`RFCyber CORP.,
`
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`
`Plaintiff,
`
`
`Defendants.
`
`
`
`
`
`Civil Action No. 2-20-cv-00335-JRG
`
`
`PATENT CASE
`
`
`JURY TRIAL DEMANDED
`
`Case 2:20-cv-00335-JRG-RSP Document 18 Filed 02/11/21 Page 1 of 15 PageID #: 91
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`
`DEFENDANTS SAMSUNG ELECTRONICS CO., LTD.’S AND SAMSUNG
`ELECTRONICS AMERICA, INC.’S ANSWER AND AFFIRMATIVE DEFENSES,
`TO PLAINTIFF RFCYBER CORP.’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung Electronics America,
`
`Inc. (“SEA”) (collectively, “Samsung” or “Defendants”), by and through their counsel, hereby
`
`respond to Plaintiff RFCyber Corp.’s (“RFCyber” or “Plaintiff”) Complaint For Patent
`
`Infringement (“Complaint”) as follows:
`
`THE PARTIES
`
`1.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 1 of the Complaint and, on that basis, denies each such
`
`allegation.
`
`2.
`
`Samsung admits that SEC is a South Korean corporation with a principal place of
`
`business at 129 Samsung-Ro, Yeongtong-Gu, Suwon-Si, Gyeonggi-Do, 443-742, Republic of
`
`Korea. Samsung denies the remaining allegations in Paragraph 2 of the Complaint.
`
`3.
`
`Samsung admits that SEA is a New York corporation having a principal place of
`
`business at 85 Challenger Road, Ridgefield Park, New Jersey 07660, and maintains an office in
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`Plano, Texas. The cited webpage (https://news.samsung.com/us/samsung-electronics-america-
`
`open-flagship-north-texas-campus/) speaks for itself and no further response is required. Samsung
`
`further admits that SEA has designated CT Corporation System, 1999 Bryan Street, Suite 900,
`
`Dallas, Texas 75201-3136, as its agent for service of process. Samsung denies that SEA has
`
`corporate offices at 1303 East Lookout Drive, Richardson, Texas 75082 and 2800 Technology
`
`Drive, Suite 200, Plano, Texas 75074.
`
`4.
`
`Samsung admits that various entities sell Samsung devices in the State of Texas,
`
`including in the Eastern District of Texas. Samsung denies the remaining allegations in Paragraph
`
`4 of the Complaint.
`
`JURISDICTION AND VENUE
`
`5.
`
`Samsung admits that the Complaint purports to state a claim for patent infringement
`
`under the patent laws of the United States, 35 U.S.C. § 1, et seq., but denies that it has committed
`
`any acts of infringement as alleged by RFCyber. Samsung does not contest that this Court has
`
`subject matter jurisdiction over RFCyber’s claim for patent infringement.
`
`6.
`
`Samsung denies that it is in any way liable or indebted to Plaintiff under these or
`
`any other claims.
`
`7.
`
`Samsung admits that this Court has personal jurisdiction over Samsung. Samsung
`
`also admits that SEA sells products to customers in this District, but denies that Samsung has
`
`committed any acts of infringement as alleged by RFCyber. Samsung further denies the remaining
`
`allegations in Paragraph 7 of the Complaint.
`
`8.
`
`For purposes of this action only, Samsung does not contest that venue is proper in
`
`this District, but denies that Samsung has committed any acts of infringement as alleged by
`
`RFCyber. Samsung admits that SEA has a place of business, and sells products to customers, in
`
`this District. Samsung denies that venue in this District is convenient and Samsung reserves the
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`right to seek transfer to a more appropriate or convenient forum. Samsung denies the remaining
`
`allegations in Paragraph 8 of the Complaint.
`
`PATENTS-IN-SUIT
`
`9.
`
`Samsung admits that U.S. Patent No. 8,118,218 (the “ʼ218 patent”) is entitled
`
`“Method and Apparatus for Providing Electronic Purse” and appears on its face to have issued on
`
`February 21, 2012. Samsung also admits that Paragraph 9 references the ʼ218 patent at
`
`https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=08118218. Samsung denies that the ʼ218
`
`patent was duly or legally issued.
`
`10.
`
`Samsung admits that U.S. Patent No. 8,448,855 (the “ʼ855 patent”) is entitled
`
`“Method and Apparatus for Funding an Electronic Purse” and appears on its face to have issued
`
`on May 28, 2013. Samsung also admits that Paragraph 10 references the ʼ855 patent at
`
`https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=08448855. Samsung denies that the ʼ855
`
`patent was duly or legally issued.
`
`11.
`
`Samsung admits that U.S. Patent No. 9,189,787 (the “ʼ787 patent”) is entitled
`
`“Method and Apparatus for Conducting E-Commerce and M-Commerce” and appears on its face
`
`to have issued on November 17, 2015. Samsung also admits that Paragraph 11 references the ʼ787
`
`patent at https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=09189787. Samsung denies that the
`
`ʼ787 patent was duly or legally issued.
`
`12.
`
`Samsung admits that U.S. Patent No. 9,240,009 (the “ʼ009 patent”) is entitled
`
`“Mobile Devices for Commerce Over Unsecured Networks” and appears on its face to have issued
`
`on January 19, 2016. Samsung also admits that Paragraph 12 references the ʼ009 patent at
`
`https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=09240009. Samsung denies that the ʼ009
`
`patent was duly or legally issued.
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`13.
`
`Samsung admits that U.S. Patent No. 10,600,046 (the “ʼ046 patent”) is entitled
`
`“Method and Apparatus for Mobile Payments” and appears on its face to have issued on March
`
`24, 2020. Samsung also admits
`
`that Paragraph 13 references
`
`the ʼ046 patent at
`
`https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=10600046. Samsung denies that the ʼ046
`
`patent was duly or legally issued.
`
`14.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 14 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`INFRINGEMENT ALLEGATIONS
`
`15.
`
`The contents of the Patents-in-Suit speak for itself, thus, no response is required.
`
`To the extent necessary, Samsung denies the allegations in Paragraph 15 of the Complaint.
`
`16.
`
`17.
`
`18.
`
`Samsung denies the allegations in Paragraph 16 of the Complaint.
`
`Samsung denies the allegations in Paragraph 17 of the Complaint.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 18 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`COUNT I
`(Infringement of the ’218 Patent)
`
`19.
`
`Samsung repeats and incorporates by reference its responses to Paragraphs 1
`
`through 18 of the Complaint as if fully set forth herein.
`
`20.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 20 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`21.
`
`Samsung denies the allegations in Paragraph 21 of the Complaint.
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`22.
`
`23.
`
`24.
`
`Samsung denies the allegations in Paragraph 22 of the Complaint.
`
`Samsung denies the allegations in Paragraph 23 of the Complaint.
`
`Paragraph 24 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 24 of the Complaint.
`
`25.
`
`Paragraph 25 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 25 of the Complaint.
`
`26.
`
`Paragraph 26 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 26 of the Complaint.
`
`27.
`
`Paragraph 27 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 27 of the Complaint.
`
`28.
`
`Paragraph 28 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 28 of the Complaint.
`
`29.
`
`Paragraph 29 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 29 of the Complaint.
`
`30.
`
`Paragraph 30 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 30 of the Complaint.
`
`31.
`
`Samsung admits that it was made aware of the ʼ218 patent through service of the
`
`Complaint. Samsung denies the remaining allegations in Paragraph 31 of the Complaint.
`
`32.
`
`33.
`
`34.
`
`35.
`
`Samsung denies the allegations in Paragraph 32 of the Complaint.
`
`Samsung denies the allegations in Paragraph 33 of the Complaint.
`
`Samsung denies the allegations in Paragraph 34 of the Complaint.
`
`Samsung denies the allegations in Paragraph 35 of the Complaint.
`
`COUNT II
`(Infringement of the ’787 Patent)
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`36.
`
`Samsung repeats and incorporates by reference its responses to Paragraphs 1
`
`through 18 [sic] of the Complaint as if fully set forth herein.
`
`37.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 37 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`38.
`
`39.
`
`40.
`
`41.
`
`Samsung denies the allegations in Paragraph 38 of the Complaint.
`
`Samsung denies the allegations in Paragraph 39 of the Complaint.
`
`Samsung denies the allegations in Paragraph 40 of the Complaint.
`
`Paragraph 41 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the remaining allegations in Paragraph 41 of the
`
`Complaint.
`
`42.
`
`Paragraph 42 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 42 of the Complaint.
`
`43.
`
`Paragraph 43 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 43 of the Complaint.
`
`44.
`
`Paragraph 44 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 44 of the Complaint.
`
`45.
`
`Paragraph 45 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 45 of the Complaint.
`
`46.
`
`Paragraph 46 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 46 of the Complaint.
`
`47.
`
`Samsung admits that it was made aware of the ʼ787 patent through service of the
`
`Complaint. Samsung denies the remaining allegations in Paragraph 47 of the Complaint.
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`48.
`
`49.
`
`50.
`
`51.
`
`Samsung denies the allegations in Paragraph 48 of the Complaint.
`
`Samsung denies the allegations in Paragraph 49 of the Complaint.
`
`Samsung denies the allegations in Paragraph 50 of the Complaint.
`
`Samsung denies the allegations in Paragraph 51 of the Complaint.
`
`COUNT III
`(Infringement of the ’855 Patent)
`
`52.
`
`Samsung repeats and incorporates by reference its responses to Paragraphs 1
`
`through 18 [sic] of the Complaint as if fully set forth herein.
`
`53.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 53 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`54.
`
`55.
`
`56.
`
`57.
`
`Samsung denies the allegations in Paragraph 54 of the Complaint.
`
`Samsung denies the allegations in Paragraph 55 of the Complaint.
`
`Samsung denies the allegations in Paragraph 56 of the Complaint.
`
`Paragraph 57 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 57 of the Complaint.
`
`58.
`
`Paragraph 58 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 58 of the Complaint.
`
`59.
`
`Paragraph 59 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 59 of the Complaint.
`
`60.
`
`Paragraph 60 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 60 of the Complaint.
`
`61.
`
`Paragraph 61 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 61 of the Complaint.
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`62.
`
`Paragraph 62 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 62 of the Complaint.
`
`63.
`
`Paragraph 63 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 63 of the Complaint.
`
`64.
`
`Paragraph 64 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 64 of the Complaint.
`
`65.
`
`Samsung admits that it was made aware of the ʼ855 patent through service of the
`
`Complaint. Samsung denies the remaining allegations in Paragraph 65 of the Complaint.
`
`66.
`
`67.
`
`68.
`
`69.
`
`Samsung denies the allegations in Paragraph 66 of the Complaint.
`
`Samsung denies the allegations in Paragraph 67 of the Complaint.
`
`Samsung denies the allegations in Paragraph 68 of the Complaint.
`
`Samsung denies the allegations in Paragraph 69 of the Complaint.
`
`COUNT IV
`(Infringement of the ’009 Patent)
`
`70.
`
`Samsung repeats and incorporates by reference its responses to Paragraphs 1
`
`through 18 [sic] of the Complaint as if fully set forth herein.
`
`71.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 71 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`72.
`
`73.
`
`74.
`
`75.
`
`Samsung denies the allegations in Paragraph 72 of the Complaint.
`
`Samsung denies the allegations in Paragraph 73 of the Complaint.
`
`Samsung denies the allegations in Paragraph 74 of the Complaint.
`
`Paragraph 75 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 75 of the Complaint.
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`76.
`
`Paragraph 76 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 76 of the Complaint.
`
`77.
`
`Paragraph 77 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 77 of the Complaint.
`
`78.
`
`Paragraph 78 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 78 of the Complaint.
`
`79.
`
`Paragraph 79 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 79 of the Complaint.
`
`80.
`
`Paragraph 80 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 80 of the Complaint.
`
`81.
`
`Paragraph 81 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 81 of the Complaint.
`
`82.
`
`Samsung admits that it was made aware of the ʼ009 patent through service of the
`
`Complaint. Samsung denies the remaining allegations in Paragraph 82 of the Complaint.
`
`83.
`
`84.
`
`85.
`
`86.
`
`Samsung denies the allegations in Paragraph 83 of the Complaint.
`
`Samsung denies the allegations in Paragraph 84 of the Complaint.
`
`Samsung denies the allegations in Paragraph 85 of the Complaint.
`
`Samsung denies the allegations in Paragraph 86 of the Complaint.
`
`COUNT V
`(Infringement of the ’046 Patent)
`
`87.
`
`Samsung repeats and incorporates by reference its responses to Paragraphs 1
`
`through 18 [sic] of the Complaint as if fully set forth herein.
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`88.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 88 of the Complaint, and, on that basis, denies each such
`
`allegation.
`
`89.
`
`90.
`
`91.
`
`92.
`
`Samsung denies the allegations in Paragraph 89 of the Complaint.
`
`Samsung denies the allegations in Paragraph 90 of the Complaint.
`
`Samsung denies the allegations in Paragraph 91 of the Complaint.
`
`Paragraph 92 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 92 of the Complaint.
`
`93.
`
`Paragraph 93 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 93 of the Complaint.
`
`94.
`
`Paragraph 94 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 94 of the Complaint.
`
`95.
`
`Paragraph 95 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 95 of the Complaint.
`
`96.
`
`Paragraph 96 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 96 of the Complaint.
`
`97.
`
`Paragraph 97 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 97 of the Complaint.
`
`98.
`
`Paragraph 98 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 98 of the Complaint.
`
`99.
`
`Paragraph 99 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 99 of the Complaint.
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`100. Paragraph 100 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 100 of the Complaint.
`
`101. Paragraph 101 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 101 of the Complaint.
`
`102. Paragraph 102 contains legal conclusions to which no answer is required. To the
`
`extent an answer is required, Samsung denies the allegations in Paragraph 102 of the Complaint.
`
`103. Samsung admits that it was made aware of the ʼ046 patent through service of the
`
`Complaint. Samsung denies the remaining allegations in Paragraph 103 of the Complaint.
`
`104. Samsung denies the allegations in Paragraph 104 of the Complaint.
`
`105. Samsung denies the allegations in Paragraph 105 of the Complaint.
`
`106. Samsung denies the allegations in Paragraph 106 of the Complaint.
`
`107. Samsung denies the allegations in Paragraph 107 of the Complaint.
`
`DEMAND FOR JURY TRIAL
`
`RFCyber’s Jury Demand does not require admission or denial.
`
`RESPONSE TO PRAYER FOR RELIEF
`
`With respect to RFCyber’s Prayer for Relief, Samsung denies that RFCyber is entitled to
`
`the judgment and relief requested in Paragraphs a-h.
`
`AFFIRMATIVE DEFENSES
`
`Without admitting that it bears the burden of proof to any of them, Samsung asserts the
`
`following defenses in response to the allegations in the Complaint.
`
`FIRST DEFENSE
`(NON-INFRINGEMENT)
`
`Samsung does not directly infringe and has not directly infringed, and does not indirectly
`
`infringe and has not indirectly infringed, by contributing to infringement or inducing infringement
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`of, any valid and enforceable claim of U.S. Patent Nos. 8,118,218 (the “’218 patent”), 8,448,855
`
`(the “ʼ855 patent”), 9,189,787 (the “ʼ787 patent”), 9,240,009 (the “ʼ009 patent”), and 10,600,046
`
`(the “ʼ046 patent”) (collectively, the “Patents-in-Suit”).
`
`SECOND DEFENSE
`(INVALIDITY)
`
`The Patents-in-Suit are each invalid for failure to comply with the requirements of Title 35
`
`of the United States Code, including, for example §§ 101, 102, 103, and 112.
`
`THIRD DEFENSE
`(NOTICE, DAMAGES AND COSTS)
`
`RFCyber is not entitled to any damages, and if any damages are available, they would only
`
`be available after filing suit, they should not include lost profits and should be limited to a
`
`reasonable royalty, and/or are also statutorily limited including, but not limited to, under 35 U.S.C.
`
`§ 287.
`
`Upon information and belief, RFCyber is barred from recovering costs in connection with
`
`this action under 35 U.S.C. § 288.
`
`FOURTH DEFENSE
`(PROSECUTION HISTORY ESTOPPEL)
`
`RFCyber is estopped from construing any valid claim of the Patents-in-Suit to cover or
`
`include, either literally or by application of the doctrine of equivalents, any of Samsung’s products,
`
`methods, or systems due to prosecution history estoppel.
`
`FIFTH DEFENSE
`(EQUITY)
`
`RFCyber is barred in whole or in part under principles of equity, including without
`
`limitation, acquiescence, prosecution laches, estoppel, waiver, misconduct, patent misuse, unfair
`
`competition, unclean hands, and/or other equitable defenses.
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`SIXTH DEFENSE
`(FAILURE TO STATE A CLAIM)
`
`With respect to each purported claim for relief alleged in the Complaint, RFCyber fails to
`
`allege facts sufficient to state a claim against Samsung upon which relief may be granted.
`
`SEVENTH DEFENSE
`(LACK OF STANDING)
`
`To the extent that RFCyber does not hold all rights, title and interest in any of the Patents-
`
`in-Suit, RFCyber lacks standing to sue for infringement for such patent(s).
`
`EIGHTH DEFENSE
`(NOT AN EXCEPTIONAL CASE)
`
`RFCyber cannot prove that this is an exceptional case justifying an award of attorney fees
`
`pursuant to 35 U.S.C. § 285.
`
`NINTH DEFENSE
`(NO WILLFUL INFRINGEMENT)
`
`RFCyber is not entitled to enhanced damages under 35 U.S.C. § 284 because Samsung has
`
`not intentionally, wilfully, or deliberately infringed any claim of the Patents-in-Suit, or acted with
`
`egregious conduct.
`
`
`
`Wherefore, Samsung prays that this Court enter judgment:
`
`PRAYER FOR RELIEF
`
`a.
`
`b.
`
`c.
`
`d.
`
`Dismissing the Complaint with prejudice;
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`Finding that this case is exceptional pursuant to 35 U.S.C. § 285 and awarding
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`Samsung its attorneys’ fees incurred in this action;
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`For an award of all costs incurred by Samsung in this action; and
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`For all such other and further relief as this Court deems just and equitable.
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`ACTIVE 55175077v4
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`13
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`Case 2:20-cv-00335-JRG-RSP Document 18 Filed 02/11/21 Page 14 of 15 PageID #: 104
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`JURY DEMAND
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`Samsung demands a trial by jury for all issues so triable.
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`Dated: February 11, 2021
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`By: /s/ Allan A. Kassenoff
`Richard A. Edlin
`Allan A. Kassenoff
`Jeffrey Colin
`Vimal M. Kapadia
`GREENBERG TRAURIG, LLP
`MetLife Building, 200 Park Avenue
`New York, NY 10002
`Telephone: (212) 801-9200
`Facsimile: (212) 801-6400
`Email: edlinr@gtlaw.com
`Email: kassenoffa@gtlaw.com
`Email: colinj@gtlaw.com
`Email: kapadiav@gtlaw.com
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`Melissa R. Smith
`State Bar No. 24001351
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`Email: melissa@gillamsmithlaw.com
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`Counsel for Defendants Samsung Electronics Co.,
`Ltd. and Samsung Electronics America, Inc.
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`ACTIVE 55175077v4
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`Case 2:20-cv-00335-JRG-RSP Document 18 Filed 02/11/21 Page 15 of 15 PageID #: 105
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`CERTIFICATE OF SERVICE
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` I hereby certify that on the 11th day of February 2021, I caused the above Defendants
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`Samsung Electronics Co., Ltd.’s and Samsung Electronics America, Inc.’s Answer and
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`Affirmative Defenses to Plaintiff RFCyber Corp.’s Complaint for Patent Infringement to be served
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`on all parties in this action via the Court’s CM/ECF system.
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`/s/ Melissa R. Smith
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`ACTIVE 55175077v4
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`15
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