DCT

4:25-cv-00886

Competitive Access Systems Inc v. Samsung Electronics Co Ltd

Log In
Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00886, E.D. Tex., 12/09/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. and Samsung Research America maintain regular and established places of business in the district, including a 216,000 square foot facility in Plano, Texas, and have committed acts of infringement there. Venue is alleged against the foreign parent, Samsung Electronics Co., Ltd., as it is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and network equipment, which utilize technologies for aggregating different network connections such as Wi-Fi and 4G/5G, infringe seven patents related to multipath communication methods.
  • Technical Context: The technology at issue involves combining multiple communication paths to increase data bandwidth, a key feature for modern mobile devices that simultaneously use Wi-Fi and cellular networks to enhance download speeds and connection reliability.
  • Key Procedural History: The complaint notes that in prior litigation involving a different defendant, a court in the Western District of Texas held that claims of U.S. Patent No. 9,350,649 (one of the patents-in-suit) were not directed to an abstract idea. The complaint also alleges that Samsung had knowledge of the inventor’s technology as early as 2016 by citing a related patent in one of its own patent applications, and that Samsung received direct notice of the asserted patents via a letter in October 2023.

Case Timeline

Date Event
2002-10-15 Earliest Priority Date for all Asserted Patents
2009-10-20 U.S. Patent No. 7,606,156 Issued
2012-07-24 U.S. Patent No. 8,228,801 Issued
2014-01-01 Approx. launch of Samsung "Download Booster" feature
2014-10-14 U.S. Patent No. 8,861,349 Issued
2016-01-01 Samsung cites inventor's patent application in its own prosecution
2016-05-24 U.S. Patent No. 9,350,649 Issued
2019-02-01 Samsung releases Galaxy S10, its first 5G smartphone with EN-DC
2020-12-15 U.S. Patent No. 10,868,908 Issued
2022-08-16 U.S. Patent No. 11,418,641 Issued
2023-02-14 U.S. Patent No. 11,582,343 Issued
2023-10-02 Plaintiff sends notice letter to Samsung
2025-12-09 Complaint Filed

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

U.S. Patent No. 7,606,156 - "Residential communications gateway (RCG) for broadband communications over a plurality of standard POTS lines..."

  • Patent Identification: U.S. Patent No. 7,606,156, "Residential communications gateway (RCG) for broadband communications over a plurality of standard POTS lines...", issued October 20, 2009.

The Invention Explained

  • Problem Addressed: At the time of the invention, high-speed internet alternatives like DSL and cable were expensive, complex to deploy, and had limited availability, while standard Plain Old Telephone Service (POTS) lines were ubiquitous but offered very limited bandwidth (maximum 56 Kbps) (Compl. ¶¶ 93-94; ’156 Patent, col. 2:26-50, col. 10:61-11:22).
  • The Patented Solution: The patent describes a "Residential Communications Gateway" (RCG) that can aggregate bandwidth from multiple, geographically dispersed communication networks to provide a broadband connection on-demand. The primary embodiment describes a system where an initiating RCG can recruit other nearby RCGs to use their respective POTS lines to assist in a data transfer, combining the bandwidth of all lines into a single "multilink PPP bundle" to overcome the 56 Kbps limitation of a single line (Compl. ¶¶ 100, 106-107; ’156 Patent, Abstract, col. 11:22-35).
  • Technical Importance: This approach enabled the delivery of broadband-level data speeds over existing, low-cost telephone infrastructure without requiring expensive upgrades to the telephone company's central office equipment (Compl. ¶ 99; ’156 Patent, col. 3:39-51).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶ 205).
  • Essential elements of Claim 1 include:
    • Developing and updating a network table of nearby RCGs, their bandwidth capabilities, and location.
    • Determining an optimum amount of bandwidth needed for a data transfer.
    • Determining which nearby RCGs to contact for unused bandwidth based on capacity, distance, and number of hops.
    • Sending a request to supporting RCGs for a portion of their unused bandwidth.
    • Receiving responses about how much bandwidth can be shared.
    • Selecting supporting RCGs for optimal use of needed bandwidth.
    • Contacting selected RCGs with control information for sending data.
    • Sending packets of data from the selected RCGs to the requesting RCG.
    • Reassembling the packets at the requesting RCG.
    • Relinquishing the bandwidth of each selected RCG.
  • The complaint reserves the right to assert additional claims, including claims 2-5 (Compl. ¶ 217).

U.S. Patent No. 8,228,801 - "Broadband Communications Device"

  • Patent Identification: U.S. Patent No. 8,228,801, "Broadband Communications Device," issued July 24, 2012.

The Invention Explained

The ’801 Patent shares a specification with the ’156 Patent and addresses the same technical problems (Compl. ¶ 85). It claims a communications device, rather than a method, that performs the function of aggregating bandwidth from multiple sources.

  • Problem Addressed: As described for the ’156 Patent, the invention sought to overcome the high cost and limited availability of broadband by leveraging existing, low-bandwidth network infrastructure (Compl. ¶¶ 93-94; ’156 Patent, col. 2:26-50).
  • The Patented Solution: The patent claims a communications device with at least one wired or wireless connection to a network and a wireless interface to connect to remote devices. A processor in the device requests assistance from the remote devices, selects them based on their available bandwidth, sends them control information to join a multilink connection, and aggregates the data received from them to increase the device's total data bandwidth (Compl. ¶ 225; ’156 Patent, col. 12:5-64).
  • Technical Importance: This device-focused patent claims the hardware and processor-level functionality for implementing the novel bandwidth aggregation system over existing infrastructure (Compl. ¶ 99; ’156 Patent, col. 3:39-51).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶ 224).

  • Essential elements of Claim 1 include:

    • A communications device with at least one connection to a communications network and at least one wireless interface for connecting to at least one remote communications device.
    • A processor that:
      • requests the remote device to assist in transferring data;
      • sends a request for unused bandwidth from the remote device;
      • receives a response with information about the unused bandwidth;
      • selects the remote device with unused bandwidth;
      • sends control information for participating in a multilink connection;
      • receives packets from the remote device; and
      • aggregates the data from the remote device with data from its own connection to increase data bandwidth.

  • The complaint reserves the right to assert additional claims, including claims 1-17 (Compl. ¶¶ 233-234).

  • U.S. Patent No. 8,861,349: "Broadband Communications Device," issued October 14, 2014.

    • Technology Synopsis: This patent, sharing the same specification, claims a method for increasing bandwidth by sending a multilink request from a first device to a geographically separate second device to join a multilink connection, then concurrently receiving data from the network at the first device's location and over a wireless connection from the second device (Compl. ¶ 138).
    • Asserted Claims: At least independent claim 13 is asserted (Compl. ¶¶ 241-242).
    • Accused Features: Samsung devices capable of implementing Multipath TCP (MPTCP) and E-UTRAN New Radio Dual Connectivity (EN-DC) as specified in 3GPP standards (Compl. ¶¶ 243-247).

  • U.S. Patent No. 9,350,649: "Multipath Communication Devices and Methods," issued May 24, 2016.

    • Technology Synopsis: This patent claims a data-requesting device that can connect concurrently to multiple network-edge devices during a multipath connection. A processor sends multipath information to devices capable of joining the connection and receives different data from different network-edge devices that have joined (Compl. ¶ 257).
    • Asserted Claims: At least independent claim 18 is asserted (Compl. ¶ 256).
    • Accused Features: Samsung devices implementing MPTCP and EN-DC, where the device connects to "Master Nodes" and "Secondary Nodes" (e.g., 4G and 5G base stations) that act as the claimed "network-edge devices" (Compl. ¶¶ 258-262).

  • U.S. Patent No. 10,868,908: "Devices and methods for multipath communications," issued December 15, 2020.

    • Technology Synopsis: This patent claims a device for multilink communication that receives multilink packets, splits data from a data source into different groups of packets during a session, and controls a data server to send the different groups to different network interfaces of a second device, with each group including a multilink session identification (Compl. ¶ 272).
    • Asserted Claims: At least independent claim 16 is asserted (Compl. ¶ 271).
    • Accused Features: Samsung devices (e.g., base stations) implementing MPTCP, EN-DC, and Carrier Aggregation (CA), where data is split using 3GPP's "split bearer" configuration and sessions are identified with a PDU Session ID (Compl. ¶¶ 273-280).

  • U.S. Patent No. 11,418,641: "Devices and Methods for Multipath Communications," issued August 16, 2022.

    • Technology Synopsis: This patent claims a communications device with a processor that sends a request to a remote device for availability to participate in a multilink communication and, if available, sends control information for participation, receives packets, and aggregates the data to increase bandwidth (Compl. ¶ 289). This claim structure is similar to that of the '801 patent.
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶ 288).
    • Accused Features: Samsung devices implementing MPTCP and EN-DC, where the device communicates with remote base stations ("Master Nodes" and "Secondary Nodes") to establish and aggregate data over a multilink connection (Compl. ¶¶ 290-297).

  • U.S. Patent No. 11,582,343: "Devices and Methods for Multipath Communications," issued February 14, 2023.

    • Technology Synopsis: This patent claims a communication device having a first connection to a first network and a second connection to a second network. A third connection to a remote device aggregates bandwidth from the first and second networks. In response to a request, the device receives a response with portions coming through both the first and second networks (Compl. ¶ 307).
    • Asserted Claims: At least independent claim 12 is asserted (Compl. ¶ 306).
    • Accused Features: Samsung devices implementing MPTCP and EN-DC, where the device connects simultaneously to a 4G-LTE network ("first network") and a 5G-NR network ("second network") to communicate with a remote server using a "split bearer" configuration (Compl. ¶¶ 308-312).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Infringing Products" as a broad range of Samsung devices and equipment, including smartphones (Galaxy S, Note, A, and Z Fold/Flip series), tablets (Galaxy Tab series), watches, base stations, and servers (Compl. ¶ 70).

Functionality and Market Context

  • The accused functionality centers on technologies that aggregate bandwidth from multiple network sources. These include Samsung's "Download Booster" feature, which simultaneously uses Wi-Fi and a mobile data connection via Multipath TCP (MPTCP) to accelerate downloads (Compl. ¶¶ 27, 69).
  • Also accused are implementations of 3GPP cellular standards, specifically E-UTRAN New Radio Dual Connectivity (EN-DC), which combines 4G and 5G network capabilities, and Carrier Aggregation (CA), which combines multiple cellular carriers (Compl. ¶¶ 28-29, 63). The complaint alleges these technologies are used in Samsung's 5G-capable devices, positioning them as essential for achieving the high speeds and low latency marketed as key benefits of 5G (Compl. ¶¶ 60-61, 65). Annotated Diagram 7 in the complaint illustrates how a remote device establishes a second data path to a server, a core concept in the multipath infringement theory (Compl. p. 37; ¶ 118).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,606,156 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for aggregating, sharing and dynamically routing and allocating bandwidth from a plurality of wired and wireless networks... A Samsung device implementing MPTCP establishes a connection with a server through multiple paths, such as a Wi-Fi router and a cellular base station, thereby aggregating bandwidth. ¶207 col. 11:29-35
developing and updating a network table that comprises a list of nearby RCGs, their bandwidth capabilities...and their location... A Samsung device initiates a multilink connection and identifies intermediary devices (e.g., Wi-Fi routers, cellular base stations) that function as "nearby RCGs" with multiple paths. ¶208 col. 15:5-24
determining an optimum amount of bandwidth needed for an immediate data transfer needs of the requesting RCG; A Samsung phone negotiates with a router or other network device to determine the optimal amount of bandwidth required for a data transfer. ¶209 col. 11:60-67
determining which of the nearby RCGs should be contacted for access to unused bandwidth...based upon...distance and a number of hops... A Samsung phone scans to detect nearby network devices (e.g., routers) and their relative distances to determine which to contact for a multipath TCP connection. ¶210 col. 12:19-28
sending a request to the supporting RCGs asking for use of a portion of the unused bandwidth; A Samsung phone negotiates with nearby network devices (e.g., wireless routers) for available bandwidth when establishing Wi-Fi connections. ¶211 col. 12:25-28
receiving responses from the supporting RCGs with information about how much bandwidth each selected RCG can share; A Samsung phone communicates with nearby network devices (e.g., routers) which, per the 802.11 specification, select a channel width, which is equivalent to sharing bandwidth information. ¶212 col. 12:28-35
selecting which of the supporting RCGs to use for optimal use of needed bandwidth; The Samsung device selects which network devices to use based on bandwidth calculations per the 802.11 RSSI function. ¶213 col. 12:52-56
contacting the selected RCGs with control information for sending data to the requesting RCG; Messages sent to initiate an MPTCP connection or associate a new subflow with an existing MPTCP connection constitute the claimed control information. ¶214 col. 12:52-60
sending packets of the data from the selected RCGs to the requesting RCG; In an MPTCP connection, the server sends data packets to the requesting Samsung device over multiple different subflows that involve different network devices ("selected RCGs"). ¶215 col. 12:67-13:3
reassembling the packets of the data at the requesting RCG; The Samsung device receives data packets over different subflows (e.g., a first and second subflow) and reassembles them to compile the requested data. ¶216 col. 13:4-12

U.S. Patent No. 8,228,801 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A communications device that is capable of providing broadband communications services... A Samsung device implementing MPTCP or EN-DC provides broadband services. ¶226 col. 3:12-20
at least one connection for connecting to a communications network; The Samsung device establishes a 4G-LTE or 5G-NR link to a base station, which provides connection to a network like the Internet. ¶227 col. 3:52-57
at least one wireless interface for connecting wirelessly to at least one remote communications device; The device’s modem connects wirelessly to a 4G-LTE base station (ENB) or 5G-NR base station (GNB), which is the "remote communications device." ¶228 col. 3:42-45
a processor that requests the at least one remote communications device to assist in transferring data... The processor in a Samsung device exchanges messages (e.g., RRC Connection Setup Complete) with base stations to establish connections for data transfer. ¶229 col. 12:5-9
sends a request to the at least one remote communications device for requesting use of a portion of unused bandwidth... The processor exchanges messages and data structures as part of the EN-DC configuration to request and allocate network resources. ¶230 col. 12:25-28
sends control information to the at least one remote communications device for participating in a multilink connection, The processor exchanges messages (e.g., UE Capability Information, GNB Addition Request) that constitute control information for setting up the EN-DC multilink connection. ¶231 col. 12:52-60
receives packets from the at least one remote communications device and aggregates the data...to increase data bandwidth... The Samsung device connects to both a 4G-LTE (ENB) and 5G-NR (GNB) base station simultaneously, aggregating data from both using a "split bearer" configuration to increase bandwidth. ¶232 col. 13:4-12

Identified Points of Contention

  • Scope Questions: A central point of contention may be whether terms originating in the context of aggregating residential POTS lines can be construed to cover modern cellular and Wi-Fi technologies. For the ’156 Patent, the question is whether a modern cellular base station or Wi-Fi router constitutes a "Residential communications gateway (RCG)." For the ’801 Patent, a similar question arises as to whether a 4G/5G base station (ENB/GNB) is a "remote communications device" as contemplated by the patent. Annotated Diagram 1 illustrates the patented concept with houses connected to a central office, which may be used to argue for a narrower, residential-focused interpretation of these terms (Compl. p. 29; ¶ 106).
  • Technical Questions: The complaint maps steps from standardized 3GPP protocols (like MPTCP and EN-DC) to the specific method steps of the asserted claims. A key technical question will be whether the automated, protocol-defined interactions between a Samsung phone and a base station perform the specific sequence of "requesting," "receiving responses," "selecting," and "contacting" as recited, for example, in claim 1 of the ’156 patent. The analysis may focus on whether there is a functional one-to-one mapping or a fundamental difference in operation.

V. Key Claim Terms for Construction

"Residential communications gateway (RCG)" (’156 Patent, Claim 1)

  • Context and Importance: This term is the central apparatus in the ’156 patent's method claim. Its construction is critical because the infringement theory requires mapping this term onto modern network equipment like Wi-Fi routers and cellular base stations (Compl. ¶ 208). Practitioners may focus on whether the "Residential" modifier limits the term's scope to a device physically located in a residence, which could challenge the allegations against network infrastructure.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The body of claim 1 refers more generally to aggregating bandwidth from "a plurality of wired and wireless networks that are geographically disbursed" without an explicit limitation to a residence. The specification also describes the RCG's function as combining capabilities of "IP routers, Class 5 circuit switches and wireless LANs" (Compl. ¶ 99; ’156 Patent, col. 2:50-52), suggesting a functional definition.
    • Evidence for a Narrower Interpretation: The patent's title explicitly names a "Residential communications gateway." The abstract describes deploying the RCG "in a residence" (’156 Patent, Abstract), and the detailed embodiment figures consistently depict RCGs as devices within houses (e.g., ’156 Patent, Fig. 7).

"remote communications device" (’801 Patent, Claim 1)

  • Context and Importance: This term is what the claimed "communications device" (the accused Samsung phone) connects with to aggregate bandwidth. The complaint alleges this term reads on 4G/5G base stations (Compl. ¶ 228). The case may turn on whether a cellular base station, which is part of a carrier's infrastructure, qualifies as a "remote communications device" in the context of a patent whose primary embodiment shows peer-to-peer communication between similar devices (other RCGs).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is not explicitly defined or limited in the claim language, potentially allowing for any communicatively "remote" device that performs the recited functions.
    • Evidence for a Narrower Interpretation: The shared specification's main embodiment shows the "remote communications device" to be another RCG (element 86 in Fig. 7), suggesting the "remote" device is a peer device of the same type, not a piece of core network infrastructure like a base station (’156 Patent, Fig. 7). This is reinforced by descriptions of RCGs in neighboring residences assisting each other (Compl. ¶¶ 112-113).

VI. Other Allegations

Indirect Infringement

  • The complaint alleges inducement of infringement across all asserted patents. The basis for this allegation is that Samsung actively advertises, instructs, and encourages end-users and developers to use the infringing functionalities (e.g., Download Booster, EN-DC, Carrier Aggregation) through product materials, user manuals, and developer documentation (Compl. ¶¶ 77, 219, 236, 251, 266, 283, 301, 316).

Willful Infringement

  • Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges pre-suit knowledge dating back to at least 2016, when Samsung cited the inventor's patent family during the prosecution of its own patent application (Compl. ¶ 71). It further alleges knowledge from at least October 2, 2023, the date of a notice letter sent to Samsung (Compl. ¶¶ 72-73). The continuation of infringing activities after these dates is alleged to be willful (Compl. ¶ 75, ¶ 78).

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

  • A core issue will be one of definitional scope: can terms such as "Residential communications gateway (RCG)" and "remote communications device," which are described in the patent specification in the context of peer-to-peer aggregation of residential POTS lines, be construed broadly enough to cover modern, fundamentally different network components like carrier-owned 4G/5G base stations and consumer Wi-Fi routers?
  • A key evidentiary question will be one of functional mapping: do the standardized operations of 3GPP protocols like MPTCP and EN-DC, as implemented in Samsung's products, perform the specific, sequential steps of discovering, querying, selecting, and controlling other devices as explicitly recited in the method claims, or is there a technical mismatch between the high-level goal of bandwidth aggregation and the particular patented method for achieving it?
  • A third question will relate to prior art and obviousness: given the early (2002) priority date, the dispute may examine whether the specific methods of dynamic bandwidth allocation and multilink session management claimed by the patents were truly novel, or whether they represent an obvious combination of known networking principles (like multilink PPP and routing table management) applied to the problem of slow connection speeds.