IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Case No.
`
`JURY TRIAL DEMANDED
`
`APEX BEAM TECHNOLOGIES LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Apex Beam Technologies LLC (“ABT” or “Plaintiff”) for its Complaint against
`
`Defendants Samsung Electronics Co., Ltd. (“Samsung Electronics”) and Samsung Electronics
`
`America, Inc. (“Samsung Electronics America”) (collectively “Samsung” or “Defendants”), for
`
`patent infringement under 35 U.S.C. § 271 and alleges as follows:
`
`THE PARTIES
`
`1.
`
`ABT is a limited liability company organized and existing under the laws of the
`
`State of Texas, with its principal place of business located at 104 East Houston Street, Suite 180,
`
`Marshall, Texas 75670.
`
`2.
`
`Defendant Samsung Electronics is a corporation organized and existing under the
`
`laws of the Republic of Korea, with its principal place of business at 129 Samsung-Ro, Yeongtong-
`
`Gu, Suwon-Si, Gyeonggi-Do, 443-742, Republic of Korea. Upon information and belief, Samsung
`
`Electronics does business in Texas, directly or through intermediaries, and offers its products
`
`and/or services, including those accused herein of infringement, to customers and potential
`
`customers located in Texas, including in the Judicial District of the Eastern District of Texas.
`
`Samsung Exhibit 1017, Page 1 of 26
`
`

`

`3.
`
`Defendant Samsung Electronics America is a corporation organized under the laws
`
`of New York, with its principal place of business at 85 Challenger Road, Ridgefield Park, New
`
`Jersey 07660. Upon information and belief, Samsung Electronics America has corporate offices
`
`in the Eastern District of Texas at 1303 East Lookout Drive, Richardson, Texas 75082 and 2800
`
`Technology Drive, Suite 200, Plano, Texas 75074. Samsung Electronics America has publicly
`
`indicated that in early 2019, it would be centralizing multiple offices in a new location in the
`
`Eastern District of Texas at the Legacy Central office campus,1 located at 6225 Declaration Drive,
`
`Plano, Texas 75023. Samsung Electronics America may be served with process through its
`
`registered agent CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136.
`
`4.
`
`Defendants have authorized sellers and sales representatives that offer and sell
`
`products pertinent to this Complaint through the State of Texas, including in this Judicial District,
`
`and to consumers throughout this Judicial District, such as: Best Buy, 422 West TX-281 Loop,
`
`Suite 100, Longview, Texas 75605; AT&T Store, 1712 East Grand Avenue, Marshall, Texas
`
`75670; T-Mobile, 1806 East End Boulevard North, Suite 100, Marshall, Texas 75670; T-Mobile,
`
`900 East End Boulevard North, Suite 100, Marshall, Texas 75670; Verizon authorized retailers,
`
`including Russell Cellular, 1111 East Grand Avenue, Marshall, Texas 75670; Victra, 1006 East
`
`End Boulevard, Marshall, Texas 75670; and Cricket Wireless authorized retailer, 120 East End
`
`Boulevard South, Marshall, Texas 75670.
`
`
`1 https://news.samsung.com/us/samsung-electronics-america-open-flagship-north-texas-campus/,
`last accessed Apr. 11, 2022.
`
`2
`
`Samsung Exhibit 1017, Page 2 of 26
`
`

`

`JURISDICTION
`
`5.
`
`This is an action for patent infringement arising under the patent laws of the United
`
`States, 35 U.S.C. §§ 1, et seq. This Court has jurisdiction over this action pursuant to 28 U.S.C.
`
`§§ 1331, 1332, 1338 and 1367.
`
`6.
`
`This Court has specific and personal jurisdiction over the Defendants consistent
`
`with the requirements of the Due Process Clause of the United States Constitution and the Texas
`
`Long Arm Statute. Upon information and belief, the Defendants have sufficient minimum contacts
`
`with the forum because each Defendant transacts substantial business in the State of Texas and in
`
`this Judicial District. Further, each Defendant has, directly or through subsidiaries or
`
`intermediaries, committed and continues to commit acts of patent infringement in the State of
`
`Texas and in this Judicial District as alleged in this Complaint, as alleged more particularly below.
`
`7.
`
`Venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1400(b) and
`
`1391(b) and (c) because each Defendant is subject to personal jurisdiction in this Judicial District,
`
`has committed acts of patent infringement in this Judicial District, and has a regular and established
`
`place of business in this Judicial District. Each Defendant, through its own acts and/or through the
`
`acts of each other Defendant, makes, uses, sells, and/or offers to sell infringing products within
`
`this Judicial District, regularly does and solicits business in this Judicial District, and has the
`
`requisite minimum contacts with this Judicial District such that this venue is a fair and reasonable
`
`one. Further, venue is proper in this Judicial District because Samsung Electronics is a foreign
`
`corporation formed under the laws of Korea with a principal place of business in Korea. Further,
`
`upon information and belief, the Defendants have admitted or not contested proper venue in this
`
`Judicial District in other patent infringement actions.
`
`
`
`3
`
`Samsung Exhibit 1017, Page 3 of 26
`
`

`

`PATENTS-IN-SUIT
`
`8.
`
`On October 29, 2019, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 10,462,767 (the “’767 Patent”) entitled “Method and Device in UE
`
`and Base Station Used for Paging.” A true and correct copy of the ’767 Patent is available at
`
`http://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10462767.
`
`9.
`
`On February 18, 2020, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 10,568,113 (the “’113 Patent”) entitled “Method and Device in UE
`
`and Base Station Used for Wireless Communication.” A true and correct copy of the ’113 Patent
`
`is available at http://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10568113.
`
`10.
`
`On February 2, 2021, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 10,912,081 (the “’081 Patent”) entitled “Method and Device used
`
`for Wireless Communication in UE and Base Station.” A true and correct copy of the ’081 Patent
`
`is available at http://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10912081.
`
`11.
`
`On March 9, 2021, the United States Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 10,944,527 (the “’527 Patent”) entitled “Method and Device for Multi-
`
`Antenna Transmission in UE and Base Station.” A true and correct copy of the ’527 Patent is
`
`available at http://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10944527.
`
`12.
`
`On March 16, 2021, the United States Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 10,951,271 (the “’271 Patent”) entitled “Method and Device for Multi-
`
`Antenna Transmission in UE and Base Station.” A true and correct copy of the ’271 Patent is
`
`available at http://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10951271.
`
`13.
`
`ABT is the sole and exclusive owner of all right, title, and interest in the ’767 Patent,
`
`the ’113 Patent, the ’081 Patent, the ’527 Patent, and the ’271 Patent (collectively, the “Patents-
`
`4
`
`Samsung Exhibit 1017, Page 4 of 26
`
`

`

`in-Suit”) and holds the exclusive right to take all actions necessary to enforce its rights to the
`
`Patents-in-Suit, including the filing of this patent infringement lawsuit. ABT also has the right to
`
`recover all damages for past, present, and future infringement of the Patents-in-Suit.
`
`FACTUAL ALLEGATIONS
`
`14.
`
`The Patents-in-Suit generally relate to systems and methods for transmission
`
`schemes in wireless communication systems.
`
`15.
`
`The ’767 Patent generally relates to paging interval schedules that enable simplified
`
`paging to mobile handsets while maintaining low power consumption. The technology described
`
`in the ’767 Patent was developed by Xiaobo Zhang of Shanghai Langbo Communication
`
`Technology Company Limited. By way of example, this technology is implemented today in the
`
`Accused Products (e.g., 5G mobile handset, tablets, and notebooks).
`
`16.
`
`The ’113 Patent generally relates to technology that uses signal timing to improve
`
`signal delivery upon a beam recovery request. The technology described in the ’113 Patent was
`
`developed by Xiaobo Zhang of Shanghai Langbo Communication Technology Company Limited.
`
`By way of example, this technology is implemented today in the Accused Products (e.g., 5G
`
`mobile handsets, tablets, and notebooks).
`
`17.
`
`The ’081 Patent generally relates to technology that uses symbol reception timing
`
`to determine beam or port location to improve communication quality. The technology described
`
`in the ’081 Patent was developed by Xiaobo Zhang of Shanghai Langbo Communication
`
`Technology Company Limited. By way of example, this technology is implemented today in the
`
`Accused Products (e.g., 5G mobile handsets, tablets, and notebooks).
`
`18.
`
`The ’527 Patent generally relates to technology that provides mobile handsets with
`
`antenna virtualization information to determine correct beam alignment to enhance transmission
`
`5
`
`Samsung Exhibit 1017, Page 5 of 26
`
`

`

`quality. The technology described in the ’527 Patent was developed by Xiaobo Zhang of Shanghai
`
`Langbo Communication Technology Company Limited. By way of example, this technology is
`
`implemented today in the Accused Products (e.g., 5G mobile handsets, tablets, and notebooks).
`
`19.
`
`The ’271 Patent generally relates to technology that uses channel qualities and
`
`differential-based reporting compared to a threshold to assist in beam selection. The technology
`
`described in the ’271 Patent was developed by Xiaobo Zhang of Shanghai Langbo Communication
`
`Technology Company Limited. By way of example, this technology is implemented today in the
`
`Accused Products (e.g., 5G mobile handsets, tablets, and notebooks).
`
`20.
`
`Defendants have infringed and continue to infringe one or more of the Patents-in-
`
`Suit by making, using, selling, offering to sell, and/or importing, and by actively inducing others
`
`to make, use, sell, offer to sell, and/or import products, including handsets, tablets, smart devices,
`
`and chipsets thereof, that implement the 5G standards. For example, the Accused Products include,
`
`but are not limited to, the Galaxy A13 5G, Galaxy A22 5G, Galaxy A32 5G, Galaxy A33 5G,
`
`Galaxy A42 5G, Galaxy A51 5G, Galaxy A52 5G, Galaxy A52s 5G, Galaxy A53 5G, Galaxy A71
`
`5G, Galaxy A73 5G, Galaxy A90 5G, Galaxy Book Go 5G, Galaxy Book Pro 360 5G, Galaxy F42
`
`5G, Galaxy F52 5G, Galaxy Fold 5G, Galaxy M32 5G, Galaxy M42 5G, Galaxy M52 5G, Galaxy
`
`Note 10 5G, Galaxy Note 10+ 5G, Galaxy Note 20 5G, Galaxy Note 20 Ultra 5G, Galaxy Quantum
`
`2, Galaxy S10 5G, Galaxy S20 5G, Galaxy S20 FE 5G, Galaxy S20 Ultra 5G, Galaxy S20 UW,
`
`Galaxy S20+ 5G, Galaxy S21 5G, Galaxy S21 Ultra 5G, Galaxy S21+ 5G, Galaxy S22, Galaxy
`
`S22 5G, Galaxy S22 Ultra, Galaxy S22+, Galaxy Tab S7 5G, Galaxy Tab S7 FE 5G, Galaxy Tab
`
`S7+ 5G, Galaxy Tab S8+ 5G, Galaxy Z Flip 5G, Galaxy Z Flip3 5G, Galaxy Z Fold 2 5G, and the
`
`Galaxy Z Fold3 5G.
`
`6
`
`Samsung Exhibit 1017, Page 6 of 26
`
`

`

`21.
`
`Samsung has had notice of the Asserted Patents, at least as of the filing date of this
`
`complaint.
`
`
`22.
`
`23.
`
`COUNT I
`(Infringement of the ’767 Patent)
`
`Paragraphs 1 through 21 are incorporated by reference as if fully set forth herein.
`
`ABT has not licensed or otherwise authorized Defendants to make, use, offer for
`
`sale, sell, or import any products that embody the inventions of the ’767 Patent.
`
`24.
`
`Defendants have and continue to directly infringe the ’767 Patent, either literally or
`
`under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making,
`
`using, offering to sell, selling, and/or importing into the United States products that satisfy each
`
`and every limitation of one or more claims of the ’767 Patent. Such products include at least the
`
`Accused Products including, but not limited to, the Galaxy A13 5G, Galaxy A22 5G, Galaxy A32
`
`5G, Galaxy A33 5G, Galaxy A42 5G, Galaxy A51 5G, Galaxy A52 5G, Galaxy A52s 5G, Galaxy
`
`A53 5G, Galaxy A71 5G, Galaxy A73 5G, Galaxy A90 5G, Galaxy Book Go 5G, Galaxy Book
`
`Pro 360 5G, Galaxy F42 5G, Galaxy F52 5G, Galaxy Fold 5G, Galaxy M32 5G, Galaxy M42 5G,
`
`Galaxy M52 5G, Galaxy Note 10 5G, Galaxy Note 10+ 5G, Galaxy Note 20 5G, Galaxy Note 20
`
`Ultra 5G, Galaxy Quantum 2, Galaxy S10 5G, Galaxy S20 5G, Galaxy S20 FE 5G, Galaxy S20
`
`Ultra 5G, Galaxy S20 UW, Galaxy S20+ 5G, Galaxy S21 5G, Galaxy S21 Ultra 5G, Galaxy S21+
`
`5G, Galaxy S22, Galaxy S22 5G, Galaxy S22 Ultra, Galaxy S22+, Galaxy Tab S7 5G, Galaxy Tab
`
`S7 FE 5G, Galaxy Tab S7+ 5G, Galaxy Tab S8+ 5G, Galaxy Z Flip 5G, Galaxy Z Flip3 5G, Galaxy
`
`Z Fold 2 5G, and the Galaxy Z Fold3 5G which practice a method in a User Equipment (UE) for
`
`paging, comprising: monitoring a first signaling in X time intervals; and receiving a first radio
`
`signal; wherein X is a positive integer; the first signaling is used for determining scheduling
`
`information for the first radio signal; the scheduling information comprises at least one of
`
`7
`
`Samsung Exhibit 1017, Page 7 of 26
`
`

`

`(occupied time-frequency resource, adopted Modulation Coding Scheme (MCS), subcarrier
`
`spacing of subcarriers in occupied frequency domain resource); the first radio signal carries a
`
`paging message; the frequency domain resource used for transmitting the first signaling belongs
`
`to a first subband; the first subband comprises a positive integer number of consecutive subcarriers
`
`in frequency domain; and at least one of (location of the first subband in frequency domain,
`
`subcarrier spacing of subcarriers included in the first subband) is used for determining the X time
`
`intervals.
`
`25.
`
`For example, Defendants have and continue to directly infringe at least claim 1 of
`
`the ’767 Patent by making, using, offering to sell, selling, and/or importing into the United States
`
`products that implement the 5G standards such as the Accused Products (e.g., 5G mobile handsets,
`
`tablets, and notebooks). For example, the Galaxy Z Fold3 5G operates on 5G networks and
`
`includes firmware for implementing 3rd Generation Partnership Product (3GPP) specifications).
`
`26.
`
`The Accused Products perform a method in a User Equipment (such as the Galaxy
`
`Z Fold3 5G) for paging comprising: monitoring a first signaling (e.g., Paging DCI) in X time
`
`intervals (e.g., PDCCH monitoring occasions); and receiving a first radio signal (e.g., PCCH, PCH,
`
`or PDSCH); wherein X is a positive integer; the first signaling is used for determining scheduling
`
`information for the first radio signal; the scheduling information comprises at least one of occupied
`
`time-frequency resource, adopted Modulation Coding Scheme (MCS), subcarrier spacing of
`
`subcarriers in occupied frequency domain resource); the first radio signal carries a paging message;
`
`the frequency domain resource used for transmitting the first signaling belongs to a first subband
`
`(e.g., a BWP); the first subband comprises a positive integer number of consecutive subcarriers in
`
`frequency domain; and at least one of (location of the first subband in frequency domain, subcarrier
`
`spacing of subcarriers included in the first subband) is used for determining the X time intervals.
`
`8
`
`Samsung Exhibit 1017, Page 8 of 26
`
`

`

`27.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’767 Patent, as provided by 35 U.S.C. § 271(b), by inducing infringement by others,
`
`such as Samsung’s customers and end-users, in this District and elsewhere in the United States.
`
`For example, Samsung’s customers and end-users directly infringe, either literally or under the
`
`doctrine of equivalents, through their use of the inventions claimed in the ’767 Patent. Samsung
`
`induces this direct infringement through its affirmative acts of manufacturing, selling, distributing,
`
`and/or otherwise making available
`
`the Accused Products, and providing instructions,
`
`documentation, and other information to customers and end-users suggesting that they use the
`
`Accused Products in an infringing manner, including technical support, marketing, product
`
`manuals, advertisements, and online documentation. Because of Samsung’s inducement,
`
`Samsung’s customers and end-users use the Accused Products in a way Samsung intends and they
`
`directly infringe the ’767 Patent. Samsung performs these affirmative acts with knowledge of the
`
`’767 Patent and with the intent, or willful blindness, that the induced acts directly infringe the ’767
`
`Patent.
`
`28.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’767 Patent, as provided by 35 U.S.C. § 271(c), by contributing to direct infringement
`
`by others, such as customers and end-users, in this District and elsewhere in the United States.
`
`Samsung’s affirmative acts of selling and offering to sell the Accused Products in this District and
`
`elsewhere in the United States and causing the Accused Products to be manufactured, used, sold,
`
`and offered for sale contribute to others’ use and manufacture of the Accused Products such that
`
`the ’767 Patent is directly infringed by others. The accused components within the Accused
`
`Products including, but not limited to, chipsets manufactured by Samsung, are material to the
`
`invention of the ’767 Patent, are not staple articles or commodities of commerce, have no
`
`9
`
`Samsung Exhibit 1017, Page 9 of 26
`
`

`

`substantial non-infringing uses, and are known by Samsung to be especially made or adapted for
`
`use in the infringement of the ’767 Patent. Samsung performs these affirmative acts with
`
`knowledge of the ’767 Patent and with intent, or willful blindness, that they cause the direct
`
`infringement of the ’767 Patent.
`
`29.
`
`ABT has suffered damages as a result of Defendants’ direct and indirect
`
`infringement of the ’767 Patent in an amount to be proved at trial.
`
`COUNT II
`(Infringement of the ’113 Patent)
`
`Paragraphs 1 through 21 are incorporated by reference as if fully set forth herein.
`
`ABT has not licensed or otherwise authorized Defendants to make, use, offer for
`
`
`30.
`
`31.
`
`sale, sell, or import any products that embody the inventions of the ’113 Patent.
`
`32.
`
`Defendants have and continue to directly infringe the ’113 Patent, either literally or
`
`under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making,
`
`using, offering to sell, selling, and/or importing into the United States products that satisfy each
`
`and every limitation of one or more claims of the ’113 Patent. Such products include at least
`
`Accused Products including, but not limited to, Galaxy A13 5G, Galaxy A22 5G, Galaxy A32 5G,
`
`Galaxy A33 5G, Galaxy A42 5G, Galaxy A51 5G, Galaxy A52 5G, Galaxy A52s 5G, Galaxy A53
`
`5G, Galaxy A71 5G, Galaxy A73 5G, Galaxy A90 5G, Galaxy Book Go 5G, Galaxy Book Pro
`
`360 5G, Galaxy F42 5G, Galaxy F52 5G, Galaxy Fold 5G, Galaxy M32 5G, Galaxy M42 5G,
`
`Galaxy M52 5G, Galaxy Note 10 5G, Galaxy Note 10+ 5G, Galaxy Note 20 5G, Galaxy Note 20
`
`Ultra 5G, Galaxy Quantum 2, Galaxy S10 5G, Galaxy S20 5G, Galaxy S20 FE 5G, Galaxy S20
`
`Ultra 5G, Galaxy S20 UW, Galaxy S20+ 5G, Galaxy S21 5G, Galaxy S21 Ultra 5G, Galaxy S21+
`
`5G, Galaxy S22, Galaxy S22 5G, Galaxy S22 Ultra, Galaxy S22+, Galaxy Tab S7 5G, Galaxy Tab
`
`S7 FE 5G, Galaxy Tab S7+ 5G, Galaxy Tab S8+ 5G, Galaxy Z Flip 5G, Galaxy Z Flip3 5G, Galaxy
`
`10
`
`Samsung Exhibit 1017, Page 10 of 26
`
`

`

`Z Fold 2 5G, and the Galaxy Z Fold3 5G which practice a method in a User Equipment (UE) for
`
`wireless communication, comprising: receiving a target radio signal; transmitting a first radio
`
`signal on a first channel; transmitting a second radio signal on a second channel; and monitoring
`
`a third radio signal in a first time window; wherein a measurement for the target radio signal
`
`obtains a target measurement value, the target measurement value, when higher than a target
`
`threshold is used for triggering the transmission of the first radio signal and the second radio signal;
`
`a time resource occupied by the first radio signal is used for determining the start time of the first
`
`time window; a time domain resource occupied by the first radio signal is used for determining a
`
`second time window, a time domain resource occupied by the second radio signal is within the
`
`second time window, and the second time window is within the first time window; a time domain
`
`resource occupied by the second radio signal is used for determining a third time window, and the
`
`end time of the third time window is the end time of the first time window; and the second time
`
`window and the third time window have overlapped time domain resource(s).
`
`33.
`
`For example, Defendants have and continue to directly infringe at least claim 1 of
`
`the ’113 Patent by making, using, offering to sell, selling, and/or importing into the United States
`
`products that implement the 5G standards, such as the Accused Products (e.g., 5G mobile handsets,
`
`tablets, and notebooks). For example, the Galaxy Z Fold3 5G operates on 5G networks and
`
`includes firmware for implementing 3rd Generation Partnership Product (3GPP) specifications).
`
`34.
`
`The Accused Products perform a method in a User Equipment (such as the Galaxy
`
`Z Fold3 5G) for wireless communication, comprising: receiving a target radio signal (e.g., SS);
`
`transmitting a first radio signal (e.g., MsgA) on a first channel (e.g., PRACH, PUSCH);
`
`transmitting a second radio signal (e.g., PUSCH scheduled by a RAR UL grant) on a second
`
`channel (e.g., PUSCH); and monitoring a third radio signal in a first time window (e.g., covering
`
`11
`
`Samsung Exhibit 1017, Page 11 of 26
`
`

`

`the time from the beginning of the second time window to the end of the third time window);
`
`wherein a measurement for the target radio signal obtains a target measurement value, the target
`
`measurement value, when higher than a target threshold is used for triggering the transmission of
`
`the first radio signal and the second radio signal; a time resource occupied by the first radio signal
`
`is used for determining the start time of the first time window; a time domain resource occupied
`
`by the first radio signal is used for determining a second time window (e.g., msgB-
`
`ResponseWindow configured by RRC signaling), a time domain resource occupied by the second
`
`radio signal is within the second time window, and the second time window is within the first time
`
`window; a time domain resource occupied by the second radio signal is used for determining a
`
`third time window (i.e., running time of ra-ContentionResolutionTimer), and the end time of the
`
`third time window is the end time of the first time window; and the second time window and the
`
`third time window have overlapped time domain resource(s).
`
`35.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’113 Patent, as provided by 35 U.S.C. § 271(b), by inducing infringement by others,
`
`such as Samsung’s customers and end-users, in this District and elsewhere in the United States.
`
`For example, Samsung’s customers and end-users directly infringe, either literally or under the
`
`doctrine of equivalents, through their use of the inventions claimed in the ’113 Patent. Samsung
`
`induces this direct infringement through its affirmative acts of manufacturing, selling, distributing,
`
`and/or otherwise making available
`
`the Accused Products, and providing instructions,
`
`documentation, and other information to customers and end-users suggesting that they use the
`
`Accused Products in an infringing manner, including technical support, marketing, product
`
`manuals, advertisements, and online documentation. Because of Samsung’s inducement,
`
`Samsung’s customers and end-users use the Accused Products in a way Samsung intends and they
`
`12
`
`Samsung Exhibit 1017, Page 12 of 26
`
`

`

`directly infringe the ’113 Patent. Samsung performs these affirmative acts with knowledge of the
`
`’113 Patent and with the intent, or willful blindness, that the induced acts directly infringe the ’113
`
`Patent.
`
`36.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’113 Patent, as provided by 35 U.S.C. § 271(c), by contributing to direct infringement
`
`by others, such as customers and end-users, in this District and elsewhere in the United States.
`
`Samsung’s affirmative acts of selling and offering to sell the Accused Products in this District and
`
`elsewhere in the United States and causing the Accused Products to be manufactured, used, sold,
`
`and offered for sale contribute to others’ use and manufacture of the Accused Products such that
`
`the ’113 Patent is directly infringed by others. The accused components within the Accused
`
`Products including, but not limited to, chipsets manufactured by Samsung, are material to the
`
`invention of the ’113 Patent, are not staple articles or commodities of commerce, have no
`
`substantial non-infringing uses, and are known by Samsung to be especially made or adapted for
`
`use in the infringement of the ’113 Patent. Samsung performs these affirmative acts with
`
`knowledge of the ’113 Patent and with intent, or willful blindness, that they cause the direct
`
`infringement of the ’113 Patent.
`
`37.
`
`ABT has suffered damages as a result of Defendants’ direct and indirect
`
`infringement of the ’113 Patent in an amount to be proved at trial.
`
`COUNT III
`(Infringement of the ’081 Patent)
`
`Paragraphs 1 through 21 are incorporated by reference as if fully set forth herein.
`
`ABT has not licensed or otherwise authorized Defendants to make, use, offer for
`
`
`38.
`
`39.
`
`sale, sell, or import any products that embody the inventions of the ’081 Patent.
`
`13
`
`Samsung Exhibit 1017, Page 13 of 26
`
`

`

`40.
`
`Defendants have and continue to directly infringe the ’081 Patent, either literally or
`
`under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making,
`
`using, offering to sell, selling, and/or importing into the United States products that satisfy each
`
`and every limitation of one or more claims of the ’081 Patent. Such products include at least
`
`Accused Products including, but not limited to, Galaxy A13 5G, Galaxy A22 5G, Galaxy A32 5G,
`
`Galaxy A33 5G, Galaxy A42 5G, Galaxy A51 5G, Galaxy A52 5G, Galaxy A52s 5G, Galaxy A53
`
`5G, Galaxy A71 5G, Galaxy A73 5G, Galaxy A90 5G, Galaxy Book Go 5G, Galaxy Book Pro
`
`360 5G, Galaxy F42 5G, Galaxy F52 5G, Galaxy Fold 5G, Galaxy M32 5G, Galaxy M42 5G,
`
`Galaxy M52 5G, Galaxy Note 10 5G, Galaxy Note 10+ 5G, Galaxy Note 20 5G, Galaxy Note 20
`
`Ultra 5G, Galaxy Quantum 2, Galaxy S10 5G, Galaxy S20 5G, Galaxy S20 FE 5G, Galaxy S20
`
`Ultra 5G, Galaxy S20 UW, Galaxy S20+ 5G, Galaxy S21 5G, Galaxy S21 Ultra 5G, Galaxy S21+
`
`5G, Galaxy S22, Galaxy S22 5G, Galaxy S22 Ultra, Galaxy S22+, Galaxy Tab S7 5G, Galaxy Tab
`
`S7 FE 5G, Galaxy Tab S7+ 5G, Galaxy Tab S8+ 5G, Galaxy Z Flip 5G, Galaxy Z Flip3 5G, Galaxy
`
`Z Fold 2 5G, and the Galaxy Z Fold3 5G which practice a method in a User Equipment (UE) for
`
`wireless communication, comprising: receiving a second radio signal; receiving a first radio signal;
`
`wherein the first radio signal is transmitted within a first time unit, a first bit block is used for
`
`generating the first radio signal, and the first radio signal comprises G multicarrier symbols; the
`
`second radio signal is transmitted within the first time unit, and the second radio signal is used for
`
`determining a time-domain resource occupied by the G multicarrier symbols; as for any one given
`
`multicarrier symbol of the G multicarrier symbols, the multi-antenna related receiving for the
`
`given multicarrier symbol is related to the relative position of a time-domain resource occupied by
`
`the given multicarrier symbol with respect to a first time point in time domain; when the time-
`
`domain resource occupied by the given multicarrier symbol is behind the first time point, the
`
`14
`
`Samsung Exhibit 1017, Page 14 of 26
`
`

`

`second radio signal is used for determining the multi-antenna related receiving for the given
`
`multicarrier symbol; and when the time-domain resource occupied by the given multicarrier
`
`symbol is before the first time point, the multi-antenna related receiving for the given multicarrier
`
`symbol is related to the multi-antenna related receiving for the second radio signal; the first time
`
`point is one time point within the first time unit; and G is a positive integer.
`
`41.
`
`For example, Defendants have and continue to directly infringe at least claim 1 of
`
`the ’081 Patent by making, using, offering to sell, selling, and/or importing into the United States
`
`products that implement the 5G standards, such as the Accused Products (e.g., 5G mobile handsets,
`
`tablets, and notebooks). For example, the Galaxy Z Fold3 5G operates on 5G networks and
`
`includes firmware for implementing 3rd Generation Partnership Product (3GPP) specifications).
`
`42.
`
`The Accused Products perform a method in a User Equipment (e.g., Galaxy Z Fold3
`
`5G) for wireless communication, comprising: receiving a second radio signal (e.g., DL DCI);
`
`receiving a first radio signal (e.g., PDSCH); wherein the first radio signal is transmitted within a
`
`first time unit, a first bit block is used for generating the first radio signal, and the first radio signal
`
`comprises G multicarrier symbols; the second radio signal is transmitted within the first time unit,
`
`and the second radio signal is used for determining a time-domain resource (e.g., time offset)
`
`occupied by the G multicarrier symbols; as for any one given multicarrier symbol of the G
`
`multicarrier symbols, the multi-antenna related receiving for the given multicarrier symbol is
`
`related to the relative position of a time-domain resource occupied by the given multicarrier
`
`symbol with respect to a first time point (e.g., reception time of DCL DCI delayed by Threshold-
`
`Sched-Offset) in time domain; when the time-domain resource occupied by the given multicarrier
`
`symbol is behind the first time point, the second radio signal is used for determining the multi-
`
`antenna related receiving for the given multicarrier symbol; and when the time-domain resource
`
`15
`
`Samsung Exhibit 1017, Page 15 of 26
`
`

`

`occupied by the given multicarrier symbol is before the first time point, the multi-antenna related
`
`receiving for the given multicarrier symbol is related to the multi-antenna related receiving for the
`
`second radio signal; the first time point is one time point within the first time unit; and G is a
`
`positive integer.
`
`43.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’081 Patent, as provided by 35 U.S.C. § 271(b), by inducing infringement by others,
`
`such as Samsung’s customers and end-users, in this District and elsewhere in the United States.
`
`For example, Samsung’s customers and end-users directly infringe, either literally or under the
`
`doctrine of equivalents, through their use of the inventions claimed in the ’081 Patent. Samsung
`
`induces this direct infringement through its affirmative acts of manufacturing, selling, distributing,
`
`and/or otherwise making available
`
`the Accused Products, and providing instructions,
`
`documentation, and other information to customers and end-users suggesting that they use the
`
`Accused Products in an infringing manner, including technical support, marketing, product
`
`manuals, advertisements, and online documentation. Because of Samsung’s inducement,
`
`Samsung’s customers and end-users use the Accused Products in a way Samsung intends and they
`
`directly infringe the ’081 Patent. Samsung performs these affirmative acts with knowledge of the
`
`’081 Patent and with the intent, or willful blindness, that the induced acts directly infringe the ’081
`
`Patent.
`
`44.
`
`Samsung has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’081 Patent, as provided by 35 U.S.C. § 271(c), by contributing to direct infringement
`
`by others, such as customers and end-users, in this District and elsewhere in the United States.
`
`Samsung’s affirmative acts of selling and offering to sell the Accused Products in this District and
`
`elsewhere in the United States and causing the Accused Produ