Exhibit 4

Case 2:23-cv-00199-JRG Document 1-4 Filed 05/05/23 Page 1 of 28 PageID #: 88
Samsung – Smartphones and Tablets (models with IR cameras, models having cameras with IR 

sensitivity, and models with the Iris Scan feature. See Product List at end for models)

Infringement of the ‘112 patent

Claim 1 Evidence

1. A method of 

measuring the 

magnitude of 

electromagnetic 

radiation in a selected 

location by a mobile 

communication device, 

comprising the steps of:

The Samsung smartphone performs a method of measuring the magnitude of

electromagnetic radiation in a selected location.

For example, when the IR sensor is used for temperature sensing, or the IR 

camera is used to take an IR image (e.g. as in a scenic photo or for the Iris 

Scan feature) the smartphone measures the magnitude of infrared 

electromagnetic radiation received by the smartphone’s IR camera (or IR 

sensor) from the location at which the IR camera/sensor is aimed.

For example, the Galaxy S4 and Note 3 models have an IR sensor, which is a 

smartphone/tablet module that is capable of measuring the magnitude of 

infrared electromagnetic radiation from an external source.

[1]

For example, the Galaxy S21 Plus smartphone includes an IR camera, which 

1

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is a smartphone module that is capable of measuring the magnitude of 

infrared electromagnetic radiation from a location at which the camera is 

aimed.

[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature, whereby the IR camera measures 

the magnitude of infrared radiation reflected by a user’s eyes, a location at 

which the camera is aimed, to distinguish unique characteristics of the user’s

eyes.

2

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[3]

3

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[4]

providing a mobile 

communication device 

that comprises an 

enclosure, a digital 

imaging sensor having a 

first field of view, such 

sensor is for generating 

a digital image of the 

selected location, 

The Samsung smartphone further provides a mobile communication device 

that comprises an enclosure and a digital imaging sensor that has a first field

of view. The sensor is for generating a digital image of the selected location.

For example, the smartphone includes an enclosure for housing a digital 

image sensor, among other components of the smartphone. The digital 

image sensor has a field of view (e.g. outwards from the rear of the 

smartphone) and is for generating a digital image of a subject or location at 

which it is aimed. 

4

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For example the Galaxy S4 has 13.1 MP CMOS image sensor within an 

enclosure, which is also referred to herein as a housing.

[6]

[6]

For example, the Galaxy S21 has 12MP BSI CMOS image sensor within an 

enclosure, which is also referred to herein as a housing.

5

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[7]

 [7]

[7]

 [7]

For example, the Galaxy S9+ has a 12.2 MP BSI CMOS image sensor within 

6

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an enclosure, which is also referred to herein as a housing.

[8]

 [8]

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a computer, The Samsung smartphone further provides a computer.

For example, the SoC CPU device includes a main processor for performing 

computational processing.

For example the Galaxy S4 includes a Qualcomm Snapdragon SoC CPU 

device and RAM memory, as a computer: 

[6]

[6]

For example, the Galaxy includes a Qualcomm Snapdragon SoC CPU device 

and RAM memory, as a computer:

8

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[7]

[7]

For example, the Galaxy S9+ includes a Qualcomm Snapdragon SoC CPU 

device and RAM memory, as a computer:

[8]

9

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[8]

and an output 

component for 

conveying information to

an operator;

The Samsung smartphone further provides an output component for 

conveying information to an operator. 

For example, the smartphone also includes a touchscreen display for 

conveying information to an operator.

For example the Galaxy S4 includes an AM-OLED touchscreen display: 

[6]

10

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[6]

For example, the Galaxy S21 includes an AM-OLED touchscreen display:

[7]

11

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[7]

For example, the Galaxy S9+ includes an AM-OLED touchscreen:

[8]

12

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[8]

coupling to the 

enclosure a module that 

is responsive to intensity

of the electromagnetic 

radiation in a selected 

spectral range;

During manufacturing of the smartphone, Samsung couples to the enclosure 

a module that is responsive to intensity of the electromagnetic radiation in a 

selected spectral range.

For example, the IR camera/sensor of the smartphone is responsive to 

electromagnetic radiation in the infrared range and is coupled to the 

smartphone’s housing.

For example, the Galaxy S4 and Note 3 models have an IR sensor, which is a 

smartphone/tablet module that is capable of measuring the magnitude of 

electromagnetic radiation in the infrared range. The IR sensor is coupled to 

the enclosure of the Galaxy S4/Note 3.

13

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[1]

For example, the Galaxy S21 Plus smartphone includes an IR wide angle 

camera, which is a smartphone module that is capable of measuring the 

magnitude of electromagnetic radiation in the infrared range. The IR wide 

angle camera is coupled to the enclosure of the Galaxy S21.

14

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature, whereby the IR camera measures 

the magnitude of electromagnetic radiation in the infrared range that is 

reflected by a user’s eyes to distinguish unique characteristics of the user’s 

eyes. The IR camera is coupled to the enclosure of the Galaxy S8, S8+, S9, 

S9+ or Note 8 models.

15

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[3]

16

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[4]

enabling positioning the 

enclosure in a vicinity of 

the selected location;

The Samsung smartphone enables positioning the enclosure in a vicinity of 

the selected location.

For example, the smartphone is handheld and mobile, therefore the 

enclosure and likewise the IR camera/sensor can be positioned in the vicinity 

of the location that is the source of infrared radiation.

For example, due to the handheld and mobile nature of the smartphone, the 

smartphone can be positioned such that it is in the vicinity of an external 

surface emitting infrared radiation in order to take a temperature reading, or 

17

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in the vicinity of a subject and pointed thereat to take an IR wide angle 

image of the subject, or in the vicinity of a user and pointed at the user’s 

eyes to use the Iris Scan feature, as the case may be for a given smartphone/

tablet model.

For example, the Galaxy S4 and Note 3 models have an IR sensor. To take a 

temperature reading, the S4 or Note 3 tablet needs to be placed in the 

vicinity of infrared electromagnetic radiation from an external source. The 

handheld and mobile nature of the Galaxy S4 and Note 3 models makes this 

positioning easy to perform.

[1]

For example, the Galaxy S21 Plus smartphone includes an IR camera. In 

order to take an IR photo of a subject, the smartphone needs to be 

positioned so that the IR camera is in the vicinity of the subject and pointed 

at the subject. The handheld and mobile nature of the Galaxy S21 model 

makes this positioning easy to perform.

18

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature. In order to use the Iris Scan feature, 

the smartphone needs to be positioned in the vicinity of the user’s face with 

the IR camera pointed at the user’s eyes. The handheld and mobile nature of 

the Galaxy S8, S8+, S9, S9+ and Note 8 models makes this positioning easy 

to perform.

19

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[3]

20

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[4]

enabling the module for 

generating a signal 

representative of the 

electromagnetic 

radiation;

The Samsung smartphone enables the module to generate a signal that is 

representative of the electromagnetic radiation.

For example, the IR camera/sensor generates a signal responsive to the 

infrared electromagnetic radiation received from the location or subject at 

which the IR camera is pointed, or from the vicinity in which the smartphone 

is placed. The design and manufacture of the smartphone itself enables the 

IR camera/sensor to generate the signal.

For example the IR sensor in the Galaxy S4 and Note 3 models produces a 

21

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signal that is used by the SoC processor to provide a numeric temperature 

reading to the user via the display. The temperature reading is 

representative of the infrared electromagnetic radiation received by the IR 

sensor.

[1]

For example the IR camera in the Galaxy S21 Plus model generates an IR 

image signal that is representative of the infrared electromagnetic radiation, 

e.g. hotter objects appear brighter in the image, which enables a user to 

distinguish hot objects from colder objects, bare earth from vegetation etc.

22

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models used for the Iris Scan feature generates an image signal responsive 

to the infrared electromagnetic radiation received from the user’s iris. 

23

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[4]

enabling processing said

signal to extract 

The Samsung smartphone enables processing the signal to extract 

information related to intensity of the electromagnetic radiation in the 

24

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information related to 

intensity of the 

electromagnetic 

radiation in the selected 

location, and

selected location.

For example, the main processor in the SoC device processes the signal to 

extract information of the infrared electromagnetic radiation, in the location 

of the IR sensor or at which the IR camera is pointed in the case of the IR 

wide angle camera and Iris Scan feature. The design and manufacture of the 

smartphone itself enables the SoC device to process the signal.

For example the IR sensor in the Galaxy S4 and Note 3 models produces a 

signal that is used by the SoC processor to provide a numeric temperature 

reading to the user via the display.[1]

For example the IR camera in the Galaxy S21 Plus model generates an IR 

image signal that is representative of the infrared electromagnetic radiation 

and provides the image to the user on the display of the smartphone. [2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models used for the Iris Scan feature generates an image signal responsive 

to the infrared radiation received from the user’s iris. The SoC device 

processes the signal to extract information, based in part on the intensity of 

the received infrared electromagnetic radiation, to determine characteristics 

of the user’s iris. If the characteristics sufficiently match previously recorded 

characteristics, the SoC unlocks the smartphone. [3] [4] [5]

enabling sending said 

information to the 

output component for 

conveying the 

information to the 

operator.

The Samsung smartphone enables sending the information to the output 

component for conveying the information to the operator.

For example, depending on the feature being activated, the SoC processor 

sends the information to the touchscreen display, which causes the display to

be unlocked as in the case of the Iris Scan feature, or to display a 

temperature, or to display an IR image captured with the IR camera. The 

design and manufacture of the smartphone itself enables the SoC device to 

send the information to the touchscreen display. [1] [2] [3] [4] [5]

25

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Product List:

Smartphones with IR cameras: Galaxy S4 and Note3 smartphones

Smartphones with wide camera having near IR sensitivity: Galaxy S21 Plus smartphone

Smartphones with the Iris Scan feature: Galaxy S8, S8+, S9, S9+ and Note 8 smartphones/tablets

References:

[1] Galaxy S4 and Note3 smartphones

https://www.phonearena.com/news/can-smartphone-take-temperature_id121600

[2] Galaxy S21 Plus smartphone

https://www.youtube.com/watch?v=l5rWDvzJJHQ#:~:text=Samsung%20Galaxy%20S21%20Plus%20%2D

%20Wide%20Camera%20Modified%20for%20Near%20Infrared%20Sensitivity,-761%20views%201

video at 0:08

[3] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones/tablets

https://www.samsung.com/in/support/mobile-devices/why-do-we-use-ir-infrared-ray-for-iris-scan-insamsung-galaxy-s8-plus/

[4] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones

https://www.howtogeek.com/404731/are-ir-scanners-in-phones-bad-for-your-eyes/

[5] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones

https://www.samsung.com/ph/support/mobile-devices/what-is-iris-scanning-and-how-to-use-it-on-mysamsung-galaxy-device/

[6] PhoneDB: SM-T837T Galaxy Tab S4 10.5 2018 LTE-A US 64GB

https://phonedb.net/index.php?m=device&id=15072&c=samsung_sm-t837t_galaxy_tab_s4_10.5_2018_ltea_us_64gb__samsung_t830&d=detailed_specs

26

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[7] PhoneDB: SM-G990U1 Galaxy S21 FE 5G UW TD-LTE US 128GB

https://phonedb.net/index.php?m=device&id=19575&c=samsung_sm-g990u1_galaxy_s21_fe_5g_uw_tdlte_us_128gb__samsung_g990&d=detailed_specs

[8] PhoneDB: SM-G965U1 Galaxy S9+ TD-LTE US

https://phonedb.net/index.php?m=device&id=13349&c=samsung_sm-g965u1_galaxy_s9plus_tdlte_us__samsung_star_2

[9] IFIXIT: Samsung Galaxy S21 Ultra Teardown

https://www.ifixit.com/Teardown/Samsung+Galaxy+S21+Ultra+Teardown/141188

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