Plaintiff MIMO Research, LLC filed a complaint on Friday in the Eastern District of Texas against defendant Samsung Electronics America, Inc. and Samsung Electronics Co., LTD (collectively, Samsung) alleging that the defendants infringed on five patents held by the plaintiff when they used patent-protected wireless communications methods and more in their products.
According to the complaint, the plaintiff is a research company that owns a variety of patents which cover wireless communication, powerline networking, and more. The complaint notes that reputable companies like Apple and Nokia have cited the patents held by the plaintiff.
The plaintiff alleges that Samsung is offering to sell and selling products and/or services that infringe the patents-in-suit. MIMO Research asserts that the defendants infringed on the five patents-in-suit by “commercializing, marketing, selling, distributing, testing, and servicing certain Accused Products.” Accordingly, these Accused Products include, for example, the Samsung Galaxy S21 5G, the Galaxy S21+5G and the Galaxy S21 Ultra 5G.
The patents-in-suit protect specific systems for wireless multiple-input multiple-output communication devices, dual-mode ultra wideband and wireless local area network communications, as well as other methods of wireless communication.
The defendant manufactures and markets products that purportedly employ methods protected by the plaintiff. MIMO Research asserts that these actions constitute patent infringement and that Samsung has injured the plaintiff and is liable. The plaintiff further alleges that Samsung “specifically intended and was aware that the normal and customary use of the accused products” would infringe on the patents-in-suit.
The complaint cites five counts of infringement. Plaintiff MIMO Research is seeking favorable judgment on each count of infringement, damages, judgment that the infringement was “willful, wanton, malicious, bad-faith, deliberate,” a trial by jury and any other relief that the court deems the plaintiff entitled to.
The plaintiff is represented by Berger & Hipskind LLP.