DCT

2:22-cv-00078

G+ Communications LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-00078, E.D. Tex., 03/14/2022
  • Venue Allegations: Plaintiff alleges venue is proper against Samsung Electronics Co., Ltd. as a foreign corporation and against Samsung Electronics America, Inc. based on its regular and established place of business and acts of infringement within the Eastern District of Texas, specifically referencing a facility in Plano, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s 5G-capable mobile devices infringe five U.S. patents that have been declared essential to the 3GPP 5G cellular communication standard.
  • Technical Context: The patents relate to fundamental processes in 5G telecommunications, the technology that underpins modern high-speed mobile connectivity for smartphones and other devices.
  • Key Procedural History: The patents-in-suit were originally assigned to ZTE Corporation and subsequently assigned to Plaintiff G+ Communications. Each patent has been declared essential to the 3GPP 5G standard. The complaint alleges that Plaintiff made good-faith efforts to license the patents to Samsung on Fair, Reasonable, and Non-Discriminatory (FRAND) terms, but negotiations were unsuccessful. Plaintiff alleges providing notice and claim charts to Samsung as early as September 8, 2021.

Case Timeline

Date Event
2008-04-25 ’881 Patent Priority Date
2008-09-19 ’776 Patent Priority Date
2014-06-24 ’776 Patent Issue Date
2015-06-26 ’430 Patent Priority Date
2015-07-31 ’443 Patent Priority Date
2015-11-10 ’881 Patent Issue Date
2016-03-31 ’130 Patent Priority Date
2019-10-15 ’430 Patent Issue Date
2020-03-17 ’443 Patent Issue Date
2020-08-04 ’130 Patent Issue Date
2021-09-08 Plaintiff alleges sending correspondence and claim charts to Defendant
2022-02-08 Plaintiff alleges sending further correspondence and claim charts to Defendant
2022-03-14 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,761,776 - "Cell Reselection Method and Terminal"

  • Patent Identification: U.S. Patent No. 8,761,776, “Cell Reselection Method and Terminal,” issued June 24, 2014.
  • The Invention Explained:
    • Problem Addressed: In cellular networks, a mobile terminal in an idle state must periodically decide which cell tower (or "cell") to camp on to maintain connectivity. The patent’s background describes the technical challenge of efficiently selecting the best cell when multiple candidate cells on different frequencies are assigned the same priority level by the network, a scenario for which existing priority-based methods were not fully specified (’776 Patent, col. 2:46-56).
    • The Patented Solution: The invention proposes a structured, two-step method for this scenario. First, a terminal uses a "priority-based reselection principle" to identify a group of "same-priority cells" from among multiple frequencies. Second, from within this pre-selected group, it applies a "best-cell reselection principle," such as an offset-based method that ranks cells by signal quality, to select the single optimal cell to connect to (’776 Patent, col. 2:57-67, Fig. 1).
    • Technical Importance: This method provides a deterministic process for resolving ambiguity in cell reselection, which may improve the speed and reliability of network connections for mobile devices moving between coverage areas.
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 (Compl. ¶59).
    • The essential elements of claim 1 include:
      • A cell reselection method for a terminal currently associated with a serving cell on a serving frequency with a first priority.
      • Performing reselection among cells on multiple frequencies, other than the serving frequency, with a second priority.
      • Setting the cells on multiple frequencies with the second priority as same-priority cells.
      • Selecting cells on multiple frequencies with the second priority according to a priority-based reselection principle.
      • Selecting a cell as a reselected cell by the terminal from among the same-priority cells based on a best-cell reselection principle.
    • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,448,430 - "Group Based Random Access Method Device and System"

  • Patent Identification: U.S. Patent No. 10,448,430, “Group Based Random Access Method Device and System,” issued October 15, 2019.
  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes the inefficiency of conventional random access procedures in LTE systems when faced with a massive number of Machine Type Communication (MTC) or Internet of Things (IoT) devices. When tens of thousands of devices in a small area attempt to access the network individually, the available random access resources can be quickly overwhelmed (’430 Patent, col. 1:12-33).
    • The Patented Solution: The invention proposes a group-based random access method where a single "first User Equipment (UE)" in a "UE group" transmits a preamble to the network on behalf of the group. Subsequently, a "second UE" (which can be the first UE, some, or all UEs in the group) monitors for the network's response. This approach consolidates access requests from multiple devices into a single initial procedure, conserving network resources (’430 Patent, Abstract; Fig. 1).
    • Technical Importance: This group-based approach is designed to enable massive-scale IoT deployments by making the initial network access process more efficient and preventing network congestion caused by simultaneous requests from many devices.
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 (Compl. ¶76).
    • The essential elements of claim 1 include:
      • A random access method comprising sending, by a first User Equipment (UE) in a UE group, a preamble to an evolved Node B (eNB) over a time-frequency resource.
      • Monitoring, by at least one of the first UE or a second UE in the UE group, a Random Access Response (RAR) corresponding to the preamble.
      • After monitoring, sending, by at least one of the first UE or the second UE, a message 3 according to an Uplink (UL) grant allocated thereto.
      • The message 3 comprises a number of UEs having random access requests in the UE group, a number of UEs contained in the UE group, or a pre-set UE number.
    • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,184,881 - "Method for Feeding Back Confirmation Information on a Physical Uplink Shared Channel"

  • Patent Identification: U.S. Patent No. 9,184,881, “Method for Feeding Back Confirmation Information on a Physical Uplink Shared Channel,” issued November 10, 2015.
  • Technology Synopsis: The patent addresses methods for a user equipment (UE) to provide feedback (ACK/NACK signals) confirming receipt of data from the network. The invention specifies how to handle feedback when a UE fails to detect a control channel, ensuring that a negative acknowledgement (NACK) is sent, and how to format feedback when multiple "codeword streams" are involved, which may prevent data loss and improve communication reliability.
  • Asserted Claims: Independent claim 9 is asserted (Compl. ¶91).
  • Accused Features: The complaint alleges that the Accused Products infringe by implementing feedback procedures for Hybrid Automatic Repeat Request (HARQ), specifically how they generate and transmit ACK/NACK messages in various scenarios as defined by the 3GPP 5G Standard (Compl. ¶¶91-95).

U.S. Patent No. 10,736,130 - "Method and Device for Uplink Control Signal Transmission, User Terminal, and Storage Medium"

  • Patent Identification: U.S. Patent No. 10,736,130, “Method and Device for Uplink Control Signal Transmission, User Terminal, and Storage Medium,” issued August 4, 2020.
  • Technology Synopsis: The patent discloses a method for transmitting uplink control information from a user terminal to the network. The method involves sending a set of K predefined sequences over M transmission symbols to convey B bits of information. This technique is designed for efficient and robust transmission of control signals, such as acknowledgements or scheduling requests, within a short Transmission Time Interval (TTI).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶107).
  • Accused Features: The Accused Products are alleged to infringe by using a method for transmitting uplink control signals that involves mapping and sending predefined sequences on transmission symbols, consistent with the functionality described in the 3GPP 5G Standard for the Physical Uplink Control Channel (PUCCH) (Compl. ¶¶107-108).

U.S. Patent No. 10,594,443 - "Transmitting Method, Receiving Method and Nodes for HARQ Information"

  • Patent Identification: U.S. Patent No. 10,594,443, “Transmitting Method, Receiving Method and Nodes for HARQ Information,” issued March 17, 2020.
  • Technology Synopsis: This patent relates to a method for efficiently transmitting Hybrid Automatic Repeat Request (HARQ) feedback, which indicates the receiving status of multiple data transmission blocks. The method generates M bits of HARQ information, where a subset of bits (M2) indicates the positions of any erroneous blocks. The length of M2 can be predefined or determined dynamically based on the number of errors, which may reduce feedback overhead while maintaining accuracy.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶120).
  • Accused Features: Infringement is alleged based on the Accused Products' implementation of HARQ information transmission. This includes detecting received transmission blocks, generating HARQ bits to indicate their status (including the positions of erroneous blocks), and transmitting this information back to the network as specified in the 3GPP 5G Standard (Compl. ¶¶120-124).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Samsung’s 5G-capable devices, including the Galaxy Note20 5G, Galaxy S20 FE 5G, Galaxy S21 5G, Galaxy A Series 5G, and Galaxy Z Fold2 5G, as well as other similar devices in Samsung's Galaxy 5G product line (Compl. ¶¶6, 49).

Functionality and Market Context

  • The complaint alleges that the relevant functionality of the Accused Products is their capability of implementing the 3GPP 5G Standard (Compl. ¶49). The complaint includes a screenshot from Samsung's website detailing the 5G network connectivity specifications for the Galaxy S21, S21+, and S21 Ultra 5G models, which lists "5G Non-Standalone (NSA), Standalone (SA), Sub6 / mmWave" capabilities (Compl. p. 10). The Accused Products are positioned as flagship and mainstream smartphones in the global mobile device market.

IV. Analysis of Infringement Allegations

'8,761,776 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A cell reselection method, by which a terminal, which is currently associated with a serving cell on a serving frequency with a first priority, performs reselection among cells on multiple frequencies, other than the serving frequency, with a second priority... The Accused Products, in compliance with the 3GPP 5G standard, perform cell reselection by evaluating cells on different frequencies with different priorities when in idle or RRC Inactive mode. The complaint provides an excerpt from the 3GPP TS 38.304 standard describing how a User Equipment (UE) handles absolute priorities of different frequencies (Compl. ¶59, p. 12). ¶59 col. 4:1-12
setting the cells on multiple frequencies with the second priority as same-priority cells... The Accused Products practice the 3GPP standard, which provides for considering frequencies to have equal priority in cell reselection, thereby setting them as same-priority cells. The complaint references "NOTE 2" of the standard, which states a UE "may consider the frequencies providing the intra-carrier and inter-carrier configuration have equal priority" (Compl. ¶60, p. 14). ¶60 col. 4:26-31
selecting cells on multiple frequencies with the second priority according to a priority-based reselection principle when a terminal performs cell reselection... The Accused Products select cells based on priority by following rules in the 3GPP standard for higher, lower, and equal priority frequencies. This is alleged to be the claimed priority-based reselection principle (Compl. ¶61, pp. 16-17). ¶61 col. 4:13-17
selecting a cell as a reselected cell by the terminal from among the same-priority cells based on a best-cell reselection principle. The Accused Products comply with the 3GPP standard's rules for selecting from among equal-priority cells based on ranking criteria, which the complaint alleges constitutes a best-cell reselection principle. The complaint provides a standard excerpt stating, "Cell reselection to a cell on an equal priority NR frequency shall be based on ranking" (Compl. ¶62, p. 18). ¶62 col. 4:32-37
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the term "best-cell reselection principle" as used in the patent is synonymous with the "ranking" criteria for equal-priority cells described in the 3GPP standard (Compl. ¶¶62, 65). The defense may argue the standard’s ranking mechanism is technically distinct from the specific offset-based principle described in the patent's embodiments.
    • Technical Questions: The complaint alleges infringement by compliance with the standard. A factual question for the court will be to determine if the functionality described in the 3GPP standard documents (e.g., Compl. p. 19, showing cell-ranking criteria) is technically equivalent to each limitation recited in claim 1.

'10,448,430 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A random access method comprising: sending, by a first User Equipment (UE) in a UE group, a preamble to an evolved Node B (eNB) over a time-frequency resource... The Accused Products, acting as UEs, initiate a 4-step random access procedure by transmitting a preamble (Msg1) on a Physical Random Access Channel (PRACH), which is a time-frequency resource. The complaint presents a diagram from the 3GPP standard illustrating this step (Compl. ¶77, p. 28). ¶77 col. 10:43-53
monitoring, by at least one of the first UE or a second UE in the UE group, a Random Access Response (RAR) corresponding to the preamble and sent by the eNB... The Accused Products monitor for a Random Access Response from the network within a configured window after sending the preamble. The complaint cites a section of the 3GPP standard describing "Random Access Response reception" (Compl. ¶78, p. 30). ¶78 col. 10:54-62
after monitoring... sending, by at least one of the first UE or the second UE, a message 3 according to a Uplink (UL) grant allocated thereto... After receiving the RAR containing an uplink grant, the Accused Products send a "message 3" (Msg3), which is a scheduled transmission to the network. The complaint provides a standard diagram showing this "Scheduled Transmission" as step 3 of the process (Compl. ¶79, p. 32). ¶79 col. 12:38-42
wherein the message 3 comprises a number of UEs having random access requests in the UE group or a number of UEs contained in the UE group or a pre-set UE number. The complaint alleges this functionality is described in the 3GPP 5G Standard. However, the complaint does not provide specific documentary evidence or explanation for how Msg3 in the standard includes a "number of UEs" in a group, instead focusing on the transmission of Msg3 itself (Compl. ¶79, p. 32). ¶79 col. 12:42-47
  • Identified Points of Contention:
    • Scope Questions: The patent claims a "group based" method where a "first UE" acts for a "UE group." A key legal and factual question will be whether the standard random access procedure, which is typically initiated by a single device for its own access, can be construed as the claimed "group based" method involving distinct first and second UEs.
    • Technical Questions: What evidence does the complaint provide that Message 3, as implemented in the Accused Products, contains the specific information required by the final limitation of claim 1—namely, a "number of UEs having random access requests in the UE group"? The complaint's allegations appear less detailed on this specific element (Compl. ¶79).

V. Key Claim Terms for Construction

For the ’776 Patent:

  • The Term: "best-cell reselection principle"
  • Context and Importance: This term defines the mechanism for making the final cell selection from the "same-priority" group. The outcome of the infringement analysis may depend on whether this term is construed broadly to cover any quality-based ranking system, such as that in the 3GPP standard, or narrowly to mean the specific offset-based calculation detailed in the patent’s specification.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general and does not specify a particular calculation, which may support a construction covering any principle for selecting the "best" cell based on technical criteria.
    • Evidence for a Narrower Interpretation: The detailed description repeatedly explains the principle in the context of an "offset-based cell reselection method" and ranking based on calculated "R values," which may suggest the inventor intended a more limited scope (’776 Patent, col. 2:64-67).

For the ’430 Patent:

  • The Term: "UE group"
  • Context and Importance: The existence of a "UE group" is a fundamental premise of the asserted claim. Practitioners may focus on this term because its construction will determine whether the accused functionality, which involves a random access procedure, qualifies as the claimed "group based" method.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is not explicitly defined in the claims, which may support a construction covering any collection of UEs participating in a coordinated network access procedure.
    • Evidence for a Narrower Interpretation: The specification discusses embodiments where the group is defined by a "group ID" and where UEs are formally organized, suggesting the term implies a more structured collection than just unrelated devices using the network (’430 Patent, col. 11:55-61). The abstract also distinguishes between a "first UE" and a "second UE" within the group, suggesting distinct roles that may not exist in a standard single-UE random access.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Samsung induces infringement by providing the Accused Products along with instructions, manuals, marketing, and technical support that encourage users to operate the devices in their intended 5G-compliant, and therefore infringing, manner (Compl. ¶¶68, 82). It further alleges contributory infringement on the basis that the accused components are material to the inventions and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶¶69, 83).
  • Willful Infringement: The complaint alleges willful infringement based on Samsung’s alleged pre-suit knowledge of the patents. This knowledge is alleged to stem from correspondence sent by Plaintiff on September 8, 2021, and February 8, 2022, which included evidence-of-use charts mapping the asserted patents to the 5G standard (Compl. ¶¶67, 72, 81, 86).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of standard essentiality and equivalence: does practicing the 3GPP 5G standard, as the Accused Products are alleged to do, necessarily result in infringement of every limitation of the asserted claims? The case will likely involve a technical, element-by-element comparison of the standard's specifications against the patent claims.
  • A second central question will be one of claim scope and construction: can patent terms rooted in specific embodiments, such as the "group based" random access method of the ’430 patent or the "best-cell reselection principle" of the ’776 patent, be construed broadly enough to read on the generalized procedures set forth in the 3GPP 5G standard?
  • A third key issue, related to damages, will concern the FRAND licensing obligations associated with standard-essential patents. The court may need to examine the parties' pre-suit negotiation conduct to determine whether Plaintiff's offers were consistent with FRAND principles and whether Defendant negotiated in good faith.