DCT

2:25-cv-00608

Massively Broadband LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00608, E.D. Tex., 06/06/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Samsung Electronics Co., Ltd. is a foreign defendant, and because Samsung Electronics America, Inc. maintains a regular and established place of business in the district, specifically its North Texas Campus in Plano, where employees allegedly engage in research, development,testing, and sales of the accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s 5G network equipment, mobile devices (including smartphones, tablets, and laptops), and enterprise mobility software infringe a portfolio of thirteen patents related to broadband wireless relays, smart antenna technologies, and network performance monitoring.
  • Technical Context: The patents address foundational technologies for high-speed, high-bandwidth wireless communications, including intelligent signal repeating, multi-band antenna tuning, and centralized network monitoring, which are central to the operation of modern 4G LTE and 5G networks.
  • Key Procedural History: The complaint alleges that Samsung had pre-suit knowledge of several of the asserted patents because they were cited by USPTO examiners during the prosecution of Samsung's own patent applications. Specifically, the complaint notes that the ’194, ’358, and ’625 patents were cited in office actions against Samsung applications, and that Samsung argued to distinguish its own inventions from the cited art, suggesting a detailed awareness of the patents’ scope.

Case Timeline

Date Event
2003-08-22 Priority Date for ’194, ’754, ’337, ’999, ’783 Patents
2007-09-10 Priority Date for ’794, ’925, ’700 Patents
2008-08-14 Priority Date for ’763, ’358 Patents
2010-03-09 Issue Date for U.S. Patent No. 7,676,194 (’194 Patent)
2012-07-17 Issue Date for U.S. Patent No. 8,224,794 (’794 Patent)
2013-01-08 Issue Date for U.S. Patent No. 8,350,763 (’763 Patent)
2013-08-14 Priority Date for ’625, ’548 Patents
2013-08-20 Issue Date for U.S. Patent No. 8,515,925 (’925 Patent)
2013-11-26 Issue Date for U.S. Patent No. 8,593,358 (’358 Patent)
2014-05-13 Issue Date for U.S. Patent No. 8,725,700 (’700 Patent)
2014-12-30 Issue Date for U.S. Patent No. 8,923,754 (’754 Patent)
2017-05-30 Issue Date for U.S. Patent No. 9,667,337 (’337 Patent)
2019-03-05 Issue Date for U.S. Patent No. 10,224,999 (’999 Patent)
2020-10-06 Issue Date for U.S. Patent No. 10,797,783 (’783 Patent)
2021-07-13 Issue Date for U.S. Patent No. 11,063,625 (’625 Patent)
2024-01-16 Issue Date for U.S. Patent No. 11,876,548 (’548 Patent)
2025-06-06 Complaint Filing Date

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

U.S. Patent No. 8,923,754 - “Intelligent Broadband Relay for Wireless Networks”

The Invention Explained

  • Problem Addressed: The patent family addresses challenges anticipated with the proliferation of ultrawideband (UWB) wireless devices, which require high bandwidths (e.g., 100 MHz or more) (Compl. ¶65; ’194 Patent, col. 3:57-59). Such wide channels have a higher noise floor, limiting their effective range, and were expected to be subject to increased interference, spam traffic, and security attacks (Compl. ¶¶ 66, 68; ’194 Patent, col. 3:66-4:13).
  • The Patented Solution: The invention is an "intelligent" wireless repeater or relay designed to extend the range of high-bandwidth networks while also providing security and traffic management (Compl. ¶¶ 67–68). The repeater’s controller can process traffic to "ignore or filter out" transmissions from undesired sources and perform network provisioning or monitoring, thereby managing interference and security threats (Compl. ¶69; ’754 Patent, col. 22:37-65).
  • Technical Importance: The invention provided a technical solution to problems of signal range and interference for high-data-rate wireless technologies before such devices became widespread, addressing issues that were not yet conventional in the 2003-2004 timeframe (Compl. ¶81).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 14 of the ’754 Patent (Compl. ¶277). Claim 1, quoted in the complaint, is representative of the “Intelligent Wireless Broadband Relay Patents” (Compl. ¶69).
  • Essential elements of independent claim 1 include:
    • A broadband wireless repeater or relay.
    • At least one receiver/transceiver for signal reception and at least one transmitter/transceiver for signal transmission.
    • A controller configured for operation in wireless networks.
    • The repeater/relay transmits and/or receives at a bandwidth of 100 MHz or more or a data rate of 100 Megabits per second or more.
    • The controller is configured to perform a plurality of functions, including: (a) ignoring or filtering out undesired signals, (b) instructing other devices to ignore undesired signals, and (c) network provisioning or monitoring.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent, but does so for others.

U.S. Patent No. 8,350,763 - “Active Antennas for Multiple Bands in Wireless Portable Devices”

The Invention Explained

  • Problem Addressed: Modern mobile devices require multiple antennas to operate on different communication channels (e.g., cellular, Wi-Fi), which operate at different frequencies (Compl. ¶88). Fitting numerous antennas into a small mobile device is described as difficult, expensive, and detrimental to radiation efficiency and power consumption (’763 Patent, col. 1:28-42).
  • The Patented Solution: The invention is a single antenna structure capable of operating on multiple, different frequency bands (Compl. ¶91). This is achieved by actively or passively tuning the antenna using electronic control, which simplifies the antenna structure, reduces mechanical complexity, and lowers material costs (’763 Patent, col. 3:62-67).
  • Technical Importance: The technology addresses the problem of limited physical space ("antenna real estate") and RF interference in compact devices by enabling a single tunable antenna to accommodate multiple frequency bands, improving efficiency and simplifying device manufacturing (Compl. ¶97).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 3, 6, 7, 10, and 13 of the ’763 Patent (Compl. ¶321).
  • Essential elements of independent claim 1 include:
    • A wireless device.
    • One or more antennas.
    • A plurality of transmitters, receivers, or transceivers that operate in one or more frequency bands.
    • Wherein at least one antenna is used by the transceivers in a plurality of different bands.
    • Wherein the antenna is either an actively tuned antenna or is tuned by passive elements selected or interconnected using electronic control.
  • The complaint explicitly asserts dependent claims.

U.S. Patent No. 11,063,625 - “Steerable Antenna Device”

  • Technology Synopsis: This patent addresses degraded performance in handheld devices caused by blocked or misaligned antennas, particularly at high frequencies (10 GHz and above) (Compl. ¶112). The invention is a method for avoiding radiation towards a user or structure by using a steerable antenna that detects the orientation of the device relative to an obstacle (e.g., a user) and adjusts its beam radiation pattern to radiate away from the obstacle (Compl. ¶103).
  • Asserted Claims: Independent claims 1 and 23, and dependent claims 2, 5, 9, 11, 12, 13, 17, and 21 (Compl. ¶343).
  • Accused Features: Certain Samsung mobile devices (e.g., Galaxy S21, S22, Z Fold models) that include on-board sensors (e.g., gyroscopes, capacitive sensors) and a steerable antenna operating in the mmWave frequency range (10 GHz to 500 GHz) are alleged to practice the claimed method (Compl. ¶¶ 196, 207).

U.S. Patent No. 8,224,794 - “Clearinghouse System, Method, and Process for Inventorying and Acquiring Infrastructure, Monitoring and Controlling Network Performance for Enhancement, and Providing Localized Content in Communication Networks”

  • Technology Synopsis: The patent addresses inefficient network management by introducing a "clearinghouse" system that aggregates and organizes location-specific and device-specific data from end-user devices (Compl. ¶116). This centralized platform inventories network assets, collects real-world performance data (e.g., radio operating conditions), and allows for optimization of connectivity and device behavior based on that data (Compl. ¶113, 117).
  • Asserted Claims: Independent claim 20 and dependent claim 25 (Compl. ¶365).
  • Accused Features: The Samsung Knox Suite, particularly the Knox Asset Intelligence feature, is alleged to infringe. The suite is described as collecting performance and Quality of Service (QoS) data from enterprise-managed mobile devices, storing it in a database, and using it for remote monitoring, analysis, and device configuration (Compl. ¶¶ 225, 235-236).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies four main categories of accused instrumentalities: (i) “Accused Hotspot Devices,” including a wide range of Samsung smartphones, tablets, and laptops; (ii) “Accused RAN Products,” including 5G Radio Access Network equipment like Massive MIMO radios and Compact Macros; (iii) “Accused Advanced Antenna Mobile Devices,” including smartphones and tablets with multi-band and/or steerable antennas; and (iv) the “Samsung Knox Suite,” an enterprise mobility and security software framework (Compl. ¶¶ 123, 157, 176, 217).

Functionality and Market Context

  • Hotspot Devices: These products are alleged to function as wireless relays by connecting to a cellular network (4G LTE or 5G) for internet access and broadcasting a Wi-Fi signal for other devices to connect (Compl. ¶122). The complaint alleges these devices are configurable to operate on wireless channels with bandwidths of 100 MHz or more and/or data rates of 100 Mbps or more, meeting the thresholds of the asserted relay patents (Compl. ¶124). A user manual for the Galaxy S24 Ultra is provided as an example of instructions for enabling this functionality (Compl. ¶153, p. 34).
  • RAN Products: This 5G infrastructure equipment provides cellular coverage for mobile devices (Compl. ¶157). The complaint alleges these products include MIMO antennas and transmit beacon frames, and are configurable to operate on 5G channels with bandwidths exceeding 100 MHz, such as the n78 band (Compl. ¶¶ 159, 160, 168, 172).
  • Advanced Antenna Mobile Devices: These smartphones and tablets allegedly contain sophisticated antenna systems. The complaint identifies specific components, such as Qualcomm, MediaTek, and Qorvo chipsets, that allegedly provide adaptive impedance tuning, allowing a single antenna to operate across multiple Sub-6 GHz frequency bands (Compl. ¶¶ 177-181). Other devices are alleged to include phased array antenna modules (e.g., Qualcomm QTM525) and various sensors (gyroscopes, capacitive sensors) to enable electronic beam steering in the mmWave 5G bands (n260/n261) (Compl. ¶207).
  • Knox Suite: This is an enterprise software solution for managing and securing Samsung mobile devices (Compl. ¶217). The Knox Asset Intelligence feature is alleged to function as the claimed "clearinghouse" by collecting device health, usage, and network condition data (including QoS and Wi-Fi connection events) from end-user devices, storing it in a "Knox Database" with associated location data, and making it available to IT administrators via a dashboard for analysis and remote management (Compl. ¶¶ 222, 225-226, 229). The complaint includes a marketing flyer for Knox Asset Intelligence showing a dashboard that summarizes Wi-Fi connectivity status (Compl. p. 46).

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,923,754 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A broadband wireless repeater or relay, comprising: at least one receiver or transceiver for signal or data reception from one or more devices; at least one transmitter or transceiver for signal or data transmission to one or more devices... a controller that is configured or configurable for operation... The Accused Hotspot Devices (e.g., Galaxy smartphones) and RAN Products are alleged to be broadband wireless relays. They contain transceivers for receiving data (e.g., from a cellular network) and transmitting data (e.g., over a Wi-Fi network or to a mobile device). The device's internal processor acts as the controller. ¶¶122, 124, 157 col. 22:37-48
wherein at least one of said receiver or transceiver... and said transmitter or transceiver... either or both transmit and receive at an instantaneous or overall occupied bandwidth of 100 MHz or more or have a data transmission rate of 100 Megabits per second or more, The Accused Hotspot Devices and RAN Products are alleged to operate on Wi-Fi 5/6/6E channels (160 MHz) and/or 4G/5G cellular bands (e.g., n41, n77) that support bandwidths of 100 MHz or more and data rates greater than 100 Mbps. ¶¶124, 130, 135-136 col. 22:53-59
wherein said controller is configured or configurable to perform... a plurality of: a) ignore or filter out at least some signal or data transmissions from one or more undesired transmitters, users, networks, data sources, or noise sources... c) network provisioning or monitoring. The controller in the Accused Hotspot Devices and RAN Products is alleged to inherently perform these functions as part of standard network operation, such as managing connections, filtering traffic, and monitoring network status to maintain connectivity. ¶¶69, 122 col. 22:60-65

Identified Points of Contention

  • Scope Questions: A central question may be whether a consumer smartphone operating in "hotspot mode" or a carrier-side 5G base station qualifies as a "broadband wireless repeater or relay" as that term is used in the patent. The defense may argue these are end-point devices or network access points with functionalities far beyond the simple repeating function contemplated by the patent, while the plaintiff may argue for a broad, functional definition covering any device that intelligently re-transmits wireless data between two different networks.
  • Technical Questions: The complaint alleges that the controller is configured to "ignore or filter out" undesired signals. A key factual question will be what specific filtering operations the accused devices perform, and whether those operations meet the claimed functionality beyond the basic packet filtering inherent in any modern network device.

U.S. Patent No. 8,350,763 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A wireless device, comprising: one or more antennas; and a plurality of transmitters, receivers or transceivers that operate in one or more frequency bands, The Accused Advanced Antenna Mobile Devices (e.g., Galaxy S-series smartphones, Galaxy Tab tablets) contain one or more antennas and multiple transceivers for different wireless standards (e.g., 5G cellular, Wi-Fi, Bluetooth). ¶¶88, 176 col. 10:18-22
wherein at least one antenna of said one or more antennas is used by said plurality of transmitters, receivers or transceivers in a plurality of different bands, A single antenna structure within the accused devices is allegedly used for communication across multiple distinct frequency bands, such as various Sub-6 GHz 5G bands (e.g., n71, n41, n77). ¶¶177, 180, 189 col. 10:23-25
wherein said at least one antenna is one or more of a) an actively tuned antenna, and b) is tuned by one or more passive elements which are selected or interconnected using electronic control. The accused devices allegedly contain RF front-end modules and/or modems (e.g., from Qualcomm, Qorvo) which include adaptive impedance tuners. These tuners are alleged to employ active tuning using tunable passive elements under electronic control to match the antenna's impedance to different frequency bands. ¶¶177, 194-195 col. 10:26-28

Identified Points of Contention

  • Technical Questions: The infringement analysis will likely focus on the precise mechanism of the accused antenna tuners. The key factual question is whether the specific identified components (e.g., Qualcomm QAT 3555, Qorvo ICs) operate by tuning "passive elements" that are "selected or interconnected using electronic control," as required by the claim. This may require detailed discovery into the circuit-level operation of the accused chipsets.
  • Scope Questions: The term "actively tuned antenna" may be a point of construction. The defense may argue for a narrow definition that does not cover the specific impedance matching techniques used in its devices, while the plaintiff will likely point to specification language supporting a broader functional definition.

V. Key Claim Terms for Construction

  • From the ’754 Patent:

    • The Term: “broadband wireless repeater or relay”
    • Context and Importance: The applicability of the entire patent family to the Accused Hotspot Devices and RAN Products depends on this term's scope. Practitioners may focus on this term because the accused products are complex, multi-function devices (smartphones, base stations), not dedicated signal boosters, raising a question of whether they fall within the patent's definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the invention as facilitating "the interconnection of network devices using ultrawideband radio" and enabling a "source" to serve as a "local hub or access point" (’194 Patent, col. 3:51-56, col. 11:13-16). This may support a functional definition covering any device that relays data between different networks.
      • Evidence for a Narrower Interpretation: The title and frequent use of "repeater" could suggest a device whose primary function is to retransmit signals to extend range, potentially allowing an argument that this is a secondary feature of the accused smartphones and not the primary function of a RAN base station.

  • From the ’763 Patent:

    • The Term: “tuned by one or more passive elements which are selected or interconnected using electronic control”
    • Context and Importance: This term defines the core technical mechanism of the invention. The infringement case will hinge on whether the accused adaptive impedance tuners in Samsung's devices meet this specific functional and structural description.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the goal of "greatly simplifying the antenna structures" and reducing "mechanical design complexity" (’763 Patent, col. 3:62-67). This purpose-oriented language may support a construction that covers various electronic tuning methods that achieve this simplification.
      • Evidence for a Narrower Interpretation: The patent discloses specific embodiments involving "tunable capacitors or inductors" (’763 Patent, col. 9:45-48). The defense may argue that the claim should be limited to these specific types of passive elements or the particular ways they are "selected or interconnected" in the disclosed embodiments.

VI. Other Allegations

  • Indirect Infringement: The complaint makes specific allegations of induced infringement against the Accused Hotspot Devices. It alleges Samsung actively encourages infringement by providing customers with user manuals and online support guides that explicitly instruct them on how to configure and enable the hotspot functionality (Compl. ¶¶ 141, 150-151). The complaint includes a screenshot from a Galaxy S24 Ultra user manual titled "Mobile Hotspot" that provides step-by-step instructions for sharing the phone's mobile data connection (Compl. ¶153, p. 34).
  • Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged based on Samsung's deep familiarity with the inventor, Professor Rappaport, through industry collaborations, conference attendance, and citations to his academic work (Compl. ¶¶ 249-258). More pointedly, it alleges Samsung had specific knowledge of the ’194, ’358, and ’625 patents because they were cited by the USPTO during the prosecution of Samsung's own patent applications, forcing Samsung to argue the patentability of its inventions over the asserted patents (Compl. ¶¶ 260-263).

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

  • A core issue will be one of definitional scope: can the term “repeater or relay,” which the patent describes as a device to facilitate network interconnection, be construed to cover the complex, multi-purpose functionality of a consumer smartphone’s “hotspot” mode and a 5G RAN base station? The outcome of this question will determine the applicability of an entire family of the asserted patents.
  • A second central dispute will be one of technical operation: does the adaptive impedance tuning circuitry within Samsung's accused mobile devices function by "tuning...passive elements which are selected or interconnected using electronic control," as claimed in the smart antenna patents? This will likely be a fact-intensive inquiry dependent on expert analysis of the accused chipsets.
  • A key question for damages will be one of willfulness: given the complaint's specific allegations that Samsung was forced to distinguish its own inventions from several of the asserted patents during its own patent prosecution, what level of pre-suit knowledge and objective recklessness can be established?