Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 1 of 57 PageID #: 1
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`
`MIMO RESEARCH, LLC,
` Plaintiff,
`v.
`
`SAMSUNG ELECTRONICS AMERICA, INC.
`AND SAMSUNG ELECTRONICS CO., LTD.,
` Defendants.
`
`
`
`
`
`
`
`
`Civil Action No._________
`
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`MIMO Research, LLC (“MIMO Research” or “Plaintiff”) brings this action and makes the
`
`following allegations of patent infringement relating to U.S. Patent Nos.: 7,091,854 (the “‘854
`
`patent”); 7,046,716 (the “‘716 patent”); 7,133,646 (the “‘646 patent”); 7,305,057 (the “‘057
`
`patent”); and 7,433,382 (the “‘382 patent”) (collectively, the “patents-in-suit”). Defendants
`
`Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd. (collectively, “Defendant(s)”
`
`or “Samsung”) infringe the patents-in-suit in violation of the patent laws of the United States of
`
`America, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`Plaintiff MIMO Research, LLC (“Plaintiff” or “MIMO Research”) is a New York
`
`1.
`
`limited liability company established in 2017. MIMO Research owns a portfolio of patents that
`
`cover Multiple Input Multiple Output (“MIMO”) wireless communication, powerline networking,
`
`and ultra-wideband (“UWB”) technology. MIMO Research is the owner of all rights, title, and
`
`interest in and to the patents-in-suit.
`
`2.
`
`Highlighting the importance of the patents-in-suit is the fact that the MIMO
`
`Research patent portfolio has been cited by over 800 U.S. and international patents and patent
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`applications assigned to a wide variety of the largest companies operating in the wireless integrated
`
`circuit field. MIMO Research’s patents have been cited by companies such as:
`
`• Apple Inc.1
`• Broadcom Inc.2
`• STMicroelectronics N.V. 3
`• Sony Group Corporation4
`• Nokia Corporation5
`• Qualcomm, Inc.6
`• Siemens AG7
`• Fujitsu Limited8
`
`3.
`
`Samsung has cited the MIMO Research patents in 22 patents and patent
`
`applications, including: U.S. Patent Nos. 7,305,250; 7,392,012; 7,929,995; 7,969,859; 8,478,271;
`
`8,611,465; 9,002,304; 9,306,616; and 7,483,406, and U.S. Patent Application Nos. 2004/0259594;
`
`2005/0170802; 2005/0195883; 2005/0243756; 2006/0209755; 2007/0140319; 2007/0195860;
`
`2008/0076433; 2008/0189119; 2009/0175381; 2012/0243645; 2014/0065992; and 20150180532.
`
`4.
`
`Defendant Samsung Electronics America, Inc. is a corporation organized under the
`
`laws of the State of New York with its principal place of business at 85 Challenger Road,
`
`Ridgefield Park, New Jersey 07660. Samsung Electronics America, Inc. may be served by serving
`
`
`1 See, e.g., U.S. Patent Nos. 7,548,577; 8,279,913; 8,705,641; 8,743,852; 8,958,760; 9,490,864;
`and 9,614,578.
`2 See, e.g., U.S. Patent Nos. 7,885,323; 8,520,715; 7,680,083; 7,725,096; 7,795,973; 7,808,985;
`7,860,146; 7,873,324; 7,877,078; 7,899,436; 7,956,689; 8,160,127; 8,213,895; 8,406,239;
`8,437,387; 8,509,707; 8,750,362; 8,750,392; 8,885,814; 9,042,436; 9,065,465; 9,313,828; and
`9,936,439.
`3 See, e.g., U.S. Patent Nos. 7,660,342; 7,656,932; 7,660,341; 7,817,763; and 8,817,935.
`4 See, e.g., U.S. Patent Nos. 9,265,004; 7,542,728; 7,545,787; 7,567,820; 7,688,784; 7,822,436;
`7,881,252; 8,045,447; 8,121,144; 8,160,001; 8,259,823; 8,462,746; 9,036,569; 9,237,572;
`9,258,833; 8,660,196; and 9,276,649.
`5 See, e.g., U.S. Patent Nos. 7,499,674; 7,643,811; 7,697,893; 7,782,894; and 9,913,248.
`6 See, e.g., U.S. Patent Nos. 8,767,812; 9,300,491; 7,916,081; 8,009,775; 8,054,223; 8,401,503;
`8,452,294; 8,467,331; 8,472,551; 8,743,903; 8,745,137; 8,745,695; 8,774,334; and 8,824,477.
`7 See, e.g., U.S. Patent Nos. 7,378,980; 7,382,271; 7,408,839; 8,155,664; and 10,051465.
`8 See, e.g., U.S. Patent Nos. 7,702,022; 7,995,680; 8,761,275; and 8,938,017.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 3 of 57 PageID #: 3
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`its registered agent CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-
`
`3136.
`
`5.
`
`Samsung Electronics America, Inc. is a wholly-owned subsidiary of Samsung
`
`Electronics Co. Ltd. Samsung Electronics America, Inc. and Samsung Electronics Co. Ltd. are
`
`collectively referred to herein as “Samsung.”
`
`6.
`
`Defendant Samsung Electronics Co. Ltd. is a corporation organized under the laws
`
`of Korea, with its principal place of business located at 129, Samsung-ro, Yeongtong-gu, Suwon-
`
`si, Gyeonngi-do 443-742, Republic of Korea.
`
`7.
`
`Samsung conducts business operations within the Eastern District of Texas in its
`
`facilities and stores located at: 776 Henrietta Creek Rd 55 Roanoke, Texas 76262-6398; 6625
`
`Excellence Way, Plano, Texas 75023; and 2601 Preston Road, Frisco, Texas 75034.
`
`JURISDICTION AND VENUE
`
`8.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. Accordingly, this Court has exclusive subject matter jurisdiction over this action
`
`under 28 U.S.C. §§ 1331 and 1338(a).
`
`9.
`
`This Court has personal jurisdiction over Samsung in this action because Samsung
`
`has committed acts within the Eastern District of Texas giving rise to this action and has
`
`established minimum contacts with this forum such that the exercise of jurisdiction over Samsung
`
`would not offend traditional notions of fair play and substantial justice. Defendant Samsung,
`
`directly and/or through subsidiaries or intermediaries (including distributors, retailers, and others),
`
`has committed and continues to commit acts of infringement in this District by, among other
`
`things, offering to sell and selling products and/or services that infringe the patents-in-suit.
`
`Moreover, Samsung is registered to do business in the State of Texas, has offices and facilities in
`
`the State of Texas, and actively directs its activities to customers located in the State of Texas.
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`10.
`
`Venue is proper in this district under 28 U.S.C. §§ 1391(b)-(d) and 1400(b).
`
`Defendant Samsung is registered to do business in the State of Texas, has offices in the State of
`
`Texas, has transacted business in the Eastern District of Texas and has committed acts of direct
`
`and indirect infringement in the Eastern District of Texas.
`
`11.
`
`Samsung has a regular and established place of business in this District and has
`
`committed acts of infringement in this District. Samsung has permanent office locations at: 776
`
`Henrietta Creek Rd 55, Roanoke, Texas 76262-6398; 6625 Excellence Way, Plano, Texas 75023;
`
`and 2601 Preston Road, Frisco, Texas 75034.
`
`12.
`
`Samsung employs full-time personnel such as sales personnel and engineers in this
`
`District
`
`13.
`
` Samsung has also committed acts of
`
`infringement
`
`in
`
`this District by
`
`commercializing, marketing, selling, distributing, testing, and servicing certain Accused Products.
`
`14.
`
`This Court has personal jurisdiction over Samsung. Samsung has conducted and
`
`does conduct business within the State of Texas. Samsung, directly or through subsidiaries or
`
`intermediaries (including distributors, retailers, and others), ships, distributes, makes, uses, offers
`
`for sale, sells, imports, and/or advertises (including by providing an interactive web page) its
`
`products and/or services in the United States and the Eastern District of Texas and/or contributes
`
`to and actively induces its customers to ship, distribute, make, use, offer for sale, sell, import,
`
`and/or advertise (including the provision of an interactive web page) infringing products and/or
`
`services in the United States and the Eastern District of Texas. Samsung, directly and through
`
`subsidiaries or intermediaries (including distributors, retailers, and others), has purposefully and
`
`voluntarily placed one or more of its infringing products and/or services, as described below, into
`
`the stream of commerce with the expectation that those products will be purchased and used by
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`customers and/or consumers in the Eastern District of Texas. These infringing products and/or
`
`services have been and continue to be made, used, sold, offered for sale, purchased, and/or
`
`imported by customers and/or consumers in the Eastern District of Texas. Samsung has committed
`
`acts of patent infringement within the Eastern District of Texas. Samsung interacts with customers
`
`in Texas, including through visits to customer sites in Texas. Through these interactions and visits,
`
`Samsung directly infringes the patents-in-suit. Samsung also interacts with customers who sell
`
`the Accused Products into Texas, knowing that these customers will sell the Accused Products into
`
`Texas, either directly or through intermediaries.
`
`15.
`
`Samsung has minimum contacts with this District such that the maintenance of this
`
`action within this District would not offend traditional notions of fair play and substantial justice.
`
`Thus, the Court therefore has both general and specific personal jurisdiction over Samsung.
`
`THE ASSERTED PATENTS
`
`U.S. PATENT NO. 7,091,854
`
`16.
`
`U.S. Patent No. 7,091,854 (the “‘854 patent”) entitled, Multiple-Input Multiple-
`
`Output Wireless Sensor Networks Communications, was filed on April 9, 2004. The ‘854 patent
`
`is subject to a 35 U.S.C. § 154(b) term extension of 187 days. MIMO Research, LLC is the owner
`
`by assignment of the ‘854 patent. A true and correct copy of the ‘854 patent is attached hereto as
`
`Exhibit A.
`
`17.
`
`The ‘854 patent claims specific systems for wireless multiple-input multiple-output
`
`communication devices.
`
`18.
`
`The ‘854 patent teaches the use of a MIMO sensor transmitter that improves array
`
`gain, diversity, and reduces channel interference and inter-symbol interference.
`
`
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`19.
`
`The ‘854 patent teaches the use of a sensor array unit coupled to an analog-to-digital
`
`converter which is coupled to a signal processing and data computing unit. The signal processing
`
`and data computing unit are coupled to a MIMO transceiver containing multiple antennas. This
`
`system improves average signal power, mitigates fading, and reduces channel interference and
`
`intersymbol interference. The reduction in channel and intersymbol interference allows the
`
`systems claimed in the ‘854 patent to significantly improve the capacity, coverage, and quality of
`
`wireless communication.
`
`20.
`
`The inventions taught in the ‘854 patent boost the data rate not only on uplink
`
`channels but also on downlink channels, which allows for better communication and control
`
`between wireless devices.
`
`21.
`
`The ‘854 patent teaches the use of a MIMO transceiver to overcome multipath
`
`propagation. Multipath propagation arises from scattering, reflection, refraction or diffraction of
`
`the radiated energy off objects in the environment. Thus, received signals are much weaker than
`
`transmitted signals due to mean propagation loss. In addition to a mean path loss, the received
`
`signals exhibit fluctuations in a signal level that is referred to fading.
`
`22.
`
`The ‘854 patent is directed to overcoming problems attendant to multipath
`
`propagation which occurs through the reflection, diffraction, and scattering of a wireless signal.
`
`“The multipath propagation arises from scattering, reflection, refraction or diffraction of the
`
`radiated energy off objects in the environment.” ‘854 patent, col. 2:43-45. The inventor of the
`
`‘854 patent illustrated the problem of multipath propagation in a subsequent textbook on signal
`
`processing.
`
`
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`George J. Maio, SIGNAL PROCESSING IN DIGITAL COMMUNICATIONS at 149 (2006).
`
`23.
`
`The ‘854 patent teaches the use of a MIMO transceiver which turns multipath
`
`propagation into a benefit. By combining the use of the transmitter antennas at one end and
`
`receiver antennas, the systems taught in the ‘854 patent enhance wireless transmission over the
`
`MIMO channel.
`
`24.
`
`The inventor of ‘854 patent described the problem of multipath propagation in a
`
`2006 textbook on signal processing:
`
`Wireless channels experience multipath propagation due to reflection, diffraction,
`and/or scattering of radiated energy off of objects located in the environment.
`Signals at the receiver are much feebler than transmitted signals because of
`propagation path loss. In addition, received signals may display fading over
`traveling distance from the transmitter. The fading includes large-scale fading and
`small-scale fading.
`George J. Maio, SIGNAL PROCESSING IN DIGITAL COMMUNICATIONS at 184-85 (2006).
`
`25.
`
`The ‘854 patent has been cited by 61 United States and international patents and
`
`patent applications as relevant prior art. Specifically, patents issued to the following companies
`
`and research institutions have cited the ‘854 patent as relevant prior art:
`
`• Qualcomm, Inc.
`
`
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`• NEC Corporation
`• Samsung Electronics Co., Ltd.
`• Allied Telesis Holdings K.k.
`• University Of Virginia
`• Texas Instruments Incorporated
`• Honeywell International Inc.
`• Shanghai Jiaotong University
`• Zebra Technologies Corp.
`• The Boeing Company
`• Chinese Academy of Sciences
`Itron, Inc.
`•
`• HBX Control Systems, Inc.
`
`U.S. PATENT NO. 7,046,716
`
`26.
`
`U.S. Patent No. 7,046,716 (the “’716 patent”) entitled, Dual-Mode Ultra Wideband
`
`and Wireless Local Area Network Communications, was filed on July 14, 2003. The ‘716 patent
`
`is subject to a 35 U.S.C. § 154(b) term extension of 342 days. MIMO Research, LLC is the owner
`
`by assignment of the ‘716 patent. A true and correct copy of the ‘716 patent is attached hereto as
`
`Exhibit B.
`
`27.
`
`The ‘716 patent discloses the use of a dual-mode UWB and wireless local area
`
`network transceiver.
`
`28.
`
`The ‘716 patent is directed to enabling network devices operating using wireless
`
`spectrum occupied by existing radio services without causing interference, thereby permitting
`
`scare spectrum resources to be used more efficiently.
`
`29.
`
`The ‘716 patent discloses novel systems for allowing the coexistence of a UWB
`
`and WLAN transceiver in an environment.
`
`30.
`
`The inventions disclosed in the ‘716 patent enable the use of communications
`
`device that operates using a transceiver that operates using more than one wireless networking
`
`standards and enables the same communication device to operate in areas in which there is a need
`
`for short-range wireless broadband communications using UWB.
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`31.
`
`The communication transceiver disclosed in the ‘716 patent can be implemented in
`
`hardware such as an in an Application Specific Integrated Circuits (ASIC), digital signal processor,
`
`field programmable gate array (FPGA), software, or a combination of hardware and software.
`
`32.
`
`The ‘716 patent has been cited by 93 patents and patent applications as relevant
`
`prior art. Specifically, patents issued to the following companies have cited the ‘716 patent as
`
`relevant prior art:
`
`• Samsung Electronics Co., Ltd.
`• Qualcomm, Inc.
`• Huawei Investment & Holding Co., Ltd.
`• Nokia Corporation
`• NXP B.V.
`Intel Corporation
`•
`• Microchip Technology Inc.
`• Corning Incorporated
`• L3Harris Technologies Inc.
`• Siemens AG
`• Kawasaki Microelectronics, Inc.
`
`U.S. PATENT NO. 7,133,646
`
`33.
`
`U.S. Patent No. 7,133,646 (the “’646 patent”) entitled, Multimode and Multiband
`
`MIMO Transceiver of W-CDMA, WLAN and UWB Communications, was filed on December 29,
`
`2003. The ‘646 patent is subject to a 35 U.S.C. § 154(b) term extension of 456 days. MIMO
`
`Research, LLC is the owner by assignment of the ‘646 patent. A true and correct copy of the ‘646
`
`patent is attached hereto as Exhibit C.
`
`34.
`
`The ‘646 patent discloses novel methods and systems for implementing a
`
`processor-based system to receive W-CDMA, WLAN, and UWB signals.
`
`35.
`
`The inventions disclosed in the ‘646 patent enable large-scale computer networks
`
`to quickly recover from a component failure.
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`36.
`
`The ‘646 patent discloses a method implemented on a transceiver system for
`
`multimode receipt of W-CDMA, WLAN, and UWB signals.
`
`37.
`
`The ‘646 patent has been cited by 108 patents and patent applications as relevant
`
`prior art. Specifically, patents issued to the following companies have cited the ‘646 patent as
`
`relevant prior art:
`
`• Sharp Corporation
`• Apple Inc.
`• Sony Group Corporation
`International Business Machines Corp.
`•
`• Qualcomm, Inc.
`• Huawei Investment & Holding Co., Ltd.
`• NXP B.V.
`• Koninklijke Philips Electronics, N.V.
`• Broadcom Limited
`Intel Corporation
`•
`• Fujitsu Limited
`• Electronics And Telecommunications Research Institute
`Infineon Technologies AG
`•
`
`U.S. PATENT NO. 7,305,057
`
`38.
`
`U.S. Patent No. 7,305,057 entitled, Multichannel Filter-Based Handheld Ultra
`
`Wideband Communications, was filed on July 7, 2003. The ‘057 patent is subject to a 35 U.S.C.
`
`§ 154(b) term extension of 922 days. MIMO Research, LLC is the owner by assignment of the
`
`’057 patent. A true and correct copy of the ‘057 patent is attached hereto as Exhibit D.
`
`39.
`
`The ‘057 patent discloses novel systems for multichannel filter-based UWB
`
`transceivers that avoid interference with WLAN 802.11a devices.
`
`40.
`
`The inventions disclosed in the ‘057 patent teach systems that permit a UWB device
`
`to operate using spectrum occupied by existing radio services without causing interference, thereby
`
`permitting scarce spectrum resources to be used more efficiently.
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`41.
`
`The ‘057 patent improves the operation of wireless networks by disclosing
`
`technologies that enable new products incorporating UWB technology.
`
`42.
`
`The ‘057 patent discloses the use of a multichannel filter for a UWB transceiver.
`
`The multichannel filter allows the UWB transceiver to operate in the frequency band from 3.1
`
`GHz to 10.6 GHz, with a conservative out of band emission mask to address interference with
`
`other devices.
`
`43.
`
`The ‘057 patent has been cited by 16 patents and patent applications as relevant
`
`prior art. Specifically, patents issued to the following companies and research institutions have
`
`cited the ‘057 patent as relevant prior art:
`
`• University Of Minnesota
`• Sorbonne Université
`• Qualcomm, Inc.
`• Nokia Corporation
`• Huawei Technologies Co., Ltd.
`Industrial Technology Research Institute
`•
`• Graz University of Technology (Austria)
`
`
`
`U.S. PATENT NO. 7,433,382
`
`44.
`
`U.S. Patent No. 7,433,382 entitled, Spread Spectrum Based Multichannel
`
`Modulation for Ultra Wideband Communications, was filed on July 7, 2003. The ‘382 patent is
`
`subject to a 35 U.S.C. § 154(b) term extension of 704 days. MIMO Research, LLC is the owner
`
`by assignment of the ’382 patent. A true and correct copy of the ‘382 patent is attached hereto as
`
`Exhibit E.
`
`45.
`
`The ‘382 patent discloses novel UWB devices that enable the transmission of data
`
`while avoiding interference with WLAN 802.11a devices.
`
`46.
`
`The inventions disclosed in the ‘382 patent are directed to solving the problem of
`
`interference between UWB devices and other devices, such as WLAN 802.11a devices.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Interference between UWB and 802.11a transmission was a problem at the time the inventions
`
`disclosed in the ‘382 patent were invented because the WLAN 802.11a devices operated in the
`
`frequency ranges 5.15 GHz to 5.35 GHz and 5.725 GHz to 5.825 GHz which overlapped with
`
`UWB signals that could operate in the frequency band of 3.1 GHz to 10.6 GHz.
`
`47.
`
` The inventions disclosed in the ‘382 patent teach technologies that permit the
`
`transmission of data using UWB without interfering with the transmission of data using non-UWB
`
`signals that overlap with the UWB frequency band.
`
`48.
`
`To address the issue of interference between devices operating in the UWB
`
`frequency band and non-UWB signals sent in an overlapping frequency band, the ‘382 patent
`
`teaches the use of multichannel pseudorandom noise mapping comprising N-I delay units coupled
`
`to N down sampling units followed by N Exclusive OR (XOR) units in parallel.
`
`49.
`
`The ‘382 patent discloses systems that improve the operation of wireless networks
`
`by disclosing technologies that reduce interference with WLAN signals using a multichannel
`
`pseudorandom noise look-up table coupled to a multichannel sequence mapping component.
`
`50.
`
`The ‘382 patent discloses the use of a digital finite impulse response shaping filter
`
`that attenuates signals with frequencies higher then specific thresholds. By using the disclosed
`
`filter, the systems taught in the ‘382 patent reduce interference with non-UWB signal.
`
`51.
`
`The ‘382 patent has been cited by 10 patents and patent applications as relevant
`
`prior art. Specifically, patents issued to the following companies and research institutions have
`
`cited the ‘382 patent as relevant prior art:
`
`• STMicroelectronics N.V.
`Industrial Technology Research Institute
`•
`• Huawei Technologies Co., Ltd.
`• East China Normal University
`• Beifang Tongyong Electronics Group Co., Ltd.
`• Universite De Provence
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`
`
`COUNT I
`INFRINGEMENT OF U.S. PATENT NO. 7,091,854
`
`52.
`
`Plaintiff references and incorporates by reference the preceding paragraphs of this
`
`Complaint as if fully set forth herein.
`
`53.
`
`Samsung designs, makes, uses, sells, and/or offers for sale in the United States
`
`products comprising a MIMO wireless sensor and transceiver system.
`
`54.
`
`Samsung designs, makes, sells, offers to sell, imports, and/or uses the following
`
`products: Galaxy Z Fold2 (SM-F916B, SM-F916JPN, SM-F916U), Galaxy Z Fold3 (SM-F926B,
`
`SM-F926JPN, SM-F926U), Galaxy S21+ (SM-G996B, SM-G996B/DS, SM-G996U, SM-
`
`G996U1), Galaxy S21 Ultra (SM-G998B, SM-G998B/DS, SM-G998U, SM-G998U1), Galaxy
`
`S22+ (SM-S906B, SM-S906B/DS, SM-S906U, SM-S906U1), and Galaxy S22 Ultra (SM-S908B,
`
`SM-S908B/DS, SM-S908U, SM-S908U1) (collectively, the “Samsung ‘854 Product(s)”).
`
`55.
`
`One or more Samsung subsidiaries and/or affiliates use the Samsung ‘854 Products
`
`in regular business operations.
`
`56.
`
`One or more of the Samsung ‘854 Products include technology for a wireless
`
`multiple-input multiple-output sensor node and transceiver system. The below excerpt from a
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`schematic of the Samsung S21 Ultra device shows one example of a MIMO sensor node connected
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`to a transceiver system.
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`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 13 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 14 of 57 PageID #: 14
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`SAMSUNG SM-G998B RF BLOCK DIAGRAM (November 12, 2020) (annotation added).
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`57.
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`One or more of the Samsung ‘854 Products include diversity modules including the
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`Qualcomm QDM5872 FEM. The QDM5872 in the Samsung ‘854 Products features an integrated
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`5G/4G low-noise amplifier and filters for receive diversity and MIMO support for sub-6 GHz
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`bands.
`
`IFIXIT WEBSITE (2021), available at:
`iFixIt Samsung Galaxy S21 Ultra Teardown,
`https://www.ifixit.com/Teardown/Samsung+Galaxy+S21+Ultra+Teardown/141188
`(annotation
`added).
`
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 14 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 15 of 57 PageID #: 15
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`58.
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`One or more of the Samsung ‘854 Products include a sensor array unit coupled to
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`an analog-to-digital converter unit. Specifically, the Samsung ‘854 Products include a sensor array
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`unit (e.g., 4x4 MIMO for receiving four simultaneous data streams). The sensor array unit is
`
`connected to analog-to-digital (ADC) structures in the device. The below excerpt from Samsung
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`documentation shows ADC structures that are coupled to the sensor array unit.
`
`
`
`SAMSUNG SM-G998B RF BLOCK DIAGRAM (November 12, 2020) (annotation added).
`
`59.
`
`One or more of the Samsung ‘854 Products comprise technology for an analog-to-
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`digital converter unit coupled to a signal processing and data computing unit. For example, the
`
`Samsung Products contain integrated circuits that perform signal processing and data computing.
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`These integrated circuits are connected to the transmission systems of the Samsung ‘854 Products
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`that comprise technology to convert signals from analog to digital signals.
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`60.
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`The Samsung ‘854 Products contain an analog-to-digital (ADC) converter unit
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`coupled to a signal processing and data computing unit. Specifically, the Samsung ‘854 Products
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 15 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 16 of 57 PageID #: 16
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`contain a signal processing and data computing unit. For example, Samsung S21 Ultra contains a
`
`SM8350 application/baseband processor.
`
`IFIXIT WEBSITE (2021), available at:
`iFixIt Samsung Galaxy S21 Ultra Teardown,
`https://www.ifixit.com/Teardown/Samsung+Galaxy+S21+Ultra+Teardown/141188
`(annotation
`added).
`
`
`One or more of the Samsung ‘854 Products include a signal processing and data
`
`61.
`
`computing unit that is coupled to a multiple-input multiple-output space-time transceiver that is
`
`connected to two or more antennas. The below diagram shows one example of the infringing
`
`functionality wherein antennas are coupled to the signal processing and data computing unit.
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`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 16 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 17 of 57 PageID #: 17
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`SAMSUNG SM-G998U LOGIC BLOCK DIAGRAM REV.0.4 (November 26, 2020) (annotation added).
`
`62.
`
`One or more of the Samsung ‘854 Products include a signal processing and data
`
`computing unit that is coupled to a multiple-input multiple-output space-time transceiver that is
`
`connected to two or more antennas.
`
`63.
`
`One or more of the Samsung ‘854 Products include memory that is coupled to the
`
`analog-to-digital converter unit, the signal processing and data computing unit, and the multiple-
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`input multiple-output space-time transceiver.
`
`64.
`
`One or more of the Samsung ‘854 Products include a power generator coupled to a
`
`power unit. The power unit and power generator include devices made by Diodes Incorporated
`
`and NXP Semiconductor. Specifically, Samsung documentation for the infringing products shows
`
`a power regulator connected to the power unit (supply voltages).
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 17 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 18 of 57 PageID #: 18
`
`iFixIt Samsung Galaxy S22 Ultra Teardown,
`IFIXIT WEBSITE (2022), available at:
`https://www.ifixit.com/Guide/Samsung+Galaxy+S22+Ultra+Chip+ID/148073
`(annotation
`added).
`
`65.
`
`One or more of the Samsung ‘854 Products include a power unit that is connected
`
`to the sensor array unit, the analog-to-digital converter unit, the signal processing and data
`
`computing unit, and the multiple-input multiple-output space-time transceiver.
`
`66.
`
`Samsung has directly infringed and continues to directly infringe the ‘854 patent
`
`by, among other things, making, using, offering for sale, and/or selling technology for MIMO
`
`wireless sensor networks, including but not limited to the Samsung ‘854 Products.
`
`67.
`
`The Samsung ‘854 Products are available to businesses and individuals throughout
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`the United States.
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`68.
`
`The Samsung ‘854 Products are provided to businesses and individuals located in
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`the Eastern District of Texas.
`
`69.
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`By making, using, testing, offering for sale, and/or selling products and services
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`that comprise a MIMO wireless sensor, including but not limited to the Samsung ‘854 Products,
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`Samsung has injured Plaintiff and is liable to Plaintiff for directly infringing one or more claims
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`of the ‘854 patent, including at least claim 15 pursuant to 35 U.S.C. § 271(a).
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 18 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 19 of 57 PageID #: 19
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`70.
`
`Samsung also indirectly infringes the ‘854 patent by actively inducing infringement
`
`under 35 U.S.C. § 271(b).
`
`71.
`
`Samsung has had knowledge of the ‘854 patent since at least service of this
`
`Complaint or shortly thereafter, and Samsung knew of the ‘854 patent and knew of its
`
`infringement, including by way of this lawsuit.
`
`72.
`
`Alternatively, Samsung has had knowledge of the ‘854 patent since at least
`
`September 5, 2007, when the ‘854 patent was identified by the Patent and Trademark Office as
`
`relevant prior art during the prosecution of U.S. Patent Application No. 11/047,766. U.S. Patent
`
`Application No. 1/047,766 is assigned to Samsung and would issue as U.S. Patent No. 7,392,012
`
`on June 24, 2008. Further, U.S. Patent No. 7,392,012 is assigned to Samsung and cites the ‘854
`
`patent as relevant prior art.
`
`US. PATENT APPLICATION NO. 11/047,766 LIST OF REFERENCES CITED BY EXAMINER at 1
`(September 5, 2007) (emphasis added).
`
`73.
`
`Samsung intended to induce patent infringement by third-party customers and users
`
`of the Samsung ‘854 Products and had knowledge that the inducing acts would cause infringement
`
`or was willfully blind to the possibility that its inducing acts would cause infringement. Samsung
`
`specifically intended and was aware that the normal and customary use of the accused products
`
`would infringe the ‘854 patent. Samsung performed the acts that constitute induced infringement,
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`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Page 19 of 57
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`Case 5:22-cv-00073 Document 1 Filed 06/10/22 Page 20 of 57 PageID #: 20
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`and would induce actual infringement, with knowledge of the ‘854 patent and with the knowledge
`
`that the induced acts would constitute infringement. For example, Samsung provides the Samsung
`
`‘854 Products that have the capability of operating in a manner that infringe one or more of the
`
`claims of the ‘854 patent, including at least claim 15, and Samsung further provides documentation
`
`and training materials that cause customers and end users of the Samsung ‘854 Products to utilize
`
`the products in a manner that directly infringe one or more claims of the ‘854 patent.9 By providing
`
`instruction and training to customers and end-users on how to use the Samsung ‘854 Products in a
`
`manner that directly infringes one or more claims of the ‘854 patent, including at least claim 15,
`
`Samsung specifically intended to induce infringement of the ‘854 patent. Samsung engaged in
`
`such inducement to promote the sales of the Samsung ‘854 Products, e.g., through Samsung user
`
`manuals, product support, marketing materials, and training materials to actively induce the users
`
`of the accused products to infringe the ‘854 patent. Accordingly, Samsung has induced and
`
`continues to induce users of the accused products to use the accused products in their ordinary and
`
`customary way to infringe the ‘854 patent, knowing that such use constitutes infringement of the
`
`‘854 patent.
`
`74.
`
`The ‘854 patent is well-known within the industry as demonstrated by multiple
`
`citations to the ‘854 patent in published patents and patent applications assigned to technology
`
`
`9 See, e.g., Samsung Galaxy S21 5G | S21+5g | S21 Ultra 5G Datasheet, SAMSUNG
`DOCUMENTATION (2021); Unfold A World Of Possibilities – Samsung Galaxy Z Fold3 5G
`Datasheet, SAMSUNG DOCUMENTAT