DCT

2:24-cv-00242

GenghisComm Holdings LLC v. Samsung Electronics America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00242, E.D. Tex., 08/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung maintains regular and established places of business in the district, including a major campus and a "Networks Innovation Center" in Plano, Texas, and has committed the alleged acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s 4G/LTE and 5G-compliant wireless mobile devices, including smartphones, tablets, and watches, infringe eight U.S. patents related to signal processing technologies for wireless communications, such as pre-coding, spreading, and modulation.
  • Technical Context: The patents-in-suit address foundational techniques for generating and processing complex wireless signals, with a focus on methods that are central to the operation of modern 4G/LTE and 5G cellular standards.
  • Key Procedural History: The complaint details extensive pre-suit communications, including notice letters with claim charts sent to Samsung between November 2020 and December 2022, followed by technical calls and correspondence. The complaint also notes that Samsung has attempted to invalidate GenghisComm’s patents through Inter Partes Review (IPR) proceedings and re-examinations, which Plaintiff characterizes as evidence supporting its claim of willful infringement.

Case Timeline

Date Event
2001-04-26 Earliest Priority Date for ’842 and ’227 Patents
2004-08-02 Earliest Priority Date for ’568, ’786, ’508, ’005, and ’285 Patents
2007-01-08 Earliest Priority Date for ’792 Patent
2017-09-19 U.S. Patent No. 9,768,842 Issues
2017-09-19 U.S. Patent No. 11,223,508 Issues
2019-02-05 U.S. Patent No. 10,200,227 Issues
2019-08-20 U.S. Patent No. 10,389,568 Issues
2020-11-19 Samsung receives notice of infringement for ’842, ’227, and ’568 Patents
2021-01-01 Approximate launch period for accused Galaxy Z, S, Note, and A models begins
2021-07-27 U.S. Patent No. 11,075,786 Issues
2022-02-15 U.S. Patent No. 11,252,005 Issues
2022-06-29 Samsung receives notice of infringement for ’786 and ’508 Patents
2022-07-05 U.S. Patent No. 11,381,285 Issues
2022-08-23 U.S. Patent No. 11,424,792 Issues
2022-12-21 Samsung receives notice of infringement for ’005, ’285, and ’792 Patents
2024-04-01 Approximate date of original Complaint filing
2025-08-05 Second Amended Complaint filing date

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

U.S. Patent No. 9,768,842 - "Pre-coding in multi-user MIMO"

The Invention Explained

  • Problem Addressed: The complaint does not provide sufficient detail for analysis of the specific problem addressed in the '842 Patent's background section.
  • The Patented Solution: The invention relates to an Orthogonal Frequency-Division Multiplexing (OFDM) transmitter architecture designed to mitigate a key drawback of OFDM signals: a high peak-to-average power ratio (PAPR) (Compl. ¶102). The solution involves a pre-processing step where an "OFDM spreader," implementing a Discrete Fourier Transform (DFT), spreads data symbols using Fourier coefficients before the standard OFDM modulation process (Compl. ¶97). This DFT-spreading technique, central to Single-Carrier Frequency-Division Multiple Access (SC-FDMA) systems, results in a transmission signal that is a superposition of subcarriers with a reduced PAPR (Compl. ¶¶97, 101-102).
  • Technical Importance: Reducing PAPR allows for the use of more power-efficient and less expensive power amplifiers in mobile devices, a critical consideration for battery life and device cost in the mass-market wireless industry (Compl. ¶102).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2, 3, 4, 7, 8, and 9 (Compl. ¶¶96-161).
  • The essential elements of independent claim 1 are:
    • An OFDM transmitter, comprising:
    • an OFDM spreader configured to spread a plurality of data symbols with Fourier coefficients to generate a discrete Fourier Transform (DFT)-spread data signal;
    • a mapper configured to map the DFT-spread data signal to a plurality of OFDM subcarriers; and
    • an OFDM modulator configured to modulate the DFT-spread data signal onto the plurality of OFDM subcarriers to produce an OFDM transmission signal comprising a superposition of the OFDM subcarriers, wherein the OFDM spreader is configured to provide the superposition with a reduced peak-to-average power ratio.

U.S. Patent No. 11,381,285 - "Transmit pre-coding"

The Invention Explained

  • Problem Addressed: The patent background describes challenges in wireless networking, including protocol inefficiencies and base-station bottlenecks in conventional cellular models, and the impracticality of implementing large antenna arrays on mobile terminals due to power, cost, and size constraints (’285 Patent, col. 1:16-col. 2:36).
  • The Patented Solution: The invention describes a method for a user device to encode data symbols using different "polyphase codes" to generate specific values for a set of OFDM subcarriers (’285 Patent, Abstract). Each polyphase code is designed to cause constructive and destructive interference among the modulated subcarriers in a way that produces a distinct, periodic pulse waveform centered at a specific time within a single OFDM symbol interval (’285 Patent, Abstract). This technique, illustrated in the patent's Figure 15, allows different data symbols to be distinguished by their timing within the same symbol period and on the same subcarriers (’285 Patent, Fig. 15).
  • Technical Importance: This approach enables time-division multiplexing within a single OFDM symbol, creating orthogonal signal spaces that can increase data throughput and spectral efficiency without requiring additional frequency or spatial resources (’285 Patent, col. 43:35-42).

Key Claims at a Glance

  • The complaint asserts claims 7, 9, 17, and 19, which depend from independent claim 1 (Compl. ¶197).
  • The essential elements of independent claim 1 are:
    • A method of communication comprising:
    • encoding data symbols with complex-valued codes to produce subcarrier values;
    • modulating these values onto OFDM subcarriers to produce a time-domain waveform;
    • wherein the subcarrier values include a first polyphase code for a first data symbol and a second polyphase code for a second data symbol;
    • the first polyphase code creates a pulse waveform centered at a first time in an OFDM symbol interval; and
    • the second polyphase code creates a second pulse waveform centered at a second, different time in the same OFDM symbol interval.

Multi-Patent Capsule Analysis

  • Patent Identification: U.S. Patent No. 10,200,227, "Pre-coding in multi-user MIMO," issued February 5, 2019 (Compl. ¶22).

  • Technology Synopsis: This patent appears related to the technology of the '842 Patent, focusing on pre-coding techniques for multi-user, multiple-input multiple-output (MIMO) wireless systems. Such techniques are used to manage interference and improve signal quality in complex communication environments.

  • Asserted Claims: Claims 18, 21, 24, and 25 (Compl. ¶162).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 4G LTE networks and comply with 4G LTE wireless standards infringe the '227 Patent (Compl. ¶¶163, 165).

  • Patent Identification: U.S. Patent No. 10,389,568, "Single carrier frequency division multiple access baseband signal generation," issued August 20, 2019 (Compl. ¶23).

  • Technology Synopsis: This patent describes technology for generating baseband signals in Single-Carrier Frequency-Division Multiple Access (SC-FDMA) systems, a core component of the 4G LTE uplink standard known for its power efficiency.

  • Asserted Claims: Claims 2, 6, 9, 11, 25, 29, 32, and 34 (Compl. ¶169).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 4G LTE networks and comply with 4G LTE wireless standards infringe the '568 Patent (Compl. ¶¶170-171).

  • Patent Identification: U.S. Patent No. 11,075,786, "Multicarrier sub-layer for direct sequence channel and multiple-access coding," issued July 27, 2021 (Compl. ¶24).

  • Technology Synopsis: The patent relates to methods of coding signals across multiple carriers, a technique used in advanced wireless systems to enhance robustness and capacity by spreading signals over frequency and/or space.

  • Asserted Claims: Claims 2, 6, 8, 11, 15, and 17 (Compl. ¶176).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 4G LTE networks and comply with 4G LTE wireless standards infringe the '786 Patent (Compl. ¶¶177-178).

  • Patent Identification: U.S. Patent No. 11,223,508, "Wireless communications using flexible channel bandwidth," issued September 19, 2017 (Compl. ¶¶1, 25).

  • Technology Synopsis: This patent addresses techniques for adapting channel bandwidth in wireless communications, a key feature of 5G systems that allows for flexible and efficient use of spectrum depending on network conditions and application requirements.

  • Asserted Claims: Claims 1, 2, 17, and 18 (Compl. ¶183).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 5G networks and comply with 5G wireless standards infringe the '508 Patent (Compl. ¶¶184-185).

  • Patent Identification: U.S. Patent No. 11,252,005, "Spreading and precoding in OFDM," issued February 15, 2022 (Compl. ¶26).

  • Technology Synopsis: The patent describes methods for spreading and precoding signals in OFDM systems, which are foundational technologies for both 4G and 5G to manage interference, improve signal integrity, and enable multi-user communications.

  • Asserted Claims: Claims 7 and 19 (Compl. ¶190).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 5G networks and comply with 5G wireless standards infringe the '005 Patent (Compl. ¶¶191-192).

  • Patent Identification: U.S. Patent No. 11,424,792, "Coordinated multipoint systems," issued August 23, 2022 (Compl. ¶28).

  • Technology Synopsis: This patent relates to coordinated multipoint (CoMP) systems, an advanced technique where multiple, geographically separated base stations cooperate to transmit to or receive from a user device, thereby improving signal quality and data rates, particularly for users at the cell edge.

  • Asserted Claims: Claims 2 and 9 (Compl. ¶204).

  • Accused Features: The complaint alleges that Samsung's devices that utilize 5G networks and comply with 5G wireless standards infringe the '792 Patent (Compl. ¶¶205-206).

III. The Accused Instrumentality

  • Product Identification: The accused products are broadly defined as "Accused Samsung LTE Devices" and "Accused Samsung 5G Devices" (Compl. ¶¶78-79). These categories encompass a wide range of Samsung's product lines, including but not limited to the Galaxy Z, S, Note, and A series of smartphones, as well as Galaxy tablets and watches that have LTE or 5G network connectivity (Compl. ¶¶78-79).
  • Functionality and Market Context: The core accused functionality is the implementation of 4G/LTE and 5G cellular standards for wireless communication (Compl. ¶¶78-79). The complaint alleges that to comply with these standards, particularly the 3GPP LTE Specification, the accused devices necessarily practice the patented methods for uplink signal transmission (Compl. ¶¶98, 101). It is alleged that these methods are performed automatically by the devices' hardware, such as Samsung's Exynos chips, without user intervention whenever the devices connect to a 4G/LTE or 5G network (Compl. ¶¶38-39, 45). The complaint positions these products as central to Samsung's business, from which it derives a large financial benefit (Compl. ¶35).

IV. Analysis of Infringement Allegations

'842 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An OFDM transmitter, comprising: Accused Samsung LTE Devices include a transmitter, such as a Qualcomm Snapdragon modem-RF system, for LTE network communications (Compl. ¶100). ¶100 col. 18:9-12
an OFDM spreader configured to spread a plurality of data symbols with Fourier coefficients to generate a discrete Fourier Transform (DFT)-spread data signal; The transmitter utilizes the LTE Specification's "Transform Precoding" method, which employs a DFT to spread data symbols and generate a DFT-spread data signal (Compl. ¶102). This equation from the 3GPP TS 36.211 standard is presented as evidence in the complaint (Compl. p. 20). ¶102 col. 19:1-20
a mapper configured to map the DFT-spread data signal to a plurality of OFDM subcarriers; The transmitter includes a mapper consistent with the LTE Specification's section on "Mapping to Physical Resources," which maps the spread signals to physical resource elements defined as subcarriers (Compl. ¶103). ¶103 col. 20:1-10
an OFDM modulator configured to modulate the DFT-spread data signal onto the plurality of OFDM subcarriers to produce an OFDM transmission signal... wherein the OFDM spreader is configured to provide the superposition with a reduced peak-to-average power ratio. The transmitter performs SC-FDMA baseband signal generation, modulating the mapped signals onto OFDM subcarriers to create a time-domain signal (Compl. ¶104). This transform precoding process results in a superposition of subcarriers with a lower peak-to-average power ratio (PAPR) compared to standard downlink OFDM signals (Compl. ¶102). ¶¶102, 104 col. 19:62-20:5

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused Single-Carrier FDMA (SC-FDMA) system, which the complaint describes as "derived from the OFDM signal," falls within the scope of the claimed "OFDM transmitter." While technically a form of DFT-spread OFDM, Samsung may argue that SC-FDMA is a distinct technology not contemplated by the patent's claims.
  • Technical Questions: The infringement theory hinges on the claim language that the spreader is "configured to provide" a reduced PAPR. The analysis may turn on whether this requires a specific design choice aimed at PAPR reduction, or if the limitation is met simply because the standardized "Transform Precoding" process inherently results in a lower PAPR.

V. Key Claim Terms for Construction

  • The Term: "OFDM spreader"

  • Context and Importance: The definition of this term is critical, as the complaint equates it with the "Transform Precoding" block specified in the 4G/LTE standard. The viability of the infringement case against standard-compliant products depends on this construction. Practitioners may focus on this term because its scope will determine whether simply implementing the SC-FDMA uplink process constitutes infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent specification describes the spreader in functional terms as a component that spreads data symbols using Fourier coefficients to generate a DFT-spread data signal, a description that aligns with the function of the LTE Transform Precoding block (Compl. ¶97; '842 Patent, col. 19:1-20).
    • Evidence for a Narrower Interpretation: Samsung may argue that the term should be limited to the specific structural embodiments, figures, or configurations disclosed in the patent's detailed description, to the extent they differ from the standard SC-FDMA implementation.

  • The Term: "configured to provide... a reduced peak-to-average power ratio"

  • Context and Importance: This functional limitation is a likely point of dispute. The case may depend on whether this language requires that the spreader be designed for the purpose of reducing PAPR, or if it is sufficient that PAPR reduction is an inherent result of the spreader's operation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent’s abstract and specification repeatedly link the use of the DFT spreader directly to the benefit of achieving a reduced PAPR, suggesting the function is an inherent and intended purpose of the claimed structure ('842 Patent, Abstract; col. 20:1-5).
    • Evidence for a Narrower Interpretation: A defendant may argue that this term implies a specific optimization or adaptation for PAPR reduction that goes beyond merely implementing a standard DFT. The argument could be that the spreader is configured to perform a transform, and the reduced PAPR is a consequential property, not the configured purpose.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Samsung directs and controls end users to practice the patented methods through automatic, non-alterable device functions and software updates (Compl. ¶¶33, 42). Contributory infringement is based on the allegation that Samsung's "4G/LTE or 5G Cellular Radio Components" are a material part of the invention, are not staple articles of commerce suitable for substantial non-infringing use, and were especially made for use in an infringing manner (Compl. ¶¶60-61, 66).
  • Willful Infringement: Willfulness is alleged based on Samsung's purported knowledge of the patents-in-suit since at least November 2020, June 2022, and December 2022, following receipt of detailed notice letters and claim charts from Plaintiff (Compl. ¶90). The complaint alleges that Samsung continued its infringing conduct despite this knowledge and without a good faith belief of non-infringement or invalidity (Compl. ¶¶95, 216). Plaintiff further cites Samsung's attempts to invalidate the patents via IPRs as additional evidence of willfulness (Compl. ¶218).

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

  • A core issue will be one of technical scope: does the claim term "OFDM transmitter," as used in the '842 Patent, read on the Single-Carrier FDMA (SC-FDMA) architecture that is mandated by the 4G/LTE standard and implemented in the accused devices? The outcome will likely depend on whether the court views SC-FDMA as a species of the claimed genus or as a distinct technology.
  • A key question will be one of claim construction: does the functional limitation "configured to provide... a reduced peak-to-average power ratio" require a specific design purpose aimed at PAPR reduction, or is the limitation satisfied if this reduction is an inherent, automatic result of implementing the standard-compliant "Transform Precoding" method?
  • A central evidentiary question will concern willfulness: given the extensive pre-suit notice alleged in the complaint, the case will likely examine what objective evidence Samsung can present to establish a good-faith belief of non-infringement or invalidity that pre-dates the filing of the lawsuit, particularly in light of the allegation that it proceeded without an opinion of counsel.