samsung smartphones infringe its 6,427,078 patent, which it describes as the first to claim a tightly integrated multifunctional camera and telephone, and its 5,915,239 patent on a voice-controlled device that can recall stored phone numbers.

Samsung's Paul Hastings team, led by partners Allan Soobert and Elizabeth Brann and associate Steven Moseley, got the case transferred from Florida to the Northern District of California last year. They then argued that the phrase “camera unit” used in the patent must include optics, a microprocessor, memory, a battery and an interface. Samsung's accused products don't meet all those limitations, it argued.

Ironworks, represented by Global IP Law Group and Banys, argued that “camera unit” didn't need to be construed, but if it did, then Gilliam should have used U.S. District Judge Sue Robinson's simple construction from the Apple case: “data collection apparatus for obtaining image information.”

Gilliam pointed to a Federal Circuit ruling from an appeal in that case in which the court implied a more expansive construction. The appellate court observed the “camera unit” is depicted in the claim specification, and the diagram includes optics, a microprocessor and a battery. “This finding tracks Samsung's proposed construction,” Gilliam wrote.

The '239 patent, meanwhile, claims a “means for interpreting the received voice commands,” but doesn't include an algorithm that spells out what the means are. Ironworks argued it wasn't necessary because voice recognition was well-known among persons of skill in the art. But Gilliam pointed to long-standing Federal Circuit case law that “a bare statement that known techniques or methods can be used does not disclose structure.”

Consequently, Ironworks and Samsung moved for a judgment of noninfringement and invalidity, and Ironworks will presumably appeal Gilliam's claim construction to the Federal Circuit. “The court finds that the stipulation is well taken and is hereby granted,” Gilliam wrote in a Thursday order.

Apple was found to have infringed Ironworks' RE39,231 patent, which is related to ring-silencing features.

Correction: A previous version of this article said that Samsung had succeeded in knocking out a patent where Apple had failed. Although MobileMedia Ideas asserted the same three patents against each company, it asserted many additional patents against Apple, with a patent on ring-silencing technology that was not asserted against Samsung leading to the $10.7 million verdict against Apple.