Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 1 of 12
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Lynk Labs, Inc.,
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`Plaintiff,
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`
`
` v.
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`Samsung Electronics Co., Ltd. and Samsung
`Electronics America, Inc.
`
` Defendants.
`
`Case No.
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`6:21-cv-00526
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`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
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`

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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 2 of 12
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`Plaintiff, Lynk Labs, Inc. (“Lynk”), files this complaint for patent infringement against
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`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (together, “Samsung”) and
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`in support thereof alleges and avers as follows:
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`NATURE OF THE ACTION
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`1.
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`This is a civil action arising under the patent laws of the United States, 35 U.S.C. §
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`1 et seq., specifically including 35 U.S.C. § 271, based on Samsung’s infringement of U.S. Patent
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`No. 11,019,697 (the “’697 Patent”). The ’697 Patent is attached hereto as Exhibit A.
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`THE PARTIES
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`2.
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`Lynk is a corporation incorporated in the State of Illinois with its principal place of
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`business at 2511 Technology Drive, Suite 108, Elgin, Illinois 60124. Before then, Lynk’s principal
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`place of business was 585 Tollgate Road, Suite E, Elgin, Illinois 60017.
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`3.
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`Upon information and belief, Defendant Samsung Electronics Co., Ltd. (“Samsung
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`Korea”) is a corporation organized under the laws of South Korea, with its principal place of
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`business at 129 Samsung-Ro, Maetan-3dong, Yeongtong-gu, Suwon-si, Gyeonggi-do, 443-742,
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`South Korea.
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`4.
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`Upon information and belief, Defendant Samsung Electronics America, Inc.
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`(“Samsung America”) is a wholly-owned subsidiary of Samsung Electronics Co., Ltd. and a
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`corporation organized under the laws of the State of New York, with its principal place of business
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`at 85 Challenger Rd., Ridgefield Park, New Jersey 07660.
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`5.
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`Defendants Samsung Korea and Samsung America are each individually liable and
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`are jointly and severally liable for infringement of the ’697 Patent. Under theories of alter ego,
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`single business enterprise liability, and agency, the conduct of each can be attributed to and
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`considered the conduct of others for purposes of infringement of the ’697 Patent. SEC and SEA
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`have in the past and continue to hold themselves out in the United States as a single entity—
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 3 of 12
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`“Samsung”—acting in concert, with knowledge of each other’s actions and control over each
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`other.
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`JURISDICTION AND VENUE
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`6.
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`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a) because the claims arise under the patent laws of the United States, 35 U.S.C. § 1 et seq.,
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`including 35 U.S.C. § 271.
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`7.
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`This Court has personal jurisdiction over Samsung in this action because its
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`contacts with the Western District of Texas are significant and pervasive. Samsung has committed
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`acts within the Western District of Texas giving rise to this action and Samsung has established
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`minimum contacts with this forum such that the exercise of jurisdiction over Samsung would not
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`offend traditional notions of fair play and substantial justice.
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`8.
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`Upon information and belief, Samsung has committed and continues to commit acts
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`of infringement in this District by, among other things, (i) availing itself of the rights and benefits
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`of the laws of the State of Texas, (ii) transacting, conducting, and/or soliciting business and
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`engaged in a persistent course of conduct in the State of Texas (and in this District), (iii) deriving
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`substantial revenue from the sales and/or use of products, such as the products accused in this
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`lawsuit (the “Accused Products”), in the State of Texas (and in this District), (iv) purposefully
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`directing activities (directly and/or through intermediaries), such as shipping, distributing, offering
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`for sale, selling, and/or advertising the Accused Products, at residents of the State of Texas (and
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`residents in this District), (v) delivering Accused Products into the stream of commerce with the
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`expectation that the Accused Products will be used and/or purchased by consumers in the State of
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`Texas (and in this District), and (vi) committing acts of patent infringement in the State of Texas
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`(and in this District).
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 4 of 12
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`9.
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`Specifically, Samsung has regular and established places of businesses in this
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`District, including at 12100 Samsung Boulevard, Austin, Texas 78754; 7300 Ranch Road 2222,
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`Austin, Texas 78730; and 1700 Scenic Loop, Round Rock, Texas 78681. Upon information and
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`belief, Samsung employs approximately 10,000 employees and contractors in this District serving
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`in a variety of capacities, including the manufacturing and research and development of
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`components used in the Accused Products.
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`10.
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`Upon information and belief, Samsung’s presence in the District continues to grow,
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`as Samsung recently purchased approximately 258 acres of additional land on which it plans to
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`expand its existing facilities in the District with a new $17 billion factory that is expected to bring
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`1,800 new permanent jobs to the District in the first 10 years. Samsung is seeking approximately
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`$1 billion in state and local tax incentives in connection with its planned expansion. See Exhibit
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`B, Austin American-Statesman, Samsung wants $1 billion tax incentive for new Austin plant that
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`would
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`create
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`1,800
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`jobs
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`(Feb
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`4,
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`2021),
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`available
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`at
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`https://www.statesman.com/story/business/2021/02/04/samsung-austin-expansion-chip-plant-
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`seeks-1-billion-taxpayer-incentives/4309503001/.
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`11.
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`Likewise, Samsung makes, sells, and offers for sale LED lighting and consumer
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`electronic products including, but not limited to, smartphones and tablet computers, throughout
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`the United States, including in this District.
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`12.
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`Further, Samsung America is registered to do business in the State of Texas, and
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`has appointed CT Corporation System, located at 1999 Bryan Street, Suite 900, Dallas, Texas
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`75201, as its registered agent.
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`13.
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`Venue is proper in this district under 28 U.S.C. §§ 1391 and 1400(b).
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 5 of 12
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`14.
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`For instance, venue is proper as to a foreign defendant in any district. 28 U.S.C. §
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`1391(c)(3); In re HTC Corp., 889 F.3d 1349 (Fed. Cir. 2018). Defendant Samsung Korea is a
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`foreign corporation organized under the laws of Korea, with a principal place of business in Korea.
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`15.
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`16.
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`Further, Samsung has committed acts of direct infringement in this District.
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`For example, the accused Samsung Galaxy S21 Ultra is available for sale to
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`customers in this District on the Samsung website:
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`17.
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`Upon information and belief, the other products accused of infringement in this
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`Complaint are similarly sold in this District through, inter alia, the physical and online stores of
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`authorized Samsung retailers such as Best Buy, Target, AT&T, T-Mobile, and Verizon.
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`FACTUAL BACKGROUND
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`18.
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`Lynk was founded in 1997 by Mike Miskin, who is and was President and CEO of
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`Lynk. Since its inception, Lynk has been a technology pioneer, challenging industry
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 6 of 12
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`understanding of conventional physics, beginning with technology in fields such as broadband
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`communications, wireless communications, and wireless power.
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`19.
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`In the early 2000s, after being negatively impacted by the telecom bubble, Lynk
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`needed to explore other market opportunities to reshape the company. While trying to continue to
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`innovate in telecommunications, high speed backplanes, wireless power, etc., Lynk realized it
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`could also apply and advance some of its technology in the general lighting field. At that time, the
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`development of light emitting diode (“LEDs”) for general lighting uses was still in its very early
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`stages. Over the course of the next several years, Lynk developed and patented pioneering
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`innovations that are now common place in the LED lighting and consumer electronics industry
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`including but not limited to: LED lighting systems driven by constant voltage power supplies,
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`smart LED lighting systems, warm dim or warm glow LED lighting devices, LED lighting devices
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`and/or systems allowing users to select the brightness and/or color temperature of light, direct AC
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`mains connected LED assemblies known as driver-on-board, wireless power, and many more.
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`20.
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`Lynk’s groundbreaking research, which continues to this day, has consistently cut
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`directly against conventional wisdom in the industry, resulting in inventions that are now common
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`in the industry. Many of Lynk’s patented technologies were revolutionary in the early 2000’s
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`when Lynk developed them, but they are now common in consumer electronics such as Samsung’s
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`Galaxy products including its smartphones and tablet computers.
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`21.
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`Lynk was, and still is, a small American business that supplies LED lighting
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`assemblies, modules, lamps, drivers, and system solutions.
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`22.
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`Lynk has witnessed with dismay the increasing unlicensed presence of Lynk’s
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`patented technology on the shelves and websites of retail stores, including in the products of
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`massive international companies such as Samsung.
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 7 of 12
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`THE PATENT-IN-SUIT
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`23.
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`On May 25, 2021, the ’697 Patent, entitled “AC LIGHT EMITTING DIODE AND
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`AC LED DRIVE METHODS AND APPARATUS,” was duly and legally issued by the United
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`States Patent and Trademark Office. A true and accurate copy of the ’697 Patent is attached hereto
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`as Exhibit A.
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`24.
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`The ’697 Patent
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`is emblematic of Lynk’s significant
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`investment
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`into
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`groundbreaking technology. Lynk has been on the forefront of LED technology development for
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`nearly twenty years and has over 35 issued patents to show for its efforts.
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`FIRST CAUSE OF ACTION
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`(Infringement of the ’697 Patent)
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`25.
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`Lynk incorporates by reference and realleges each and every allegation of
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`Paragraphs 1 through 24 as if set forth herein.
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`26.
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`Samsung imports, offers for sale, and sells certain smartphone products, which
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`directly infringe at least Claims 1, 7, and 14 of the ’697 Patent. The infringing products include
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`any and all Samsung smartphone products featuring the LED technology set forth in certain claims
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`of the ’697 Patent.
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`27.
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`For instance, as described by the exemplary photographs below, the Samsung
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`Galaxy S21 Ultra (“S21 Ultra”) is, as recited in claim 1 of the ’697 Patent, an “apparatus”
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`comprising:
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`at least one LED;
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`a semiconductor device configured to emit a laser;
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`a data receiver including an antenna, wherein the data receiver is
`configured to transmit and receive data;
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`a circuit configured to detect human touch via capacitive sensing;
`and
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 8 of 12
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`a battery ground capacitively coupled to at least one of the data
`receiver, the circuit, the at least one LED, or the semiconductor
`device via a conductor,
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`wherein the apparatus is portable, and
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`wherein the at least one LED, the semiconductor device, the data
`receiver, the circuit, and the battery ground are contained within a
`package and connected to at least one circuit board within the
`package.
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`Antennas 
`(and Data 
`Receiver) 
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`Laser Module 
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 9 of 12
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`LED Flash 
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`Package 
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`AMOLED Capacitive 
`Touchscreen 
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`28. More specifically, the S21 Ultra contains:
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`
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`a. at least one LED, including the LED flash and the LED backlights within the
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`device’s AMOLED capacitive touchscreen;
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`b. a laser autofocus module, a semiconductor device configured to emit a laser;
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`c. multiple data receivers and antennas supporting mobile data, Wi-Fi, Bluetooth, and
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`other data transmission protocols;
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`d. a capacitive touchscreen, i.e., a circuit configured to detect human touch via
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`capacitive sensing; and
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`e. upon information and belief, a battery ground capacitively coupled to at least one
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`of the data receiver, the circuit, the at least one LED, or the semiconductor device
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`via a conductor.
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`29.
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`Further, the S21 Ultra is a mobile phone, which is designed to be carried by a user
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`and therefore portable.
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`30.
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`Finally, the S21 Ultra’s various components are all contained within its external
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`housing (i.e., a package) and connected the device’s various circuit boards such that the device can
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`function.
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`31.
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`Lynk has been damaged as a result of the infringing conduct by Samsung alleged
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`above. Thus, Samsung is at least liable to Lynk in an amount that compensates it for such
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`infringement, which by law cannot be less than a reasonable royalty, together with interest and
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`costs as fixed by this Court under 35 U.S.C. § 284.
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`32.
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`Samsung’s infringement of the ’697 Patent has caused, and will continue to cause,
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`Lynk to suffer substantial and irreparable harm.
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`33.
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`Samsung will have been aware that it infringes the ’697 Patent since at least the
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`issuance of the ’697 Patent and the filing of this Complaint on May 25, 2021. Therefore, any
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`infringement of the ’697 Patent by Samsung occurring after May 25, 2021 is willful.
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`34.
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`Lynk has complied with the marking requirements of 35 U.S.C. § 287 with respect
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`to the ’697 Patent.
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`WHEREFORE, Lynk requests that:
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`PRAYER FOR RELIEF
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`A.
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`The Court find that Samsung has directly infringed the ’697 Patent and hold
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`Samsung liable for such infringement;
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`B.
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`The Court award damages pursuant to 35 U.S.C. § 284 adequate to compensate
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`Lynk for Samsung’s past infringement of the ’697 Patent, including both pre- and post-judgment
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`interest and costs as fixed by the Court;
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`C.
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`The Court increase the damages to be awarded to Lynk by three times the amount
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`found by the jury or assessed by the Court for infringement occurring after May 25, 2021;
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 11 of 12
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`D.
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`The Court declare that this is an exceptional case entitling Lynk to its reasonable
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`attorneys’ fees under 35 U.S.C. § 285;
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`E.
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`The Court grant injunctive relief permanently enjoining Samsung from further
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`infringement of the ’697 Patent; and
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`F.
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`The Court award such other relief as the Court may deem just and proper.
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`JURY DEMAND
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`Plaintiff Lynk Labs, Inc. hereby demands a trial by jury on every issue on which it is so
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`entitled.
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`Case 6:21-cv-00526 Document 1 Filed 05/25/21 Page 12 of 12
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`Dated: May 25, 2021
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`
`By:
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` Respectfully submitted,
`
` /s/ Darlene F. Ghavimi
`Darlene F. Ghavimi
`TX Bar No. 24072114
`K&L GATES LLP
`2801 Via Fortuna, Suite 350
`Austin, Texas 78746
`Telephone: (512) 482-6800
`darlene.ghavimi@klgates.com
`
`Jim A. Shimota (pro hac vice forthcoming)
`Nelson M. Hua (pro hac vice forthcoming)
`K&L GATES LLP
`70 West Madison Street, Suite 3300
`Chicago, Illinois 60602
`Telephone: (312) 372-1121
`Fax: (312) 827-8000
`jim.shimota@klgates.com
`nelson.hua@klgates.com
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`Attorneys for Plaintiff Lynk Labs, Inc.
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