Actually, BOOKS had 'always on' displays before Nokia.Nope... Samsung was inspired by Nokia.
Dead Sea Scrolls had 'always on' displays before books.
Cave Paintings had 'always on' displays before dead sea scrolls.
Reality had an always on display before cave paintings.
So lets just cut to the chase and say that all of this was inspired by the real world a LONG time before any smart phone company existed, and NONE of them can patent/trademark/copyright due to prior art by the creator of the universe. Do you REALLY want to go to a lawsuit against Cthulu? I hear that it isn't only the court he holds in contempt, and his contempt is legendary.