Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 1 of 22 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`ERICSSON INC., TELEFONAKTIEBOLAGET
`LM ERICSSON, AND ERICSSON AB
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD., AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
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`Defendants.
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`Civil Action No. 2:21-cv-1
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`JURY TRIAL
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiffs Ericsson Inc., Telefonaktiebolaget LM Ericsson, and Ericsson AB (collectively,
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`“Ericsson”) file this Original Complaint for Patent Infringement against Samsung Electronics
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`Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”), and allege as
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`follows:
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`The Parties
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`1.
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`Plaintiff Ericsson Inc. is a Delaware corporation with its principal place of
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`business at 6300 Legacy Drive, Plano, Texas 75024.
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`2.
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`Plaintiff Telefonaktiebolaget LM Ericsson is a corporation organized under the
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`laws of the Kingdom of Sweden with its principal place of business at Torshamnsgatan 21, Kista,
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`164 83, Stockholm, Sweden.
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`3.
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`Plaintiff Ericsson AB is a corporation under the laws of the Kingdom of Sweden
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`with its principal place of business at Torshamnsgatan 23, Kista, 16480, Stockholm, Sweden.
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`NG-9J84MDUI 4848-6787-5541v6
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`4.
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`Ericsson owns a valuable portfolio of patents that are globally used in cellular
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`handsets, smartphones, tablet computers, televisions, and many other electrical devices.
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`5.
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`Defendant Samsung Electronics Co., Ltd. (“SEC”) is a Korean company with its
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`principal place of business in Suwon, South Korea. SEC has an “Information Technology &
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`Mobile Communications” division that is responsible for the design, manufacture, and sale of
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`mobile devices, such as smartphones that operate on cellular networks around the world and in
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`the United States.
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`6.
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`Defendant Samsung Electronics America, Inc. (“SEA”) is a New York
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`corporation with its principal place of business in Ridgefield Park, New Jersey, and it is a
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`wholly-owned subsidiary of SEC. SEA imports into the United States and sells in the United
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`States, including in this District, smartphones that operate on cellular networks in the United
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`States.
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`Jurisdiction and Venue
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`7.
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`This is an action arising under the patent laws of the United States, 35 U.S.C. §
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`271. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
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`8.
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`9.
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`Venue proper in this judicial district under 28 U.S.C. §§ 1391 and 1400(b).
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`This Court has personal jurisdiction over Defendants Samsung. Samsung has
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`continuous and systematic business contacts with the State of Texas. Samsung, directly or
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`through subsidiaries or intermediaries (including distributors, retailers, and others), has
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`negotiated with Ericsson in this District, and also conducts its business extensively throughout
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`Texas, by shipping, distributing, offering for sale, selling, and advertising (including the
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`provision of an interactive web page) its products and/or services in the State of Texas and the
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`Eastern District of Texas. SEA, SEC’s wholly-owned subsidiary, maintains an office in Plano,
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`Texas, and is responsible for importing and selling smartphones, tablets, other mobile devices,
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`and cellular network infrastructure equipment that operate on cellular networks in the United
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`States, as well as televisions with wireless connectivity. SEC and SEA regularly do business or
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`solicit business, engage in other persistent courses of conduct, and/or derive substantial revenue
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`from products and/or services provided to individuals in the State of Texas.
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`10.
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`SEC and SEA, directly and through subsidiaries or intermediaries (including
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`distributors, retailers, and others), have purposefully and voluntarily placed one or more products
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`and/or services in the stream of commerce that practice the Asserted Patents with the intention
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`and expectation that they will be purchased and used by consumers in the Eastern District of
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`Texas. These products and/or services have been and continue to be purchased and used by
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`consumers in the Eastern District of Texas.
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`11.
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`On information and belief the Samsung products accused of infringement in this
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`case are manufactured, in whole or in part, by Samsung Electronics Thai Nguyen Co. Ltd.,
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`Samsung Electronics Vietnam Co., Ltd., and Samsung Electronics HCMC CE Complex, Co.,
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`Ltd., which are subsidiaries of Defendant Samsung Electronics Co., Ltd.
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`12.
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`Ericsson Inc. is a corporation with its principal place of business in the Eastern
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`District of Texas. Ericsson Inc. is a wholly-owned subsidiary of LME, and is responsible, among
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`other things, for importing and selling cellular network infrastructure equipment to cellular
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`carriers in the United States.
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`The Asserted Patents
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`13.
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`U.S. Patent No. 7,151,430, entitled “Method of and Inductor Layout for Reduced
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`VCO Coupling,” was duly and legally issued to inventor Thomas Mattson on December 19,
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`2006. Ericsson owns by assignment the entire right, title, and interest in the ʼ430 patent and is
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`entitled to sue for past and future infringement.
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`14.
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`U.S. Patent No. 6,879,849, entitled “In-Built Antenna for Mobile Communication
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`Device,” was duly and legally issued to inventor Stjepan Begic on April 12, 2005. Ericsson owns
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`by assignment the entire right, title, and interest in the ʼ849 patent and is entitled to sue for past
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`and future infringement.
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`15.
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`U.S. Patent No. 7,286,823, entitled “Mobile Multimedia Engine,” was duly and
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`legally issued to inventors Mikael Reinholdsson, Erik Ledfelt, and Johan Svener on October 23,
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`2007. Ericsson owns by assignment the entire right, title, and interest in the ʼ823 patent and is
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`entitled to sue for past and future infringement.
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`16.
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`U.S. Patent No. 9,313,178, entitled “Method and System for Secure Over-the-top
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`Live Video Delivery,” was duly and legally issued to inventors Kevin J. Ma, Robert Hickey, and
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`Paul Tweedale on April 12, 2016. Ericsson owns by assignment the entire right, title, and interest
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`in the ʼ178 patent and is entitled to sue for past and future infringement.
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`Count I: Claim for Patent Infringement of the ʼ430 Patent
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`17.
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`Ericsson repeats and realleges the allegations in paragraphs 1-16 as if fully set
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`forth herein.
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`18.
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`Samsung has infringed, contributed to the infringement of, and/or induced
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`infringement of the ’430 patent by making, using, selling, offering for sale, or importing into the
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`United States, or by intending that others make, use, import into, offer for sale, or sell in the
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`United States, products and/or methods covered by one or more claims of the ’430 Patent, and
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`products which are made by a process covered by one or more claims of the ‘430 Patent,
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`including, but not limited to, smartphones and other mobile devices and televisions with wireless
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`NG-9J84MDUI 4848-6787-5541v6
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`connectivity. The accused electronic devices with wireless connectivity that infringe one or more
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`claims of the ’430 patent include, but are not limited to, at least the Samsung Galaxy S20+5G
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`and Samsung’s The Frame, The Terrace, Q70T, Q80T, Q90T, Q800T, Q900TS, 32Q50, Q60T,
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`TU8000, and TU8300 smart TVs.
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`19.
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`For example, at least the Samsung Galaxy S20+5G and the Samsung 32Q50
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`Smart TV infringe at least claims 1, 11, and 20 of the ʼ430 patent. Samsung makes, uses, sells,
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`offers for sale, imports, exports, supplies or distributes within the United States these devices,
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`which are covered by or made by a process covered by the claims of the ‘430 patent, and thus
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`directly infringes the ʼ430 patent.
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`20.
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`Samsung indirectly infringes the ʼ430 patent as provided by 35 U.S.C. § 271(b)
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`by inducing infringement by others, such as resellers and end-user customers in this District and
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`throughout the United States. For example, direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G and the
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`Samsung 32Q50 Smart TV, who perform each step of the claimed invention as directed by
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`Samsung. Samsung received actual notice of the ʼ430 patent at least as early as the filing of this
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`Complaint.
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`21.
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`Samsung’s affirmative acts of selling the Galaxy S20+5G and the Samsung
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`32Q50 Smart TV, causing the Samsung Galaxy S20+5G and the Samsung 32Q50 Smart TV to
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`be manufactured, and providing directions, instructions, schematics, diagrams, or designs to its
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`manufacturers, resellers, or end-users to make or use the Samsung Galaxy S20+5G and the
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`Samsung 32Q50 Smart TV in a manner that directly infringes the ʼ430 patent. Through its
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`manufacture and sales of the Galaxy S20+5G and the Samsung 32Q50 Smart TV, Samsung
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`performed the acts that constitute induced infringement with knowledge or willful blindness that
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`the induced acts would constitute infringement.
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`22.
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`Samsung also indirectly infringes the ʼ430 patent by contributing to infringement
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`by others, such as resellers and end-user customers, in accordance with 35 U.S.C. § 271(c) in this
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`District and throughout the United States. Direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G and the
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`Samsung 32Q50 Smart TV.
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`23.
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`Samsung’s affirmative acts of selling the Galaxy S20+5G and the 32Q50 Smart
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`TV and causing the Galaxy S20+5G and the 32Q50 Smart TV to be manufactured and sold
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`contribute to Samsung’s manufacturers, resellers, and end-users making or using the Galaxy
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`S20+5G and the 32Q50 Smart TV in a normal and customary way that infringes the ʼ430 patent.
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`The Galaxy S20+5G and the 32Q50 Smart TV constitutes the material part of Ericsson’s
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`patented invention, has no substantial non-infringing uses, and is known by Samsung to be
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`especially made or especially adapted for use to infringe the ʼ430 patent.
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`24.
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`The Samsung Galaxy S20+5G uses the Broadcom BCM4375 Dual-Band
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`802.11ax Wi-Fi/Bluetooth Combo Chip, which includes an inductor layout having reduced
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`mutual electromagnetic coupling on the semiconductor die.
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`25.
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`The Samsung Galaxy S20+5G includes at least one first inductor having a
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`reduced far field that includes a first loop having a shape that is substantially symmetrical about
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`a first predefined axis. The Samsung Galaxy S20+5G also has a second loop that is connected to
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`and substantially identical in shape and size to the first loop. The second loop is arranged such
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`that a magnetic field emanating therefrom tends to cancel a magnetic field emanating from the
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`first loop. The direction and orientation of the electrical current flowing through the two loops
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`results in such a manner as to cancel a magnetic field emanating from the first loop. The image
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`below depicts at least one first inductor of the Samsung Galaxy S20+5G comprising a first and
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`second loop:
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`26.
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`The Samsung Galaxy S20+5G includes two closely spaced terminals connected to
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`the first loop for supplying electrical current to the first and second loops while minimizing
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`magnetic field contributions from the terminals.
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`27.
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`The Samsung Galaxy S20+5G also includes at least one second inductor
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`positioned at a predetermined distance from the first inductor, wherein a mutual electromagnetic
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`coupling between the first inductor and the second inductor is reduced as a result of the first
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`inductor having a reduced electromagnetic field. The image below depicts the relative position of
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`the first and second inductors in the Samsung S20+5G:
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`NG-9J84MDUI 4848-6787-5541v6
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`28.
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`The Samsung 32Q50 Smart TV uses the Samsung WCP730M module, which
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`includes the MediaTek MT7668 chip with an inductor layout having reduced mutual
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`electromagnetic coupling on the semiconductor die.
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`29.
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`The Samsung 32Q50 Smart TV includes at least one first inductor having a
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`reduced far field that includes a first loop having a shape that is substantially symmetrical about
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`a first predefined axis. The Samsung 32Q50 Smart TV also has a second loop that is connected
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`to and substantially identical in shape and size to the first loop. The second loop is arranged such
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`that a magnetic field emanating therefrom tends to cancel a magnetic field emanating from the
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`first loop. The direction and orientation of the electrical current flowing through the two loops
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`results in such a manner as to cancel a magnetic field emanating from the first loop. The image
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`NG-9J84MDUI 4848-6787-5541v6
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`8
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 9 of 22 PageID #: 9
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`below depicts at least one first inductor of the Samsung 32Q50 Smart TV comprising a first and
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`second loop:
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`30.
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`The Samsung 32Q50 Smart TV includes two closely spaced terminals connected
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`to the first loop for supplying electrical current to the first and second loops while minimizing
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`magnetic field contributions from the terminals.
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`31.
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`The Samsung 32Q50 Smart TV also includes at least one second inductor
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`positioned at a predetermined distance from the first inductor, wherein a mutual electromagnetic
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`coupling between the first inductor and the second inductor is reduced as a result of the first
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`inductor having a reduced electromagnetic field. The image below depicts the relative position of
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`the first inductor and the second inductors in the Samsung 32Q50 Smart TV:
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`NG-9J84MDUI 4848-6787-5541v6
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 10 of 22 PageID #: 10
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`Count II: Claim for Patent Infringement of the ʼ849 Patent
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`32.
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`Ericsson repeats and realleges the allegations in paragraphs 1-31 as if fully set
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`forth herein.
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`33.
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`Samsung has infringed, contributed to the infringement of, and/or induced
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`infringement of the ’849 patent by making, using, selling, offering for sale, or importing into the
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`United States, or by intending that others make, use, import into, offer for sale, or sell in the
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`United States, products and/or methods covered by one or more claims of the ’849 Patent, and
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`products which are made by a process covered by one or more claims of the ‘849 Patent,
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`including, but not limited to, smartphones and other mobile devices. The accused wireless
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`communication devices that infringe one or more claims of the ’849 patent include, but are not
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`limited to, at least the Samsung Galaxy S20+5G.
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`34.
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`For example, at least the Samsung Galaxy S20+5G infringes at least claims 1 and
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`12 of the ʼ849 patent. Samsung makes, uses, sells, offers for sale, imports, exports, supplies or
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`distributes within the United States these devices, which are covered by or made by a process
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`covered by the claims of the ‘849 patent, and thus directly infringes the ʼ849 patent.
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`NG-9J84MDUI 4848-6787-5541v6
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`10
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 11 of 22 PageID #: 11
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`35.
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`Samsung indirectly infringes the ʼ849 patent as provided by 35 U.S.C. § 271(b)
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`by inducing infringement by others, such as resellers and end-user customers in this District and
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`throughout the United States. For example, direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G, who
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`perform each step of the claimed invention as directed by Samsung. Samsung received actual
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`notice of the ʼ849 patent at least as early as of the filing of this Complaint.
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`36.
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`Samsung’s affirmative acts of selling the Galaxy S20+5G, causing the Samsung
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`Galaxy S20+5G to be manufactured, and providing directions, instructions, schematics,
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`diagrams, or designs to its manufacturers, resellers, or end-users to make or use the Samsung
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`Galaxy S20+5G in a manner that directly infringes the ʼ849 patent. Through its manufacture and
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`sales of the Galaxy S20+5G, Samsung performed the acts that constitute induced infringement
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`with knowledge or willful blindness that the induced acts would constitute infringement.
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`37.
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`Samsung also indirectly infringes the ʼ849 patent by contributing to infringement
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`by others, such as resellers and end-user customers, in accordance with 35 U.S.C. § 271(c) in this
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`District and throughout the United States. Direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G.
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`38.
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`Samsung’s affirmative acts of selling the Galaxy S20+5G and causing the Galaxy
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`S20+5G to be manufactured and sold contribute to Samsung’s manufacturers, resellers, and end-
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`users making or using the Galaxy S20+5G in a normal and customary way that infringes the ʼ849
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`patent. The Galaxy S20+5G constitutes the material part of Ericsson’s patented invention, has no
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`substantial non-infringing uses, and is known by Samsung to be especially made or especially
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`adapted for use to infringe the ʼ849 patent.
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`NG-9J84MDUI 4848-6787-5541v6
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`39.
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`The Samsung Galaxy S20+5G is a mobile communication device having a case
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`and a main printed circuit board within the case for mounting electronic communication
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`components, including an antenna apparatus.
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`40.
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`The Samsung Galaxy S20+5G includes an antenna pattern formed of conductive
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`material (metal) located on a specified planar surface of a main printed circuit board, as shown in
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`the image below of the surface of a mmWave communication PCB opposite to the side on which
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`an antenna control circuitry IC is mounted:
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`41.
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`The antenna apparatus in the Samsung Galaxy S20+5G includes a ground plane
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`formed of electrically conductive material. For example, a metal plate that is grounded (i.e., a
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`ground plane) is mounted on a separate PCB within the case that encloses the mmWave
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`communication PCB, as shown in the image below:
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`NG-9J84MDUI 4848-6787-5541v6
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`42.
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`The antenna apparatus of the Samsung Galaxy S20+5G has a mounting device for
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`supporting the ground plane within the case so that the ground plane is in a facing spaced-apart
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`parallel relationship with the antenna pattern and is in a spaced-apart relationship with the
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`printed circuit board. For example, in the Galaxy S20+5G, the mounting device for spacing apart
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`and supporting the mmWave communication PCB and a separate PCB having a ground plane
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`includes a mated connector and interface PCB that is mounted between the mmWave
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`communication PCB and the ground plane on the separate PCB, as shown in the image below:
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`NG-9J84MDUI 4848-6787-5541v6
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`Count III: Claim for Patent Infringement of the ʼ823 Patent
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`43.
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`Ericsson repeats and realleges the allegations in paragraphs 1-42 as if fully set
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`
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`forth herein.
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`44.
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`Samsung has infringed, contributed to the infringement of, and/or induced
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`infringement of the ’823 patent by making, using, selling, offering for sale, or importing into the
`
`United States, or by intending that others make, use, import into, offer for sale, or sell in the
`
`United States, products and/or methods covered by one or more claims of the ’823 Patent
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`including, but not limited to, smartphones and other mobile devices. The accused wireless
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`communication devices that infringe one or more claims of the ’823 patent include, but are not
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`limited to, at least the Samsung Galaxy S20+5G.
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`45.
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`For example, at least the Samsung Galaxy S20+5G infringes at least claim 15 of
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`the ʼ823 patent. Samsung makes, uses, sells, offers for sale, imports, exports, supplies or
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`distributes within the United States these devices and thus directly infringes the ʼ823 patent.
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`NG-9J84MDUI 4848-6787-5541v6
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 15 of 22 PageID #: 15
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`46.
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`Samsung indirectly infringes the ʼ823 patent as provided by 35 U.S.C. § 271(b)
`
`by inducing infringement by others, such as resellers and end-user customers in this District and
`
`throughout the United States. For example, direct infringement is the result of activities
`
`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G, who
`
`perform each step of the claimed invention as directed by Samsung. Samsung received actual
`
`notice of the ʼ823 patent at least as early as of the filing of this Complaint.
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`47.
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`Samsung’s affirmative acts of selling the Samsung Galaxy S20+5G, causing the
`
`Samsung Galaxy S20+5G to be manufactured, and providing directions, instructions, schematics,
`
`diagrams, or designs to its manufacturers, resellers, or end-users to make or use the Samsung
`
`Samsung Galaxy S20+5G in a manner that directly infringes the ʼ823 patent. Through its
`
`manufacture and sales of the Samsung Galaxy S20+5G, Samsung performed the acts that
`
`constitute induced infringement with knowledge or willful blindness that the induced acts would
`
`constitute infringement.
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`48.
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`Samsung also indirectly infringes the ʼ823 patent by contributing to infringement
`
`by others, such as resellers and end-user customers, in accordance with 35 U.S.C. § 271(c) in this
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`District and throughout the United States. Direct infringement is the result of activities
`
`performed by manufacturers, resellers, or end-users of the Samsung Galaxy S20+5G.
`
`49.
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`Samsung’s affirmative acts of selling the Samsung Galaxy S20+5G and causing
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`the Samsung Galaxy S20+5G to be manufactured and sold contribute to Samsung’s
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`manufacturers, resellers, and end-users making or using the Samsung Galaxy S20+5G in a
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`normal and customary way that infringes the ʼ823 patent. The Samsung Galaxy S20+5G
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`constitutes the material part of Ericsson’s patented invention, has no substantial non-infringing
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`NG-9J84MDUI 4848-6787-5541v6
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`uses, and is known by Samsung to be especially made or especially adapted for use to infringe
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`the ʼ823 patent.
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`50.
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`The Samsung Galaxy S20+5G is a mobile terminal for a wireless communications
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`system. The Samsung Galaxy S20+5G and its Android 10 operating system comprise a mobile
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`multimedia engine. The Android operating system on the Samsung Galaxy S20+5G is a software
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`services component. The Samsung Galaxy S20+5G includes various hardware components,
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`including a display, camera, memory, audio components, etc. that are controlled by the software
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`services component. For example, the display and audio outputs of the Samsung Galaxy S20+5G
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`are controlled by the software services components that supports the respective video and audio
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`codecs.
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`51.
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`The Samsung Galaxy S20+5G includes various multimedia application software,
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`such as Camera, Gallery, and Samsung Voice applications. These applications access the camera,
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`display, and audio input/recording; video playback, audio playback, and display functionality.
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`Additionally, the Android operating system provides a framework for creating certain third-party
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`or OEM camera or media applications to be installed on the Samsung Galaxy S20+5G.
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`52.
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`The Samsung Galaxy S20+5G also includes an interface component that
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`corresponds to a JAVA API framework. The JAVA API Framework comprises Android
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`Multimedia framework - android.media, which comprises android.media.MediaCodec and
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`android.media.MediaPlayer for providing at least one multimedia application with access to the
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`mobile multimedia engine (for example, access to low-level media codecs and hardware).
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`53.
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`The Java API framework also comprises a middleware services layer including
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`the at least one interface including an application programming interface (API) for loading,
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`installing and running multimedia application software in the multimedia engine.
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 17 of 22 PageID #: 17
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`54.
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`The middleware services layer of the Samsung Galaxy S20+5G’s Android
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`operating system isolates the mobile multimedia engine from the multimedia application
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`software except via the at least one interface (the functionalities provided by the framework APIs
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`communicate with system services to access the underlying hardware/resources accessible only
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`through the operating system).
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`Count IV: Claim for Patent Infringement of the ʼ178 Patent
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`55.
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`Ericsson repeats and realleges the allegations in paragraphs 1-54 as if fully set
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`forth herein.
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`56.
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`Samsung has infringed, contributed to the infringement of, and/or induced
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`infringement of the ’178 patent by making, using, selling, offering for sale, or importing into the
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`United States, or by intending that others make, use, import into, offer for sale, or sell in the
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`United States, products and/or methods covered by one or more claims of the ’178 Patent
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`including, but not limited to, Samsung smartphones and other mobile devices and Smart TVs
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`implementing Google Widevine DRM, including Samsung’s Samsung Galaxy S20 Ultra, Galaxy
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`S20 5G, Galaxy S20+ 5G, Galaxy S20 Ultra 5G, Galaxy S10 series, Galaxy S7 series, Galaxy S5
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`series, Galaxy Z Fold2 5G, and Galaxy Fold 512GB mobile phones, Samsung’s Galaxy Tab S7,
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`Galaxy Tab S7+, Galaxy Tab S6, Galaxy Tab S6 Lite, Galaxy Tab S5e, Galaxy Tab S4, Galaxy
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`Tab A7 10.4, Galaxy Tab A 8.4, Galaxy Tab A 8.0 Kids Edition, Galaxy Tab A 8.0, Galaxy Tab
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`A 10.1, and Galaxy Tab A 8.0 tablet computers; and The Frame, The Terrace, Q70T, Q80T,
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`Q90T, Q800T, Q900TS, Q900, 32Q50, Q60T, The Sero, The Serif, TU7000, TU8000, TU8300,
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`RU9000, Q50R, N5300, Q950TS, and TU6950 smart TVs (“Samsung Widevine Products”).
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 18 of 22 PageID #: 18
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`57.
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`For example, Samsung Widevine Products infringe at least claim 1 of the ʼ178
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`patent. Samsung makes, uses, sells, offers for sale, imports, exports, supplies or distributes
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`within the United States these devices and thus directly infringes the ʼ178 patent.
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`58.
`
`Samsung indirectly infringes the ʼ178 patent as provided by 35 U.S.C. § 271(b)
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`by inducing infringement by others, such as resellers and end-user customers in this District and
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`throughout the United States. For example, direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of Samsung Widevine Products, who
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`perform each step of the claimed invention as directed by Samsung. Samsung received actual
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`notice of the ʼ178 patent at least as early as of the filing of this Complaint.
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`59.
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`Samsung’s affirmative acts of selling Widevine Products, causing the Samsung
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`Widevine Products to be manufactured, and providing directions, instructions, schematics,
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`diagrams, or designs to its manufacturers, resellers, or end-users to make or use the Samsung
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`Widevine Products in a manner that directly infringes the ʼ178 patent. Through its manufacture
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`and sales of Samsung Widevine Products, Samsung performed the acts that constitute induced
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`infringement with knowledge or willful blindness that the induced acts would constitute
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`infringement.
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`60.
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`Samsung also indirectly infringes the ʼ178 patent by contributing to infringement
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`by others, such as resellers and end-user customers, in accordance with 35 U.S.C. § 271(c) in this
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`District and throughout the United States. Direct infringement is the result of activities
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`performed by manufacturers, resellers, or end-users of Samsung Smart TVs.
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`61.
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`Samsung’s affirmative acts of selling the Samsung Widevine Products and
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`causing the Samsung Widevine Products to be manufactured and sold contribute to Samsung’s
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`manufacturers, resellers, and end-users making or using Samsung Widevine Products in a normal
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 19 of 22 PageID #: 19
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`and customary way that infringes the ʼ178 patent. Samsung Widevine Products constitute the
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`material part of Ericsson’s patented invention, has no substantial non-infringing uses, and is
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`known by Samsung to be especially made or especially adapted for use to infringe the ʼ178
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`patent.
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`62.
`
`Samsung Widevine Products implement a method of handling secure distribution
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`of content by supporting Google Widevine DRM with a common encryption API.
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`63.
`
`Samsung Widevine Products perform the step of initiating a media playback
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`request (e.g., tuning into a live stream) and receiving a playback request response (e.g., the client
`
`player receiving a license that corresponds to the live stream).
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`64.
`
`Samsung Widevine Products perform the step of parsing content information from
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`the playback request response (e.g., “pssh” data blobs being returned), the content information
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`including content encryption keys (keys for the media segment), content encryption key
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`identifiers (e.g., key Ids), and content encryption key expiration times (e.g., each key is
`
`associated with a key rotation period).
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`65.
`
`Samsung Widevine Products perform the step of retrieving content and manifest
`
`files from a content delivery server. For example, the Google Widevine DRM system
`
`implements on Samsung Widevine Products retrieves content (e.g., video) and a manifest (MPD)
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`from a content delivery network.
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`66.
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`Samsung Widevine Products perform the step of detecting content encryption key
`
`rotation boundaries between periods of use of different content encryption keys in decrypting
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`retrieved content. For example, with the client encounters a new “pssh” box, it will issue a new
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`license request. The key rotation boundary occurs whenever the client encounters a new “pssh”
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`box, at which point it will issue a new license request and continue to decrypt content.
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 20 of 22 PageID #: 20
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`67.
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`Samsung Widevine Products perform the step of issuing requests to a license
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`server ahead of a key rotation boundary to retrieve a second content encryption key to be used
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`after a content encryption key rotation boundary is reached. For example, the client issues a new
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`license request to the license server ahead of a key rotation boundary as it can still decrypt
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`content in a current key period. The client also has keys required to decrypt the new key period,
`
`which is a second content encryption key to be used after a content encryption key rotation
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`boundary is reached.
`
`68.
`
`Samsung Widevine Products perform the step of applying the second key for
`
`content decryption after the key rotation boundary is reached. For example, once the key rotation
`
`boundary is reached, the client applies keys to decrypt content.
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`Demand for Jury Trial
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`Ericsson hereby demands a trial by jury on all claims so triable.
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`Prayer for Relief
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`WHEREFORE, Ericsson respectfully requests that this Court enter judgment in its favor
`
`and grant the following relief:
`
`A. Adjudge that Samsung infringes the Asserted Patents;
`
`B. Adjudge that Samsung’s infringement of the Asserted Patents was willful, and that
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`Samsung’s continued infringement of the Asserted Patents is willful;
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`C. Award Ericsson damages in an amount adequate to compensate Ericsson for
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`Samsung’s infringement of the Asserted Patents, but in no event less than a
`
`reasonable royalty under 35 U.S.C. § 284;
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`D. Award enhanced damages pursuant to 35 U.S.C. § 284;
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`Case 2:21-cv-00001 Document 1 Filed 01/01/21 Page 21 of 22 PageID #: 21
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`E. Award Ericsson pre-judgment and post-judgment interest to the full extent allowed
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`under the law, as well as its costs;
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`F. Enter an order finding that this is an exceptional case and awarding Ericsson its
`