`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Civil Action No. 2:15-cv-1754
`
`JURY TRIAL DEMANDED
`
`
`
`
`PERSONALIZED MEDIA
`COMMUNICATIONS, LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS AMERICA, INC.
`and SAMSUNG ELECTRONICS CO., LTD.,
`
` 
`
`Defendants.
`
`
`PLAINTIFF’S DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS PURSUANT TO P.R. 3-1
`
`Pursuant to Patent Rule 3-1, Plaintiff Personalized Media Communications, LLC
`
`(“PMC”) hereby provides its Disclosure of Asserted Claims and Preliminary Infringement
`
`Contentions Concerning Defendants Samsung Electronics America, Inc. and Samsung
`
`Electronics Co., Ltd. (collectively, the “Defendants” or “Samsung”). PMC reserves the right to
`
`further amend or modify its disclosures herein—including to supplement its infringement
`
`contentions pursuant to P.R. 3-6—based on additional information obtained through discovery or
`
`other means concerning the Defendants’ products or services.
`
`I.
`
`
`
`PMC’s P.R. 3-1(a) Disclosures: Infringed Claims
`
`Subject to ongoing discovery and investigation, PMC hereby contends that the
`
`Defendants infringe the following claims of U.S. Patent Nos. 7,747,217, 7,752,649, 7,752,650,
`
`7,856,649, 8,675,775, 8,711,885 (“Patents-in-Suit”) under 35 U.S.C. § 271(a) by making, using,
`
`offering to sell, and/or selling in the United States and/or importing into the United States, the
`
` 
`
`1
`
`SAMSUNG 1008
`
`

`
` 
`
`Accused Instrumentalities set forth in Part II below. PMC further contends that Defendants
`
`infringe the Patents-in-Suit by (i) practicing the asserted method claims of the Patents-in-Suit in
`
`the United States, and/or (ii) by making, using, offering to sell, and/or selling in the United States
`
`and/or importing into the United States the Accused Instrumentalities set forth in Part II below,
`
`which practice the asserted method claims of the Patents-in-Suit. PMC further contends that the
`
`Defendants infringe the following claims of the Patents-in-Suit under 35 U.S.C. § 271(b) by
`
`actively and knowingly inducing, directing, causing, and encouraging others, including, but not
`
`limited to, their designers, manufacturers, suppliers, distributors, resellers, audio and video
`
`integrators and consultants, software developers, customers, end users, subscribers, and repair
`
`providers, to infringe the Patents-in-Suit by making, using, selling, and/or offering to sell in the
`
`United States, and/or importing into the United States, the Accused Instrumentalities set forth in
`
`Part II below. PMC contends that the Defendants actively and knowingly induce infringement
`
`by others by, inter alia, providing the aforementioned direct infringers with (i) infringing
`
`functionality and/or devices; (ii) manuals and guides, technical documentation, technical support
`
`and assistance, advertisements and marketing; and/or (iii) software and/or firmware updates.
`
`PMC reserves the right to supplement its position as to infringement following further discovery
`
`and/or claim construction.
`
`U.S. Patent No.
`7,747,217
`
`7,752,649
`
`7,752,650
`7,856,649
`8,675,775
`8,711,885
`
`Claims Infringed by Samsung Digital Televisions
`1, 2, 3, 4, 5, 7, 9, 11, 30, 31, 32, 38
`1, 2, 3, 7, 8, 11, 12, 13, 22, 23, 24, 26, 27, 28, 29, 39, 40, 41, 42, 45, 48,
`49, 50, 51, 62, 63, 64, 67, 78, 79, 80, 81, 82, 83, 84, 88, 89, 90, 91, 92, 93,
`94, 97, 98
`1, 2, 3, 4, 9, 18, 32, 33
`9, 10
`2, 3, 4, 5, 6, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, 23
`1, 9, 10, 11, 12, 13, 14, 15, 17, 21, 23, 26, 27, 100, 102, 103, 105, 106
`
` 
`
`2
`
`

`
` 
`
`U.S. Patent No.
`8,675,775
`
`Claims Infringed by Samsung Android Smartphones
`2, 3, 6, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, 23
`
`II.
`
`PMC’s P.R. 3-1(b) Disclosures: Accused Instrumentality
`
`
`
`Subject to ongoing discovery and investigation, and based on available information
`
`obtained to date, PMC hereby contends that the following Accused Instrumentalities infringe the
`
`Asserted Claims:
`
`
`
`(A) Samsung digital televisions, including LED televisions such as the 9 Series
`
`(including, but not limited to, models UN46B9000 and UN55B9000), the 8 Series (including, but
`
`not limited to, models UN46B8000 and UN55B8000), the 7100 Series (including, but not limited
`
`to, models UN40B7100, UN46B7100, and UN55B7100), the 7 Series (including, but not limited
`
`to, models UN40B7000, UN46B7000, and UN55B7000), the 6 Series (including, but not limited
`
`to, models UN40B6000, UN46B6000, and UN55B6000), the 7 750 Series (including, but not
`
`limited to, models LN40750, LN46750, and LN52750), the 6 650 Series (including, but not
`
`limited to, models LN22650, LN32650, LN37650, LN40650, LN46650, and LN55650), the
`
`C9000 Series (including, but not limited to, models 46C9000 and 55C9000), the C8000 Series
`
`(including, but not limited to, models 32C8000, 40C8000, 46C8000, 55C8000, and 65C8000),
`
`the C7000 Series (including, but not limited to, models 40C7000, 46C7000, and 55C7000), the
`
`C6500 Series (including, but not limited to, models 32C6500, 37C6500, 40C6500, 46C6500, and
`
`55C6500), the C6000 Series (including, but not limited to, models 32C6000, 37C6000, 40C6000,
`
`and 46C6000), the C5000 Series (including, but not limited to, models UA32C5000QR and
`
`UA40C5000QR), the D8000 Series (including, but not limited to, models 40D8000, 46D8000,
`
`55D8000 and 65D8000), the D7000 Series (including, but not limited to, models 40D7000,
`
`46D7000, 55D7000 and 65D7000), the D6500/6400 Series (including, but not limited to, models
`
` 
`
`3
`
`

`
` 
`
`40D6500, 46D6500, 55D6500 and 60D6500), the ES8000 Series (including, but not limited to,
`
`models UN40ES8000, UN46ES8000, UN55ES8000, and UN65ES8000), the ES7500/7000
`
`Series (including, but not limited to, models UN46ES7500, UN55ES7500, UN60ES7500), the
`
`ES6500 Series (including, but not
`
`limited
`
`to, models UN40ES6500, UN46ES6500,
`
`UN50ES6500, UN55ES6500, and UN60ES6500), the ES6100 Series (including, but not limited
`
`to, models UN40ES6100, UN46ES6100, UN50ES6100, UN55ES6100, and UN60ES6100), the
`
`UHD S9 Series (including, but not limited to, models UN85S9AF, UN110S9BF, UN110S9VF,
`
`and UN105S9WAF), the F9000 Series (including, but not limited to, models UN65F9000 and
`
`UN55F9000), the F8000 Series (including, but not limited to, models UN46F8000, UN55F8000,
`
`UN60F8000, UN65F8000, and UN75F8000), the F7500 Series (including, but not limited to,
`
`models UN46F7500, UN55F7500, and UN60F7500), the F7100 Series (including, but not
`
`limited to, models UN46F7100, UN55F7100, UN60F7100, UN65F7100, and UN75F7100), the
`
`F6800 Series (including, but not limited to, models UN46F6800, UN50F6800, and UN55F6800),
`
`the F6400 Series (including, but not limited to, models UN46F6400, UN50F6400, UN60F6400,
`
`UN65F6400, and UN75F6400), the F5500 Series (including, but not limited to, models
`
`UN32F5500, UN40F5500, UN46F5500, and UN50F5500), the F5000 Series (including, but not
`
`limited to, models UN22F5000, UN32F5000, UN40F5000, UN46F5000, and UN50F5000), the
`
`F4000 Series (including, but not limited to, model UN19F4000), the HU9000 Series (including,
`
`but not limited to, models UN55HU9000, UN65HU9000, and UN78HU9000), the HU8700
`
`Series (including, but not limited to, models UN55HU8700 and UN65HU8700), the HU8550
`
`Series (including, but not limited to, models UN50HU8550, UN55HU8550, UN65HU8550, and
`
`UN75HU8550), the HU7250 Series (including, but not limited to, models UN55HU7250 and
`
`UN65HU7250), the HU6900 Series (including, but not limited to, models UN40HU6950,
`
` 
`
`4
`
`

`
` 
`
`UN50HU6950, and UN55HU6950), the HU8000 Series (including, but not limited to, models
`
`UN48H8000, UN55H8000, UN65H8000), the H7150 Series (including, but not limited to,
`
`models UN46H7150, UN55H7150, UN60H7150, UN65H7150, and UN75H7150), the H6400
`
`Series (including, but not limited to, models UN40H6400, UN48H6400, UN50H6400,
`
`UN55H6400, UN60H6400, and UN65H6400), the H6350 Series (including, but not limited to,
`
`models UN32H6350, UN40H6350, UN48H6350, UN50H6350, UN55H6350, UN60H6350, and
`
`UN65H6350), the H5500 Series (including, but not limited to, models UN32H5500,
`
`UN40H5500, and UN48H5500), the H4000 Series (including, but not limited to, model
`
`UN28H4000), JS9500 (including, but not limited to, models UN65JS9500, UN78JS9500, and
`
`UN88JS9500), JS9000 (including, but not limited to, models UN48JS9000, UN558JS9000, and
`
`UN65JS0500), JS8500 (including, but not limited to, models UN48JS8500, UN55JS8500, and
`
`UN65JS8500), JS7000 (including, but not limited to, models UN50JS7000, UN55JS7000, and
`
`UN88JS7000), JU7500 (including, but not limited to, models UN48JU7500, UN55JU7500,
`
`UN65JU7500, and UN78JU7500), JU7100 (including, but not limited to, models UN40JU7100,
`
`UN50JU7100, UN55JU7100, UN60JU7100, UN65JU7100, and UN75JU7100), JU6700
`
`(including, but not limited to, models UN40JU6700, UN48JU6700, UN55JU6700, and
`
`UN65JU6700), JU6600 (including, but not limited to, models UN40JU6600, UN48JU6600, and
`
`UN55JU6600), JU6500 (including, but not limited to, models UN40JU6500, UN48JU6500,
`
`UN50JU6500, UN55JU6500, UN60JU6500, UN65JU6500, UN75JU6500), JU6400 (including,
`
`but not
`
`limited
`
`to, models UN40JU6400, UN48JU6400, UN50JU6400, UN55JU6400,
`
`UN60JU6400, UN65JU6400, UN75JU6400), JU6300 (including, but not limited to, models
`
`UN32JU6300, UN40JU6300, UN48JU6300, UN55JU6300), and JU6200 (including, but not
`
`limited to, models UN32JU6200, UN40JU6200, UN48JU6200, UN50JU6200, UN55JU6200,
`
` 
`
`5
`
`

`
` 
`
`UN60JU6200); Plasma Televisions, including the 6 650 Plasma Series (including, but not limited
`
`to, models PN50650 and PN58650), the 8 850 Plasma Series (including, but not limited to,
`
`models PN50B850, PN50B860, PN58B850, and PN58B860), the C8000 Plasma Series
`
`(including, but not limited to, models 50C8000, 58C8000, and 53C8000), the C7000 Plasma
`
`Series (including, but not limited to, models 50C7000, 58C7000, and 63C7000), the C6500
`
`Plasma Series (including, but not limited to, models 50C6500 and 58C6500), the D8000 Plasma
`
`Series (including, but not limited to, models 51D8000, 59D8000 and 64D8000), the D7000
`
`Plasma Series (including, but not limited to, models 51D7000 and 59D7000), the D6900/6500
`
`Plasma Series (including, but not limited to, models 51D6500 and 59D6500 or 51D6900 and
`
`59D6900), the D550 Plasma Series (including, but not limited to, models 51D550 and 59D550)
`
`E8000 Plasma Series (including, but not limited to, models PN51E8000, PN60E8000, and
`
`PN64E8000), the E7000 Plasma Series (including, but not limited to, models PN51E7000,
`
`PN60E7000, PN64E7000), the E6500 Plasma Series (including, but not limited to, models
`
`PN51E6500 and PN60E6500), the E5500 Plasma Series (including, but not limited to, models
`
`PN51E550 and PN60E550), the E530 Plasma Series (including, but not limited to, models
`
`PN51E530A3F and PN60E530A3F), the E450 Plasma Series (including, but not limited to,
`
`models PN51E450A1F and PN43E450A1F), the F8500 Plasma Series (including, but not limited
`
`to, models PN51F8500, PN60F8500, and PN64F8500), the F5500 Plasma Series (including, but
`
`not limited to, models PN51F5500, PN60F5500, and PN64F5500), the F5300 Plasma Series
`
`(including, but not limited to, models PN51F5300, PN60F5300, and PN64F5300), the F4500
`
`Plasma Series (including, but not limited to, models PN43F4500 and PN51F4500), and the
`
`H5000 Plasma Series (including, but not limited to, model PN64H5000); and OLED televisions,
`
`including the ES9000 Series (including, but not limited to, model KN55ES9000) and the S9C
`
` 
`
`6
`
`

`
` 
`
`Series (including, but not limited to, model KN55S9). The Accused Instrumentalities also
`
`include the integrated circuits, processors, chips, chipsets, modules, cores, tuners, tuning
`
`components, demodulators, decoders, demultiplexers, and/or components used in each of the
`
`foregoing Samsung digital televisions, including, but not limited to, the Hawk-P, Hawk-M,
`
`Hawk-N, Hawk-UFT, and/or X14H Systems-on-Chip.
`
`
`
`(B) Samsung Android Smartphones, including the Galaxy S (including, but not limited
`
`to, models SGH-I997, SGH-I897, SGH-I896, SGH-T959, SGH-T959V/W, SCH-I500, SCH-
`
`S950C, SPH-D700, SCH-I405, SCH-I405U, SCH-R930, SCH-S720C, SCH-R910, SCH-R915),
`
`the Galaxy S II and S II Plus (including, but not limited to, models SGH-I777, SGH-I727, SGH-
`
`I927, SPH-D710, I9210, SGH-T989, SCH-R760, and GT-I9105/P), the Galaxy S III (including,
`
`but not limited to, models GT-I9300, GT-I9305, SGH-T999/L, SGH-I747, SCH-R530, SCH-
`
`I535, SCH-S960L, and SCH-S968C), the Galaxy S III Mini (including, but not limited to, model
`
`SM-G730A), the Galaxy S4 (including, but not limited to, models GT-I9500, GT-I9505, GT-
`
`I9506, GT-I9505G, SGH-I337, SGH-M919, SCH-I545, SPH-L720, SCH-R970, SCH-R970X,
`
`and SCH-R970C), the Galaxy S4 Mini (including, but not limited to, models GT-I9190, SPH-
`
`L520, SCH-I435, SCH-R890, SCH-R530U, and SGH-I257), the Galaxy S5 (including, but not
`
`limited to, models SM-G900A, SM-G900RZWAUSC, SM-G900P, SM-G900R4, SM-G900T,
`
`and SM-G900V), the Galaxy S5 Mini (including, but not limited to, model SM-G800H), the
`
`Galaxy S6 (including, but not limited to, models SM-G920, SM-G920A, SM-G920F, SM-
`
`G920T, SM-G920V), the Galaxy S6 Edge (including, but not limited to, models SM-G925, SM-
`
`G925A, SM-G925F, SM-G925T, SM-G925V), the Galaxy Alpha (including, but not limited to,
`
`models SM-G850A, and SM-G850T), the Galaxy Note (including, but not limited to, models
`
`GT-N7000, SGH-I717, and SGH-T879), the Galaxy Note II (including, but not limited to,
`
` 
`
`7
`
`

`
` 
`
`models GT-N7100, GT-N7105, SCH-i605, SCH-R950, SGH-i317M, SGH-T889, and SPH-
`
`L900), the Galaxy Note 3 (including, but not limited to, models N9000, N9005, N9006, SM-
`
`N900A, SM-N900V, SM-N900P, SM-N900R4, SM-N900T), the Galaxy Note 4 (including, but
`
`not limited to, models SM-N910A, SM-910P, SM-N910R4, SM-N910T, SM-N910T1, and SM-
`
`N910V), the Galaxy Note Edge (including, but not limited to, models SM-N915, SM-N915A,
`
`SM-N915T, SM-N915V), and the Galaxy Note 5 (including, but not limited to, models SM-920,
`
`SM-N920T, SM-N920A, and SM-N920V). The Accused Instrumentalities also include the
`
`integrated circuits, processors, chips, chipsets, modules, cores, tuners, tuning components,
`
`demodulators, decoders, demultiplexers, and/or components used in each of the foregoing
`
`Samsung Android Smartphones, including, but not limited to, Samsung Exynos and/or
`
`Qualcomm Snapdragon Systems-on-Chip.
`
`III.
`
`PMC’s P.R. 3-1(c) Disclosures: Preliminary Infringement Charts
`
`
`
`Subject to ongoing discovery and investigation, and based on available information
`
`obtained to date, PMC hereby contends that each element of each infringed claim is found within
`
`each Accused Instrumentality as shown in preliminary infringement claim charts attached hereto
`
`as Exhibits A through G. PMC reserves the right to amend its asserted claims and infringement
`
`contentions pursuant to P.R. 3-6 as discovery progresses and additional information is gathered.
`
`IV.
`
`PMC’s P.R. 3-1(d) Disclosures: Literal Infringement and Infringement Under DOE
`
`
`
`Subject to ongoing discovery and investigation, and based on available information
`
`obtained to date, PMC hereby contends that, except where it is indicated otherwise, each element
`
`of each asserted claim is literally present in each of the Accused Instrumentalities as specifically
`
`shown in Exhibits A through G.
`
`To the extent that certain elements of the asserted claims are not literally present in each
`
`8
`
`
`
` 
`
`

`
` 
`
`of the Accused Instrumentalities, at this time, PMC contends that such elements of the asserted
`
`claims are met by the Accused Instrumentalities under the Doctrine of Equivalents:
`
`U.S. Patent No.
`7,747,217
`
`7,752,649
`
`7,752,650
`
`7,856,649
`
`8,675,775
`
`8,711,885
`
`Claim Elements
`
`“output device” in claim 38.
`“processor[s]” in claims 1, 2, 3, 7, 8, 11, 12, 13, 22, 23, 24, 26, 27, 28, 29,
`39, 40, 41, 42, 45, 48, 49, 50, 51, 62, 63, 64, 67, 78, 79, 80, 81, 82, 83, 84,
`88, 89, 90, 91, 92, 93, 94, 97, and 98.
`“control processor” in claims 1, 2, 3, 7, 8, 11, 12, 13, 22, 23, 24, 26, 27, 28,
`29, 39, 40, 41, 42, 45, 48, 49, 50, 51, 62, 63, 64, 67, 78, 79, 80, 81, 82, 83,
`84, 88, 89, 90, 91, 92, 93, 94, 97, and 98.
`“digital switch” in claims 45, 48, 49, 50, 51, 78, 79, 80, 81, 82, 83, 84, 88,
`89, 90, 91, 92, 93, 94, 97, and 98.
`“message” in claims 1, 2, 3, 7, 8, 11, 12, 13, 22, 23, 24, 26, 27, 28, 29, 39,
`40, 41, 42, 45, 48, 49, 50, 51, 64, 78, 79, 80, 81, 82, 83, 84, 88, 89, 90, 91,
`92, 93, 94, 97, and 98.
`“processor[s]” in claims 1, 2, 3, 4, 9, 18, 32, and 33.
`“control processor” in claims 1, 2, 3, 4, and 9.
`“digital switch” in claims 1, 2, 3, 4, 9, 18, 32, and 33.
`“command[s]” in claims 1, 2, 3, 4, 9, 18, 32, and 33.
`“message” in claims 1, 2, 3, 4, 9, 18, 32, and 33.
`“processor[s]” in claims 9 and 10.
`“message” in claim 10.
`Samsung Digital Televisions:
`“processor[s]” in claims 2, 3, 4, 5, 6, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21,
`and 23.
`Samsung Android Smartphones:
`“receiver station” in claims 2, 3, 6, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, and
`23.
`“processor[s]” in claims 2, 3, 6, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, and
`23.
`“processor[s]” in claims 1, 9, 10, 11, 12, 13, 14, 15, 17, 21, 23, 26, 27, 100,
`102, 103, 105, and 106.
`“control processor” in claims 100, 102, 103, 105, and 106.
`“selecting . . . input source” in claims 9, 10, 11, 12, 13, 14, 15, 17, 21, 23,
`26, and 27.
`“valve” in claim 1.
`“message” in claim 105.
`
` 
`
`9
`
`

`
` 
`
`
`
`As indicated above, discovery is necessary to further develop PMC’s infringement
`
`positions—either literal or under the Doctrine of Equivalents, and the Court has yet to issue a
`
`claim construction order. Pursuant to P.R. 3-6, PMC expressly reserves the right to amend and
`
`supplement its position on whether there is infringement under the Doctrine of Equivalents of
`
`any other elements of any asserted claims after further discovery from the Defendants and/or
`
`pending this Court’s claim construction order.
`
`V.
`
`PMC’s P.R. 3-1(e) Disclosures: Priority Dates
`
`
`
`PMC contends that the asserted claims of U.S. Patent Nos. 7,747,217 and 7,856,649 are
`
`entitled to the priority date of U.S. Patent Application Serial No. 06/317,510, filed November 3,
`
`1981, which issued as U.S. Patent No. 4,694,490.
`
`
`
`PMC further contends that the asserted claims of U.S. Patent Nos. 7,752,649, 7,752,650,
`
`8,675,775, and 8,711,885 are at least entitled to the priority date of U.S. Patent Application
`
`Serial No. 07/096,096, filed September 11, 1987, now U.S. Patent No. 4,965,825, which was a
`
`continuation-in-part of U.S. Patent Application Serial No. 06/829,531, filed February 14, 1986,
`
`now U.S. Patent No. 4,704,725, which was a continuation of U.S. Patent Application Serial No.
`
`06/317,510, filed November 3, 1981, now U.S. Patent No. 4,694,490.
`
`VI.
`
`PMC’s P.R. 3-1(f) Disclosures: Right to Rely on PMC’s Own Instrumentality
`
`
`
`PMC presently does not intend to rely upon the assertion that its own instrumentalities
`
`practice the claimed inventions.
`
` Respectfully submitted,
`
`
`
`
`
`
`
`
`s/ Meng Xi
`S. Calvin Capshaw
`Elizabeth L. DeRieux
`CAPSHAW DERIEUX LLP
`114 East Commerce Avenue
`Gladewater, TX 75647
`
`Dated: February 8, 2016
`
`
`
`
`
`
`
`
`
` 
`
`10
`
`

`
`Telephone: (903) 236-9800
`ccapshaw@capshawlaw.com
`ederieux@capshawlaw.com
`
`Arun S. Subramanian
`SUSMAN GODFREY L.L.P.
`560 Lexington Avenue, 15th Floor
`New York, NY 10022
`Telephone: (212) 471-8346
`asubramanian@susmangodfrey.com
`
`Joseph S. Grinstein
`SUSMAN GODFREY L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002
`Telephone: (713) 653-7820
`jgrinstein@susmangodfrey.com
`
`Meng Xi
`SUSMAN GODFREY L.L.P.
`1901 Avenue of the Stars, Suite 950
`Los Angeles, CA 90067
`Telephone: (310) 789-3158
`mxi@susmangodfrey.com
`
`Dmitry Kheyfits
`KHEYFITS P.C.
`1140 Avenue of the Americas, 9th Floor
`New York, NY 10036
`Telephone: (212) 203-5399
`dkheyfits@kheyfits.com
`
`
`Attorneys for Plaintiff
`Personalized Media Communications, LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record are being served via electronic mail with a copy
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`of this document on February 8, 2016.
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`s/ Meng Xi
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` Meng Xi
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