Samsung Electronics America Inc v. Akhavan

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Movants: Samsung Electronics America, Inc. (New York) and Samsung Electronics Co., Ltd. (Republic of Korea)
  • Non-movants: Hertsel Akhavan (New York) and Feridoon Ghassabian (New York)
  • Movants' Counsel: The Law Offices of Robert C. Brady, P.C.; Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
• Case Identification: 2:26-cv-00584, E.D.N.Y., 02/03/2026
• Venue Allegations: Venue is asserted in the Eastern District of New York because it is the district where discovery from the non-parties is to take place, pursuant to Federal Rule of Civil Procedure 37(a)(2).
• Core Dispute: Movants seek a court order to compel two non-parties to comply with discovery subpoenas for deposition testimony related to a separate, ongoing patent infringement lawsuit in the Eastern District of Texas.
• Technical Context: The underlying patent infringement dispute involves technology for data entry on mobile devices, combining keyboard inputs with other modalities like voice recognition to improve user interaction on devices with limited space.
• Key Procedural History: This action is an ancillary proceeding related to Keyless Licensing LLC v. Samsung Elecs. Am., Inc., filed in the Eastern District of Texas. In that case, Keyless Licensing accuses Samsung of infringing three patents. Samsung seeks to depose the non-movants in this New York action to obtain testimony regarding prior patent transfers and commercialization efforts, which Samsung asserts are relevant to calculating potential damages in the Texas litigation.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

The complaint does not assert any patents-in-suit for infringement. It references U.S. Patent No. 11,503,144 as one of three patents at issue in an ancillary patent infringement case (Keyless Licensing LLC v. Samsung, E.D. Tex.) Compl. ¶11 The following analysis is based on the '144 Patent, which is the only patent referenced by number in the complaint.

U.S. Patent No. 11,503,144 - "SYSTEMS TO ENHANCE DATA ENTRY IN MOBILE AND FIXED ENVIRONMENT"

• Patent Identification: U.S. Patent No. 11,503,144, titled "SYSTEMS TO ENHANCE DATA ENTRY IN MOBILE AND FIXED ENVIRONMENT," issued November 15, 2022.

The Invention Explained

• Problem Addressed: The patent's background describes the inefficiency of data entry methods on electronic devices with a limited number of keys, such as the multi-press system on traditional telephone keypads, and also notes the drawbacks of voice-only recognition systems '144 Patent, col. 1:33-64
• The Patented Solution: The invention proposes a multi-modal data entry system that combines a limited number of keys with other input methods, primarily voice recognition, to enter data '144 Patent, abstract For example, a user could press a key corresponding to a group of letters while simultaneously speaking to select a specific letter or word, aiming to provide a faster and more intuitive data entry method than prior art systems '144 Patent, col. 2:1-20 The patent discloses numerous embodiments, including keypads integrated into mobile phones, mice, and wearable devices '144 Patent, Figs. 1, 16, 23A-C
• Technical Importance: The technology aimed to improve the speed and ergonomics of text entry on compact mobile devices, a significant challenge during the transition from feature phones to smartphones.

Key Claims at a Glance

The complaint does not assert any specific claims of the '144 Patent. For illustrative purposes, an analysis of the first independent claim is provided below.

• Independent Claim 1:
  • A mobile phone device, comprising:
  • a practically rectangular shaped housing;
  • a processor, a display unit, a microphone and a speaker, wherein said mobile phone components of a mobile phone are integrated;
  • said housing having a front surface, a back surface and four side surfaces, wherein a length of the front surface of said mobile phone corresponds to the distance between the ear and the mouth of a user;
  • wherein a length of the front surface is substantially shorter than the length and wherein the housing has a thin thickness;
  • wherein said display unit adapted to display unit practically covers the entire front surface of said housing;
  • wherein said mobile phone does not include a physical key on the front surface; and
  • wherein said components of the mobile phone are integrated within said housing such that none of said components is noticeably extended out from said housing.

III. The Accused Instrumentality

The complaint is a motion to compel discovery and does not allege patent infringement (Compl. ¶¶29, 41). Therefore, it does not identify any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint makes no allegations of patent infringement and does not contain a claim chart or provide any theory of infringement. No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

As the complaint does not allege infringement or identify disputed claim limitations, it provides no basis for an analysis of key terms for construction.

VI. Other Allegations

The complaint does not allege indirect infringement or willful infringement. It is a motion to compel non-party compliance with discovery subpoenas (Compl. ¶¶29-40; Compl. ¶¶41-52).

VII. Analyst’s Conclusion: Key Questions for the Case

This filing is a procedural motion to compel discovery. However, the nature of the information sought reveals key questions that will likely be central to the underlying patent infringement litigation in the Eastern District of Texas.

• A core issue for the underlying infringement case, highlighted by this discovery dispute, will be one of patent valuation: what evidence of prior commercialization attempts or patent transfers exists that could inform a reasonable royalty or damages calculation for the asserted patents? (Compl. ¶¶26-27).
• A central validity question may arise from the patent's early priority date relative to its recent issuance: can the claims of the '144 Patent, which describe a modern smartphone form factor without a physical front-facing keyboard, withstand challenges based on intervening prior art developed in the nearly two decades between its priority date (2004) and issue date (2022)?
• A critical procedural question in this ancillary action is one of discovery scope: is the testimony sought from non-parties regarding a separate entity ("Classicom L.L.C.") sufficiently relevant to the damages model in the main patent case to overcome the burden on those non-parties? (Compl. ¶¶26-28).