Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 1 of 8 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Civil Action No.: 2:15-cv-948
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`
`
`Judge:
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`Jury Trial Demanded
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`Defendants.
`
`
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`
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`KONINKLIJKE KPN N.V.
`
`Plaintiffs,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., &
`SAMSUNG TELECOMMUNICATIONS
`AMERICA LLP
`
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff, Koninklijke KPN N.V. (hereafter “KPN”), files this Complaint against Samsung
`
`Electronics Co., Ltd., Samsung Electronics America, Inc., and , and Samsung Telecommunications
`
`America LLP (collectively, “Defendants” or “Samsung”), and alleges as follows:
`
`BACKGROUND
`
`1.
`
`KPN’s extensive research and development efforts have led to hundreds of issued
`
`patents in the United States and across the world. These patents have in turn been licensed by
`
`leading global telecommunications companies, including many of Samsung’s mobile technology
`
`competitors.
`
`2.
`
`Despite more than two years of negotiations involving senior members of both
`
`companies, Samsung has refused to license, on mutually agreeable terms, KPN’s patents, including
`
`the one described herein. KPN therefore files this suit against Samsung seeking the Court’s
`
`protection of KPN’s valuable intellectual property rights.
`
`3734765v1/014360
`
`Samsung, Exh. 1010, p. 1
`
`

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`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 2 of 8 PageID #: 2
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`
`
`
`
`PARTIES
`
`3.
`
`KPN is a telecommunications (including fixed, mobile, television and internet) and
`
`ICT solution provider headquartered at Maanplein 55, NL-2516 CK, The Hague, the Netherlands.
`
`4.
`
`Samsung Electronics Co., Ltd. (“SEC”), is upon information and belief a Korean
`
`corporation with its principal place of business at 416, Maetan 3-dong, Yeongtong-gu, Suwon-si,
`
`Gyeonggi-do 443-742, South Korea. SEC can be served with process by serving in accordance with
`
`the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents, in
`
`accordance with Fed. R. Civ. P. 4(f).
`
`5.
`
`Samsung Electronics America, Inc. (“SEA”), is upon information and belief a New
`
`York corporation with its principal place of business at 85 Challenger Road, Ridgefield Park, New
`
`Jersey 07660.
`
`6.
`
`Samsung Telecommunications American LLP (“STA”), was upon information and
`
`belief a Delaware limited liability company with its principal place of business at 1301 East Lookout
`
`Drive, Richardson, Texas 75082, and which could be served with process by serving Corporation
`
`Service Company DBA CSC – Lawyers Incorporating Service Company, 211 E. 7th Street, Suite
`
`620, Austin, Texas 78701-3218. Counsel for Samsung has represented that, effective January 1,
`
`2015, STA merged with SEA. KPN thus makes its allegations in this case pursuant to the
`
`representations and warranties set forth in the Stipulation entered as Dkt. 39 in KPN v. Samsung et
`
`al., Case No. 2:14-cv-01165-JRG (Dkt. 34).
`
`7.
`
` STA, SEC, and SEA are referred to herein as “Samsung.”
`
`JURISDICTION AND VENUE
`
`
`
`2
`
`Samsung, Exh. 1010, p. 2
`
`

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`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 3 of 8 PageID #: 3
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`
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`8.
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`This is a civil action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction over this case under
`
`28 U.S.C. §§ 1331 and 1338(a).
`
`9.
`
`Venue is proper in this federal district pursuant to 28 U.S.C. §§ 1391 and 1400(b)
`
`because Defendants have done business in this District, have committed acts of infringement in this
`
`District, and continue to commit acts of infringement in this District, entitling KPN to relief.
`
`THE ASSERTED PATENT
`
`10.
`
`This lawsuit asserts a cause of action for infringement of United States Patent No.
`
`9,014,667 (the “’667 patent”).
`
`11.
`
`On April 21, 2015, the U.S. Patent and Trademark Office duly and legally issued the
`
`‘667 patent entitled, “Telecommunications Network and Method for Time-Based Network Access.”
`
`KPN is the owner by assignment of the ‘667 patent and holds all right, title and interest to the ‘667
`
`patent. A true and correct copy of the ‘667 patent is attached as Exhibit A.
`
`12.
`
`KPN is the exclusive owner of all rights, title, and interest in the ‘667 patent,
`
`including the right to bring this suit for injunctive relief and damages, and including the right to sue
`
`for and recover all past, present and future damages for infringement of the ‘667 patent. The ‘667
`
`patent is valid and enforceable.
`
`13.
`
`Upon information and belief, Samsung has had knowledge of and notice of the ‘667
`
`patent, and of its infringement, prior to the filing of this lawsuit in connection with licensing
`
`negotiations that have taken place between the parties, and has engaged in the activities detailed
`
`below despite an objective likelihood that its actions constituted infringement of a valid patent.
`
`
`
`3
`
`Samsung, Exh. 1010, p. 3
`
`

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`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 4 of 8 PageID #: 4
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`Samsung has also received notice of the ‘667 patent and of its infringement with the filing of the
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`Complaint for Patent Infringement in this action.
`
`COUNT 1
`
`(Samsung’s Infringement of the ‘667 Patent)
`
`14.
`
`KPN repeats and re-alleges the allegations in the preceding paragraphs as if fully set
`
`forth herein.
`
`15.
`
`Samsung has infringed and continues to infringe the ‘667 Patent under 35 U.S.C.
`
`§ 271, literally or under the doctrine of equivalents, by making, using, selling, and/or offering for
`
`sale in the United States, and/or importing into the United States, infringing products without
`
`authorization by KPN.
`
`16.
`
`Samsung directly infringed and continues to directly infringe one or more claims of
`
`the ‘667 Patent by importing, offering to sell, selling, or using products or methods that infringe the
`
`‘667 Patent, including but not limited to the Samsung Galaxy S5 and related Samsung
`
`Communication Devices, products incorporating the same or similar Back-off Timer technology,
`
`and infrastructure incorporating the same or similar technology (hereafter “the ‘667 Accused
`
`Products”). Samsung has directly infringed and continues to directly infringe one or more of the
`
`claims of the ‘667 Patent by making, using, offering to sell, selling, or importing the ‘667 Accused
`
`Products.
`
`17.
`
`In addition to the foregoing and/or in the alternative, Samsung indirectly infringes the
`
`‘667 Patent by inducing and contributing to infringement by others, including but not limited to
`
`OEMs, partners, service providers, manufacturers, importers, resellers, customers, and/or end users,
`
`in accordance with 35 U.S.C. § 271(b), in this District and elsewhere in the United States. Samsung
`
`
`
`4
`
`Samsung, Exh. 1010, p. 4
`
`

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`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 5 of 8 PageID #: 5
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`is actively, knowingly, and intentionally inducing infringement of the ‘667 Patent by practicing the
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`methods set forth therein and by selling, offering to sell and/or importing into the United States the
`
`‘667 Accused Products; with the knowledge and specific intent that third parties, such as those
`
`described above, will continue to, either alone or in combination with Samsung, practice the
`
`patented methods, and use, sell, offer for sale, and/or import the ‘667 Accused Products supplied by
`
`Samsung to infringe the ‘667 Patent; and with the knowledge and specific intent to encourage and
`
`facilitate the infringement through the dissemination of the ‘667 Accused Products and/or the
`
`creation and dissemination of promotional and marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical information relating to the ‘667 Accused Products
`
`and infringing uses thereof.
`
`18.
`
`In addition to the foregoing and/or in the alternative, Samsung has knowingly
`
`contributed to the infringement of one or more claims of the ‘667 Patent under 35 U.S.C. § 271(c).
`
`Samsung is actively, knowingly and intentionally contributing to the infringement of the ‘667 Patent
`
`by selling, offering to sell, and/or importing into the United States, the ‘667 Accused Products, with
`
`the knowledge that they are especially designed or adapted to operate in a manner that infringes the
`
`‘667 Patent; with the knowledge that third parties, including those set forth above, will continue to,
`
`either alone or in combination with Samsung, infringe the claims of the ‘667 patent, and with the
`
`knowledge that the infringing technology in the ‘667 Accused Products is not a staple article of
`
`commerce suitable for substantial non-infringing use.
`
`19.
`
`Samsung’s acts of infringement have caused damage to KPN, and KPN is entitled to
`
`recover from Samsung the damages it has sustained as a result of Samsung’s wrongful acts in an
`
`amount subject to proof at trial.
`
`
`
`5
`
`Samsung, Exh. 1010, p. 5
`
`

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`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 6 of 8 PageID #: 6
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`
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`20.
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`Samsung’s infringement of KPN’s exclusive rights under the ‘667 Patent has caused
`
`KPN irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`DEMAND FOR JURY TRIAL
`
`21.
`
`KPN hereby demands a jury trial for all issues so triable.
`
`PRAYER FOR RELIEF
`
`
`
`WHEREFORE, KPN prays for judgment as follows:
`
`A.
`
`Declaring that Samsung has infringed the ‘667 patent, contributed to infringement of
`
`the ‘667 patent, and/or induced infringement of the ‘667 patent;
`
`B.
`
`Awarding damages arising out of Samsung’s infringement of the ‘667 patent,
`
`including enhanced damages pursuant to 35 U.S.C. § 284 and a compulsory future royalty until
`
`expiration of the ‘667 patent, to KPN, together with prejudgment and post-judgment interest, in an
`
`amount according to proof;
`
`C.
`
`Permanently enjoining pursuant to 35 U.S.C. § 283 Samsung, its officers, agents, and
`
`employees, and those persons in active concert or participating with any of them, and its successors
`
`and assigns, from infringement, inducement of infringement, and contributory infringement of the
`
`‘667 patent, including but not limited to making, using, selling and/or offering for sale within the
`
`United States or importing into the United States, any devices, products, software, or methods that
`
`infringe the ‘667 patent before the expiration of the ‘667 patent;
`
`D.
`
`Awarding attorneys’ fees to KPN pursuant to 35 U.S.C. § 285 or as otherwise
`
`permitted by law;
`
`E.
`
`Awarding such other costs and further relief as the Court may deem just and proper.
`
`
`
`6
`
`Samsung, Exh. 1010, p. 6
`
`

`
`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 7 of 8 PageID #: 7
`
`
`
`Respectfully submitted,
`
`SUSMAN GODFREY, L.L.P.
`
`
`
`/s/ Lexie White
`Lexie G. White
`State Bar No. 24048876
`lwhite@susmangodfrey.com
`SUSMAN GODFREY, L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Telephone: (713) 651-9366
`Facsimile: (713) 654-6666
`
`Attorney-in-charge for Plaintiff
`
`
`
`
`Stephen D. Susman
`State Bar No. 19521000
`ssusman@susmangodfrey.com
`Adam T. Hockensmith
`State Bar No. 24083184
`ahockensmith@susmangodfrey.com
`Jeffrey S. David
`State Bar No. 24053171
`jdavid@susmangodfrey.com
`SUSMAN GODFREY, L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Telephone: (713) 651-9366
`Facsimile: (713) 654-6666
`
`LeElle Krompass
`State Bar No. 24074549
`lkrompass@susmangodfrey.com
`SUSMAN GODFREY L.L.P.
`560 Lexington Avenue, 15th Floor
`New York, New York 10022
`Telephone: (212) 336-8341
`Facsimile: (212) 336-8340
`
`T. John Ward, Jr.
`State Bar No. 00794818
`jw@wsfirm.com
`Claire Abernathy Henry
`
`
`
`7
`
`Samsung, Exh. 1010, p. 7
`
`

`
`Case 2:15-cv-00948 Document 1 Filed 06/05/15 Page 8 of 8 PageID #: 8
`
`/s/ Lexie White
`Lexie G. White
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that all counsel of record who are deemed to have consented to electronic
`
`service are being served June 5, 2015 with a copy of this document via the Court’s CM/ECF
`system per Local Rule CV-5(a)(3).
`
`
`
`State Bar No. 24053063
`claire@wsfirm.com
`WARD & SMITH LAW FIRM
`PO Box 1231
`Longview, Texas 75606
`Telephone: (903) 757-6400
`Facsimile: (903) 757-2323
`
`Attorneys for Plaintiff
`
`
`
`
`
`
`8
`
`Samsung, Exh. 1010, p. 8
`
`

`
`Case 2:15-cv-00948 Document 1-1 Filed 06/05/15 Page 1 of 1 PageID #: 9
`
`JS 44 (Rev 12/12)
`
`CIVIL COVER SHEET
`The J. 44 civil cover sheet and the information con1nincd herein neither replace nor supplement the filing and service ofpleadin&s or other papers as required by law, except as
`provided by loc I rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
`purpose of iniliatL1g the civil docket sheet.
`(!>'Li/:' /NSJ'flUC.'1'/0 N8 ON NEXT PAGE OF THIS FORM.)
`
`I. (a) PLAINTIFFS
`KONINKLIJKE KPN N.V.
`
`_._T.!.1h"'e"-'N"'""'e"'th_.,e,,,r_,,la"""",..... _ __ _
`(b) County of Residence of First Listed Plaintiff
`(EXCEPT JN U.S. Pl..AJN11FF CASES)
`
`DEFENDANTS
`SAMSUNG ELECTRONICS CO, LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA
`LLP
`County of Residence of First Listed Defendant
`(JN U.S. PLAINTIFF CASES ONLY)
`IN LAND CONDEMNATION CASES, USE THE LOCATION OF
`THE TRACT OF LAND INVOLVED.
`
`NOTE:
`
`( C) Attorneys (Firm Name, Address. and Telephone Number)
`Lexie G. White, Stephen D. Susman, Susman Godfrey, LLP, 1000
`Louisiana St, Suite 5100, Houston, Texas 77002 713-651-9366
`
`Attorneys (/[Known)
`
`II. BASIS OF JURISDICTION (Placean "X"inOneBoxOnly)
`
`0
`
`I U.S. Government
`Plaintiff
`
`!'!! 3 Federal Question
`(U.S. Government Not a Party)
`
`III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in one Box for Plaintiff
`(For Diversity Cases Only)
`and One Box for Defendant)
`PTF DEF
`PTF
`DEF
`D
`I
`D
`I
`D 4
`D 4
`
`Citizen of This State
`
`Incorporated or Principal Place
`of Business In This State
`
`D 2 U S Government
`Defendant
`
`D 4 Diversity
`(Indicate Citizenship of Parties in Item Ill)
`
`Citizen of Anod1er State
`
`0 2
`
`0
`
`2
`
`Incorporated and Principal Place
`of Business In Another State
`
`D 5 D 5
`
`PERSONAL INJURY
`0 365 Personal Injury -
`Product Liability
`D 367 Health Care/
`Phannaceutical
`Personal lnjwy
`Product Liabi lity
`0 368 Asbestos Personal
`Injury Product
`Liability
`PERSONAL PROPERTY
`0 370 Other Fraud
`D 37 I Truth in Lending
`D 380 Other Personal
`Property Damage
`0 385 Property Damage
`Product Liability
`
`IV. NATURE 0 F SUIT (1'111~.: an "X" in One Box onlvJ
`TORTS
`I
`CONTrn~
`0 110 Insurance
`PERSONAL INJURY
`0 120 Marino
`D 3 I 0 Airplane
`0 315 Airplane Product
`D 130 Miller Act
`Liability
`D 140 Negotiable Instrument
`0 320 Assault, Libel &
`D 150 Recovery of Overpayment
`Slander
`& Enforcement of Judgment
`D 330 Federal Employers'
`D 151 Medicaie Act
`Liability
`D 152 Recovery of Defaulted
`0 340 Marine
`Student Loans
`D 345 Marine Product
`(Excludes Veterans)
`Liability
`D 153 Recovery of Overpayment
`D 350 Motor Vehicle
`of Veteran's Benefits
`0 355 Motor Vehicle
`D 160 Stockholders' Suits
`Product Liability
`D 190 Od1er Contract
`D 195 Contract Product Liability D 360 Other Personal
`0 196 Franchise
`Injury
`D 362 Personal Injury -
`Medical M6l1>roctkc
`PRISONER l'F.TITTONS
`Cl \/If, RIGHTS
`Habeas Corpus:
`D 440 Other Civil Rights
`0 441 Voting
`D 463 Alien Detainee
`0 510 Motions to Vacate
`0 442 Employment
`0 443 Housing/
`Sentence
`0 530 General
`Accommodations
`0 445 Arner. w/Disabilities - D 535 Death Penalty
`Employment
`Other:
`0 446 Arner. w/Disabilities - D 540 Mandamus & 0t•1er
`Od1er
`D 550 Civil Rights
`0 448 Education
`D 555 Prison Condition
`D 560 Civil Detainee -
`Conditions of
`Confinement
`
`1
`REAL PRO PffiTV
`0 210 Lru1d Condemnation
`D 220 Foreclosure
`D 230 Rent Lease & Ejectment
`D 240 Torts to Land
`D 245 Tort Product Liability
`0 290 All Other Real Property
`
`Citizen or Subject of a
`fotci o Coun
`
`D 3
`
`D 3 Foreign Nation
`
`D 6 D 6
`
`fiO Rf'ill'U'REIPENAL 1'Y
`0 625 Drug Related Seizure
`of Property 21 USC 881
`0 690 Other
`
`DAN KRut•rcv
`0 422 Appeal 28 USC 158
`D 423 Withdrawal
`28 USC 157
`
`Ul t
`
`~ • . I .·!lo.I
`
`D 820 Copy1 ights
`M 830 Patent
`0 840 Trademark
`
`D 861 HIA (1395ff)
`D 862 Black Lung (923)
`D 863 DIWC/DIWW (405(g))
`0 864 SSJD Title XVI
`D 865 RSI '405(g))
`
`EEDERAL TAX SUITS
`0 870 Taxes (U.S. Plaintiff
`or Defendant)
`D 871 IRS-Third Party
`26 USC 7609
`
`A W . . U
`
`D 710 1'11ir L.i\iot Standards
`Act
`0 720 Labor/Management
`Relations
`D 740 Rai lway Labor Act
`D 751 Family and Medical
`Leave Act
`0 790 Other Labor Litigation
`0 791 Employee Retirement
`Income Security Act
`
`IMl'!flGRATlON
`O 462 Nnturnli:mtion Appli ~olion
`0 465 Other Immigration
`Actions
`
`OTllER STATUTf};;
`
`I
`
`D 375 False Claims Act
`D 400 State Reapportionment
`0 410 Antitrust
`D 430 Banks and Banking
`D 450 Commerce
`D 460 Deportation
`0 470 Rackelee1 Influenced and
`Corrupt Organizations
`D 480 Consumer Credit
`0 490 Cable/Sat TV
`D 850 Securities/Co1runodities/
`Exchange
`0 890 Other Statutory Actions
`D 891 Agricultural Acts
`D 893 Environmental Matters
`D 895 Freedom oflnforrnation
`Act
`D 896 Arbitration
`0 899 Administrative Procedure
`Act/Review or Appeal of
`Agency Decision
`D 950 Constitutionality of
`State Statutes
`
`V. ORIGIN (P/acean ··x"inOneBoxOnly)
`)!!( 1 Original
`0 2 Removed from
`Proceeding
`State Court
`
`0 3 Remanded from
`Appellate Court
`
`0 4 Reinstated or
`Reopened
`
`0 6 Multidistrict
`Litigation
`
`0 5 Transferred from
`Al101hcr District
`($P'ci V)
`Cite: the U.S. Civil Statute under whi ch you are fil ing (Do not cite jurisdictional statutes unless diversity) :
`3:...::;5....::U:..:...S;::.:·c...::.C....::. 2;::.:7....::1- -- -- -- - -- - -- -- - - -- - -- - -- -- - - (cid:173)
`VI. CAUSE OF ACTION i-;
`'Brief qescdp\lon of cause:
`Patent Infringement
`0 CHECK IF THIS IS A CLASS ACTION
`UNDER RULE 23, F.R.Cv.P.
`
`VII. REQUESTED IN
`COMPLAINT:
`VIII. RELATED CASE(S)
`IF ANY
`
`(See instn1clions):
`
`JUDGE Judge Gilstrap
`
`DOCKET NUMBER 2: 14-cv-1165
`
`DATE
`0610512015
`1"0 R OFFI E SE ONLY
`
`RECEIPT#
`
`AMOUNT
`
`APPL YING lFP
`
`JUDGE
`
`MAG.JUDGE
`
`DEMAND$
`
`CHECK YES only if demanded in complaint:
`JURY DEMAND:
`)!I Yes
`0 No
`
`Samsung, Exh. 1010, p. 9
`
`

`
`Christine Aylor
`
`From:
`Sent:
`To:
`Subject:
`
`txedCM@txed.uscourts.gov
`Friday, June 05, 2015 10:44 AM
`txedcmcc@txed.uscourts.gov
`Activity in Case 2:15-cv-00948 Koninklijke Kpn N.V. v. Samsung Electronic America, Inc.,
`et al Complaint
`
`This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to
`this e-mail because the mail box is unattended.
`***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
`attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
`all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
`apply to all other users. To avoid later charges, download a copy of each document during this first
`viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not
`apply.
`
`U.S. District Court [LIVE]
`
`Eastern District of TEXAS
`
`Notice of Electronic Filing
`
`The following transaction was entered by White, Alexandra on 6/5/2015 at 10:43 AM CDT and filed on
`6/5/2015
`Case Name:
`Koninklijke Kpn N.V. v. Samsung Electronic America, Inc., et al
`Case Number:
`2:15-cv-00948
`Filer:
`Koninklijke Kpn N.V.
`Document Number: 1
`
`Docket Text:
`COMPLAINT for Patent Infringement against All Defendants ( Filing fee $ 400 receipt number
`0540-5231219.), filed by Koninklijke Kpn N.V.. (Attachments: # (1) Civil Cover Sheet)(White,
`Alexandra)
`
`
`2:15-cv-00948 Notice has been electronically mailed to:
`
`Alexandra G White lwhite@susmangodfrey.com, cmurphy@susmangodfrey.com
`
`2:15-cv-00948 Notice will not be electronically mailed to:
`
`The following document(s) are associated with this transaction:
`
`Document description:Main Document
`Original filename:n/a
`Electronic document Stamp:
`[STAMP dcecfStamp_ID=1041545818 [Date=6/5/2015] [FileNumber=9606229-0]
`
`1
`
`Samsung, Exh. 1010, p. 10
`
`

`
`[6458a8e4497433f984df2f941227c2cd82a195e82a9901f78560c7037327a19e9078
`8b8fce1bbaaf58358b576ea692e7924ad12595853c95de7e6dc4ca22a2ed]]
`Document description:Civil Cover Sheet
`Original filename:n/a
`Electronic document Stamp:
`[STAMP dcecfStamp_ID=1041545818 [Date=6/5/2015] [FileNumber=9606229-1]
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`9ced8cd9a143c0973bd48a613ec4819678c45bbaa7417d7ba53cd1a95b4e]]
`
`
`
`2
`
`Samsung, Exh. 1010, p. 11