• All Courts
  • Federal Courts
  • Bankruptcies
  • PTAB
  • ITC
Track Search
Export
Download All
Displaying 9-23 of 494 results

No. 44 ANSWER to 42 Amended Complaint, by SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG ELECTRONICS ...

Document California Institute of Technology v. SAMSUNG ELECTRONICS CO., LTD. et al, 2:21-cv-00446, No. 44 (E.D.Tex. May. 16, 2022)
Answer
Samsung admits that the website cited in Paragraph 15 Footnote 1 of the First Amended Complaint, when accessed on April 5, 2022, stated that SEA’s “Mobile hub in Plano centralizes innovation and enhances cross-functional collaboration for all teams dedicated to their largest mobile product line: smartphones” and its “[d]ivisions includ[e] Networks, Mobile Marketing, Computing and Wearables, and Product Management.” Samsung further admits that the April 6, 2018 website cited in Paragraph 15 Footnote 2 of the First Amended Complaint, when accessed on April 5, 2022, stated that as of the date of that article, “Samsung Electronics America’s North Texas offices will now be located in a newly redeveloped 216,000 square foot building” and “more than 1,000 regional employees from two current locations in Richardson and Plano will be relocated to the new location.” Samsung denies the remaining allegations in Paragraph 15 of the First Amended Complaint.
Samsung admits that the third-party website cited in Paragraph 45 Footnote 12, when accessed on April 5, 2022, stated on its face the principal office of the Wi-Fi Alliance was 10900-A Stonelake Boulevard Suite 195, Austin, TX 78759 USA and that it included the quoted language “the specific purpose of the corporation is to promote multi- vendor interoperability for markets including the enterprise, small office, and home and in particular the development, adoption and use of Wi-Fi technology and products and services relating thereto.” Samsung admits SEC became a Sponsor member of the Wi-Fi Alliance in 2011.
Samsung admits that the third-party website cited in Paragraph 46 Footnote 17 of the First Amended Complaint, when accessed on April 5, 2022, purported to be a certification identifying a date of June 16, 2020 for the SM-F707U product.
Samsung admits that the third-party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022 purported to be a certification identifying a date of September 4, 2019 for the SM-N976U product.
Samsung admits the third- party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022, included the terms “Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™ ac.” Samsung further admits the third-party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022, included the language “LDPC Rx” and “LDPC Tx” under the “Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™ ac” headings on the fourth page.
cite Cite Document

No. 42 AMENDED COMPLAINT (First Amended Complaint) against SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG ...

Document California Institute of Technology v. SAMSUNG ELECTRONICS CO., LTD. et al, 2:21-cv-00446, No. 42 (E.D.Tex. May. 2, 2022)
Complaint
Caltech is a world-renowned science and engineering research and education institution, where extraordinary faculty and students seek answers to complex questions, discover new knowledge, lead innovation, and transform our future.
Caltech investigates the most challenging, fundamental problems in science and technology in a singularly collegial, interdisciplinary atmosphere, while educating outstanding students to become creative members of society.
For example, a paper by Aline Roumy, Souad Guemghar, Giuseppe Caire, and Sergio Verdú praising these IRA codes was published in August 2004 in the IEEE Transactions on Information Theory.
One of the key improvements to the 802.11n version (finalized by IEEE in 2009 and providing the basis for Wi-Fi 4) of the standard involved a “High Throughput (HT)” mode that is implemented using specific LDPC (Low-Density Parity Check) error correction codes.
As another example, an AnandTech review of the Samsung Galaxy S5 shows “a Qualcomm Atheros QCA6174” Wi-Fi module.6 Upon information and belief, the “QCA6174” refers to or is similar to the previously mentioned QCA6174A chip and utilizes LDPC codes.
cite Cite Document

No. 19 ANSWER to 1 Complaint,, by SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG ELECTRONICS CO., LTD..(Smith, ...

Document California Institute of Technology v. SAMSUNG ELECTRONICS CO., LTD. et al, 2:21-cv-00446, No. 19 (E.D.Tex. Apr. 5, 2022)
Answer
Samsung admits that the website cited in Paragraph 15 Footnote 1 of the Complaint, when accessed on April 5, 2022, stated that SEA’s “Mobile hub in Plano centralizes innovation and enhances cross-functional collaboration for all teams dedicated to their largest mobile product line: smartphones” and its “[d]ivisions includ[e] Networks, Mobile Marketing, Computing and Wearables, and Product Management.” Samsung further admits that the April 6, 2018 website cited in Paragraph 15 Footnote 2 of the Complaint, when accessed on April 5, 2022, stated that as of the date of that article, “Samsung Electronics America’s North Texas offices will now be located in a newly redeveloped 216,000 square foot building” and “more than 1,000 regional employees from two current locations in Richardson and Plano will be relocated to the new location.” Samsung denies the remaining allegations in Paragraph 15 of the Complaint.
Samsung admits that, on its face, the ’552 patent purports to identify Dariush Divsalar, Robert J. McEliece, Hui Jin, and Fabrizio Pollara as inventors.
Samsung admits that the third-party website cited in Paragraph 47 Footnote 12, when accessed on April 5, 2022, stated on its face the principal office of the Wi-Fi Alliance was 10900- A Stonelake Boulevard Suite 195, Austin, TX 78759 USA and that it included the quoted language “the specific purpose of the corporation is to promote multi-vendor interoperability for markets including the enterprise, small office, and home and in particular the development, adoption and use of Wi-Fi technology and products and services relating thereto.” Samsung admits SEC became a Sponsor member of the Wi-Fi Alliance in 2011.
Samsung admits that the third-party website cited in Paragraph 48 Footnote 17 of the Complaint, when accessed on April 5, 2022, purported to be a certification identifying a date of June 16, 2020 for the SM-F707U product.
Samsung admits that the third-party website cited in Paragraph 49 Footnote 18 of the Complaint, when accessed on April 5, 2022 purported to be a certification identifying a date of September 4, 2019 for the SM-N976U product.
cite Cite Document

No. 62 REDACTION to 60 Sealed Response to Motion,, re 51 Sealed Patent Motion to Transfer to the Central ...

Document California Institute of Technology v. SAMSUNG ELECTRONICS CO., LTD. et al, 2:21-cv-00446, No. 62 (E.D.Tex. Aug. 19, 2022)
Introduction Samsung’s motion to transfer venue is built on a series of unsupported assertions that fail to coalesce in any way to warrant its requested relief.
This Court can readily dispense of Samsung’s motion to transfer venue on its face because Samsung cannot invoke of a Patent License Agreement (PLA) between two other parties.
In that case, defendant Universal entered into a Purchase Agreement to buy plaintiff William Alling’s company, Luminoptics, and to use its “best efforts” to manufacture electronic ballasts.
To avoid any confusion arising from this erroneous Certificate and consistent with the file history of the ’710 Patent, on September 30, 2011, Caltech and CE agreed to an Amendment – which superseded the original license – clarifying that .
Because Samsung is not a party to the PLA and cannot establish it is an intended third-party beneficiary, the Court cannot “presuppose a contractually valid ,” Atlantic Marine is inapposite, and a full § 1404 analysis must be undertaken.
cite Cite Document

No. 1 COMPLAINT FOR PATENT INFRINGEMENT against SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG ELECTRONICS ...

Document California Institute of Technology v. SAMSUNG ELECTRONICS CO., LTD. et al, 2:21-cv-00446, No. 1 (E.D.Tex. Dec. 3, 2021)
Complaint
Caltech is a world-renowned science and engineering research and education institution, where extraordinary faculty and students seek answers to complex questions, discover new knowledge, lead innovation, and transform our future.
Caltech investigates the most challenging, fundamental problems in science and technology in a singularly collegial, interdisciplinary atmosphere, while educating outstanding students to become creative members of society.
For example, a paper by Aline Roumy, Souad Guemghar, Giuseppe Caire, and Sergio Verdú praising these IRA codes was published in August 2004 in the IEEE Transactions on Information Theory.
One of the key improvements to the 802.11n version (finalized by IEEE in 2009 and providing the basis for Wi-Fi 4) of the standard involved a “High Throughput (HT)” mode that is implemented using specific LDPC (Low-Density Parity Check) error correction codes.
As another example, an AnandTech review of the Samsung Galaxy S5 shows “a Qualcomm Atheros QCA6174” Wi-Fi module.6 Upon information and belief, the “QCA6174” refers to or is similar to the previously mentioned QCA6174A chip and utilizes LDPC codes.
cite Cite Document

Hughes Communications, Inc. v. California Institute of Technology

Docket IPR2015-00061, Patent Trial and Appeal Board (Oct. 14, 2014)

cite Cite Docket

Hughes Communications, Inc. v. California Institute of Technology

Docket IPR2015-00081, Patent Trial and Appeal Board (Oct. 17, 2014)
Glenn Perry, Kalyan Deshpande, Trevor Jefferson, presiding
Case TypeInter Partes Review
Patent
8284833
Petitioner Hughes Communications, Inc.
Patent Owner California Institute of Technology
cite Cite Docket

11 Other Refund request: Petitioners Request for Post Institution Fees

Document IPR2023-00137, No. 11 Other Refund request - Petitioners Request for Post Institution Fees (P.T.A.B. Aug. 9, 2023)
On November 1, 2022, Samsung Electronics Co., Ltd. (“Samsung”) filed a Petition for Inter Partes Review seeking review of claims 1-4, 6-11, and 13-14 of U.S. Patent No. 8,284,833.
On May 4, 2023, the Patent Trial and Appeal Board issued its Decision Denying Institution of Inter Partes Review (Paper No. 10).
Payment of these Post-Institution fees was processed through PRPS on November 1, 2022 and charged to Deposit Account 506092.
Upon review and approval of this request, Petitioner respectfully requests that the Board credit the post-institution fee to Deposit Account 506092.
Attorneys for Petitioner Samsung Electronics Attorneysfor Petitioner Samsung Electronics Co., Ltd. Co., Ltd.
cite Cite Document

9 Other other: Patent Owners Pre Institution Sur Reply

Document IPR2023-00137, No. 9 Other other - Patent Owners Pre Institution Sur Reply (P.T.A.B. Mar. 17, 2023)
Petitioner’s new stipulation is crafted to ensure Petitioner can still base district court invalidity arguments on variations not materially different from the IPR challenge.
Moreover, Ericsson was decided prior to the Fintiv memo, which specified a Sotera stipulation sets the bar for eliminating concerns of overlapping efforts.
By the expected May institution decision date, substantial pretrial work related to validity will be complete: fact discovery will be closed, expert reports will be served, and all dispositive motions will be due within a month.
The Markman order confirmed the commonsense notion that invalidity arguments are being actively litigated and played a role in claim construction.
Caltech never “disavowed” an admission that memory locations or indices were known; the POPR pointed out, among other deficiencies, that the petition conjured virtually every limitation of the independent claims from nowhere, presenting a case disconnected from the prior art.
cite Cite Document

8 Pet Reply to PO Resp: Petitioners Reply to Patent Owners Preliminary Response

Document IPR2023-00137, No. 8 Pet Reply to PO Resp - Petitioners Reply to Patent Owners Preliminary Response (P.T.A.B. Mar. 10, 2023)
Factor 4: Petitioner hereby stipulates, if the IPR is instituted, not to pursue invalidity challenges to the ’833 Patent in the parallel district court lawsuit that rely on any reference used in the grounds of the Petition (Kobayashi and Rorabaugh).
Here, however, Samsung’s “intermediate” stipulation above ensures that the Board will not address prior art or arguments presented in district court.
Though Samsung’s initial stay request was denied, the Eastern District of Texas has indicated that pre-institution denials are a matter of course rather than a merits judgment: “In this district, courts usually deny motions for stay when the PTAB has not acted on a petition for inter partes review.” Perdiemco LLC v. Telular Corp., No. 2:16-CV-01408-JRG-RSP, 2017 WL 2444736, at *2 (E.D.
Factor 6: To the extent the panel concludes that the Fintiv factors compel a discretionary denial, the highly meritorious Petition “strengthen[s] the patent system by allowing the review of patents challenged with a sufficiently strong initial merits showing of unpatentability.” CommScope Tech. LLC v. Dali Wireless, Inc., IPR2022-01242, Paper 23 at 4 (Feb. 27, 2023) (precedential).
To argue otherwise, PO resorts to disavowing its previous admission that memory locations and indexes were known in the art (POPR, 3-5; see also Pet., 14-15).
cite Cite Document

7 POPR filed: Patent Owners Preliminary Response

Document IPR2023-00137, No. 7 POPR filed - Patent Owners Preliminary Response (P.T.A.B. Feb. 10, 2023)
However, this fails to address the particular modifications Petitioner proposes making for Kobayashi (including the specific choices regarding what memory elements are and are not stored and the introduction of the interleaver mapping array).
Further undermining Petitioner’s flawed arguments regarding motivation to modify Kobayashi and reasonable expectation of success, the Board has consistently found that the field of error-correcting codes was highly unpredictable.
As an initial matter, similar to the deficiencies discussed above regarding the interleaver mapping array, Petitioner again fails to explain how a POSA could be motivated to incorporate a modification taught nowhere in the prior art.
The PTAB also instituted trial for multiple patents in the same family directed to the same IRA codes and issued final written decisions upholding every claim subject to an obviousness challenge.
And in Coolit Systems, Inc. v. Asetek Danmark A/S, the merits were “substantively strong” because similar claims had been invalidated in an IPR of a family member based on the same asserted art, and there were delays caused by Patent Owner.
cite Cite Document

5 Notice Mandatory Notice: Notice Mandatory Notice

Document IPR2023-00137, No. 5 Notice Mandatory Notice - Notice Mandatory Notice (P.T.A.B. Nov. 21, 2022)

cite Cite Document

6 Notice Power of Attorney: Notice Power of Attorney

Document IPR2023-00137, No. 6 Notice Power of Attorney - Notice Power of Attorney (P.T.A.B. Nov. 21, 2022)

cite Cite Document

3 Notice Power of Attorney: Samsung Electronics America, Co Power of Attorney

Document IPR2023-00137, No. 3 Notice Power of Attorney - Samsung Electronics America, Co Power of Attorney (P.T.A.B. Nov. 1, 2022)

cite Cite Document

1 Petition as filed: Petition for Inter Partes review

Document IPR2023-00137, No. 1 Petition as filed - Petition for Inter Partes review (P.T.A.B. Nov. 1, 2022)

cite Cite Document
<< 1 2 3 4 5 ... >>