Missed Call LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Missed Call, LLC (Texas)
  • Defendant: Samsung Electronics America, Inc. (New York)
  • Plaintiff's Counsel: Ramey LLP
• Case Identification: 2:26-cv-00155, E.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant's systems, products, and services that provide notifications for missed telephone calls infringe a patent related to distinguishing the cause of a missed call.
• Technical Context: The technology concerns telecommunications features on user devices that analyze network signals to determine whether a missed call was terminated by the caller or by a network timeout, and to present this information to the user.
• Key Procedural History: The complaint states that Plaintiff is a "non-practicing entity." It also notes that Plaintiff and its predecessors have entered into settlement licenses with other entities in the past, but asserts these licenses did not grant rights to produce a patented article and thus do not trigger patent marking requirements.

Case Timeline

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

U.S. Patent No. 9,531,872 - "Communication Apparatus For Providing An Indication About A Missed Call, And Method Thereof," issued December 27, 2016

The Invention Explained

• Problem Addressed: The patent identifies a deficiency in conventional missed call notifications, which do not inform the user why a call was missed (i.e., whether the caller hung up or the call timed out) ʼ872 Patent, col. 2:11-17 Prior art solutions that counted the number of rings were deemed unreliable indicators of a call's importance or urgency ʼ872 Patent, col. 2:18-23
• The Patented Solution: The invention is a communication device that analyzes specific network data to determine the reason for a missed call ʼ872 Patent, abstract When a call is disconnected, the device extracts a "cause value" from a "cause information element" sent by the telecommunications network ʼ872 Patent, col. 4:10-16 This value explicitly states whether the call was terminated by the caller (e.g., "NORMAL CLEARING") or by the network (e.g., "RECOVERY ON TIME EXPIRY") ʼ872 Patent, col. 4:17-22 ʼ872 Patent, col. 4:43-46 The device then provides a specific indication to the user based on this cause, distinguishing a potentially urgent, network-terminated call from a less urgent, user-terminated one ʼ872 Patent, col. 4:35-40 ʼ872 Patent, col. 4:47-52
• Technical Importance: This approach provides a direct, reliable method for assessing the potential urgency of a missed call by using standardized network protocol data rather than ambiguous heuristics like ring duration ʼ872 Patent, col. 2:11-17

Key Claims at a Glance

• The complaint asserts infringement of claims 1-13 Compl. ¶9 Independent claim 1 is representative.
• Independent Claim 1 requires:
  • A communication apparatus comprising receiving means, a control unit, output means, and processing means.
  • The processing means extracts a "cause value" from a "cause information element" sent from a network.
  • When a caller ends the call, the cause value indicates this, and the apparatus outputs an indication that the call was "caused by the caller."
  • When the network ends the call, the cause value indicates this, and the apparatus outputs an indication that the call was "caused by the network and was urgent."
• The complaint asserts infringement of dependent claims 2-13, which add further limitations Compl. ¶9

III. The Accused Instrumentality

Product Identification

The complaint broadly accuses "systems, products, and services" maintained, operated, and administered by Samsung that "facilitate providing of an indication of a missed telephone call" Compl. ¶9 A sales brochure for a "Samsung SCC Pro" product is cited as an example Compl. ¶11

Functionality and Market Context

The complaint does not provide specific technical details about how the accused Samsung products operate. It alleges in a conclusory manner that they perform the functions claimed in the '872 Patent Compl. ¶9 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in "Exhibit A" but does not attach it Compl. ¶10 The infringement theory must therefore be inferred from the complaint's narrative allegations. The central allegation is that Samsung's products, by providing missed call notifications, necessarily practice the methods claimed in the '872 Patent Compl. ¶9 The complaint does not, however, plead specific facts showing how the accused products determine the cause of a missed call or whether they use the specific network "cause value" required by the claims.

• Identified Points of Contention:
  • Technical Questions: A primary factual dispute will likely concern the underlying mechanism of Samsung's missed call notifications. The core question is whether the accused products actually "extract a cause value contained in a cause information element sent from a network," as mandated by the claims ʼ872 Patent, claim 1 Discovery will be required to determine if the accused systems use this specific network data or an alternative method (e.g., ring counters, timers, or other heuristics) to generate missed call alerts.
  • Scope Questions: The analysis will also raise questions about the scope of the claim language itself. For instance, what constitutes an "indication that the missed received incoming call... was urgent"? ʼ872 Patent, claim 1 The parties may dispute whether a generic missed call alert meets this limitation, or if the claim requires a specific, heightened notification explicitly tied to a network-terminated call.

V. Key Claim Terms for Construction

• The Term: "cause value contained in a cause information element"

  • Context and Importance: This term is the technical linchpin of the asserted claims. The infringement case hinges on whether the accused products use this specific, standardized network data element. Its construction will determine whether alternative methods for detecting the cause of a disconnection fall outside the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Narrower Interpretation: The specification provides specific examples of cause values, such as "RECOVERY ON TIME EXPIRY" and "NORMAL CLEARING" ʼ872 Patent, col. 4:21-22 ʼ872 Patent, col. 4:45-46 It also references established telecommunication standards like ITU-T Q.931 and 3GPP TS 24.008, which define these elements ʼ872 Patent, col. 3:58-64 This evidence may support a construction limiting the term to these or similar standardized protocol messages.
    • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of arguments for a broader interpretation.

• The Term: "an indication that the missed received incoming call was caused by the network and was urgent"

  • Context and Importance: This term defines the user-facing output required by the claim when a network timeout occurs. The dispute will be over what type of notification qualifies as both identifying the network as the cause and conveying urgency.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Narrower Interpretation: The specification suggests a deliberate and specific output, stating that the processing means "associate a high indication of urgency, such as a particular image or the like, to said cause value" ʼ872 Patent, col. 4:35-38 This language could support an argument that the claim requires a specially designed alert, not just any standard notification.
    • Evidence for a Broader Interpretation: The claim language itself is open-ended. A party could argue that any notification for a network-terminated call that is visually or audibly distinct from a user-terminated call inherently serves as an "indication" of urgency, as the patent itself frames such calls as more important ʼ872 Patent, col. 2:41-48

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Samsung actively encourages and instructs its customers on how to use the infringing products, citing a sales brochure as an example Compl. ¶11 Contributory infringement is based on the allegation that there are "no substantial noninfringing uses" for the accused products and services Compl. ¶12
• Willful Infringement: The complaint alleges Defendant has known of the '872 patent "from at least the filing date of the lawsuit" Compl. ¶11 Compl. ¶12 It further requests a finding of willfulness and treble damages if discovery reveals pre-suit knowledge of the patent and its infringement Compl. ¶VII.e

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

The resolution of this dispute appears to depend on the answers to two central questions:

1. A core issue will be one of evidentiary proof: What evidence will discovery yield to show that Samsung's accused products perform the specific technical step of "extracting a cause value contained in a cause information element" sent from a network? The complaint currently lacks specific factual allegations on this point, making it a critical area for development.
2. A key question of claim scope and functional mapping will be: Assuming Samsung's products do differentiate between types of missed calls, does the resulting user notification meet the claim requirement of providing "an indication that the missed received incoming call was caused by the network and was urgent"? The case may turn on whether the accused functionality can be mapped onto this specific two-part logical outcome required by the patent.