DCT

2:26-cv-00157

Mobility IP v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00157, E.D. Tex., 02/27/2026
  • Venue Allegations: Venue is alleged against Samsung Electronics America, Inc. based on its maintenance of a "regular and established place of business" in the district, specifically a "flagship campus" in Plano, Texas. Venue is alleged against the foreign parent, Samsung Electronics Co., Ltd., as a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant's mobile devices, including smartphones and watches equipped with the Samsung Wallet (formerly Samsung Pay) mobile payment service, infringe seven U.S. patents related to secure, biometrically-authenticated mobile transactions using near-field communication (NFC).
  • Technical Context: The lawsuit concerns the technology underpinning the rapidly growing market for contactless mobile payments, where users authenticate transactions on a personal device rather than using a physical payment card.
  • Key Procedural History: The complaint alleges that Defendant Samsung has been aware of at least one of the asserted patents (the '772 Patent) since October 2016, when Samsung cited it as prior art during the prosecution of its own patent application. This allegation may be used to support Plaintiff's claim of willful infringement.

Case Timeline

Date Event
2002-07-09 Earliest Priority Date for '772, '807, '513, '412, '187 Patents
2007-01-25 Earliest Priority Date for '345, '924 Patents
2012-04-03 U.S. Patent No. 8,151,345 Issues
2013-10-01 U.S. Patent No. 8,548,924 Issues
2014-07-01 U.S. Patent No. 8,766,772 Issues
2015-01-13 U.S. Patent No. 8,933,807 Issues
2015-09-28 Samsung launches its Samsung Pay mobile payment service
2016-10-25 Date Samsung allegedly became aware of the '772 Patent
2019-03-19 U.S. Patent No. 10,235,513 Issues
2020-07-07 U.S. Patent No. 10,706,412 Issues
2020-09-01 U.S. Patent No. 10,762,187 Issues
2026-02-27 Complaint Filing Date

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

U.S. Patent No. 8,151,345 - "Self-Authorizing Devices"

  • Issued: April 3, 2012

The Invention Explained

  • Problem Addressed: The patent addresses the need to adapt the enhanced security and fraud prevention techniques of physical smartcard systems for use in internet-based transactions, which were becoming more popular US 8,151,345 B1, col. 1:41-47
  • The Patented Solution: The patent describes a "cellular network adapter" that contains both a secure element (for storing financial data) and a secure element reader. This adapter interrogates the secure element, converts the retrieved file information into transaction authorization information, and transmits it over a wireless network, such as a cellular network US 8,151,345 B1, abstract US 8,151,345 B1, col. 2:27-40 A key feature is a security measure where the reader awaits a "startup instruction comprising an unpredictable number" originating over the wireless network before interrogating the secure element US 8,151,345 B1, col. 6:47-59
  • Technical Importance: This approach provided a framework for conducting secure financial transactions on mobile devices over public networks by integrating the reader and secure element functions within the mobile device itself.

Key Claims at a Glance

  • The complaint asserts independent claim 23 Compl. ¶30
  • The essential elements of claim 23 include:
    • A cellular network adapter for a cellular network device configured with a cellular network application interface.
    • A secure element comprising a data file.
    • A secure element reader configured to interrogate the secure element according to ISO 7816-4 to generate file information.
    • A near field communications (NFC) controller bridge chip to convert the file information to an RF signal.
    • A communications controller to receive the file information, convert it into transaction authorization information, and transmit it over a wireless network.
    • A requirement that the secure element reader awaits a startup instruction with an unpredictable number from the wireless network before interrogation.
  • The complaint reserves the right to assert additional claims.

U.S. Patent No. 8,548,924 - "Self-Authorizing Token"

  • Issued: October 1, 2013

The Invention Explained

  • Problem Addressed: The patent addresses the need for secure devices and methods that adapt smartcard security techniques for internet-based transactions US 8,548,924 B2, col. 1:41-47
  • The Patented Solution: The patent describes a physical "token" for transmitting a communications data package to a host device. The token comprises a "mounting structure" (like a circuit board), a secure element affixed to it containing a data file, a secure element interrogator also affixed to it, and a communications controller to transmit the data package US 8,548,924 B2, abstract US 8,548,924 B2, col. 2:54-67 This architecture physically co-locates the components needed to securely access and transmit sensitive data.
  • Technical Importance: This invention defined a physical architecture for a self-contained, secure token that could be integrated into various form factors for conducting secure transactions with host devices.

Key Claims at a Glance

  • The complaint asserts independent claim 60 Compl. ¶42

  • The essential elements of claim 60 include:

    • A token for transmitting a communications data package to a host device.
    • A mounting structure.
    • A secure element affixed to the mounting structure, containing a data file with transaction information.
    • A secure element interrogator affixed to the mounting structure, configured to interrogate the secure element and generate the data package.
    • A communications controller affixed to the mounting structure, configured to receive the data package from the interrogator and transmit it to the host device.

  • The complaint reserves the right to assert additional claims.

  • Multi-Patent Capsule: U.S. Patent No. 8,766,772

    • Patent Identification: U.S. Patent No. 8,766,772, "System and Method for Providing Secure Transactional Solutions", issued July 1, 2014.
    • Technology Synopsis: The patent describes a mobile device that uses a biometric input (e.g., fingerprint) to authorize a transaction. The processor receives a request via a radio frequency antenna, compares the received biometric data with stored biometric information, and, if they match, provides the transaction information.
    • Asserted Claims: The complaint asserts independent claim 9 Compl. ¶54
    • Accused Features: The complaint alleges that Samsung's devices, which include fingerprint sensors, NFC antennas, processors, and memory, practice the claimed invention when performing mobile payments Compl. ¶¶55-64

  • Multi-Patent Capsule: U.S. Patent No. 8,933,807

    • Patent Identification: U.S. Patent No. 8,933,807, "System and Method for Providing Secure Transactional Solutions", issued January 13, 2015.
    • Technology Synopsis: The patent describes a mobile device comprising both cellular and short-range RF circuitry. An authentication module uses stored biometric information to verify a user's identity, and upon successful authentication, a transaction module provides transaction information via the short-range RF circuitry.
    • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶70
    • Accused Features: The complaint alleges that Samsung's devices, with their cellular radios, NFC circuitry, biometric readers, and processors, infringe by using biometric authentication to enable NFC-based mobile payments Compl. ¶¶72-79

  • Multi-Patent Capsule: U.S. Patent No. 10,235,513

    • Patent Identification: U.S. Patent No. 10,235,513, "System and Method for Providing Secure Identification Solutions", issued March 19, 2019.
    • Technology Synopsis: The patent describes a mobile device where a processor receives a request from a point-of-sale (POS) terminal via a short-range radio circuit. The processor then compares newly received biometric data with stored fingerprint information and, upon a match, transmits the transaction information back to the POS terminal. The invention also claims the mobile device body that houses these components.
    • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶84
    • Accused Features: The complaint alleges infringement by Samsung's devices, which house a fingerprint scanner, NFC circuit, memory, and processor that collectively perform the claimed steps during a mobile payment transaction Compl. ¶¶86-95

  • Multi-Patent Capsule: U.S. Patent No. 10,706,412

    • Patent Identification: U.S. Patent No. 10,706,412, "System and Methods for Providing Secure Transactional Solutions", issued July 7, 2020.
    • Technology Synopsis: The patent describes a processor-driven method in a mobile device. The processor establishes a secure connection with a POS device via short-range RF, prompts the user for biometric information, authenticates the user, and in response, generates a key, secures the payment information, and transmits both the key and the secured information to the POS device.
    • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶100
    • Accused Features: The complaint alleges that the processors in Samsung's devices perform these steps when conducting a Samsung Pay transaction, which it describes as following the EMV standard involving the generation and transmission of a cryptogram (key) Compl. ¶¶102-113

  • Multi-Patent Capsule: U.S. Patent No. 10,762,187

    • Patent Identification: U.S. Patent No. 10,762,187, "System and Method for Providing Secure Transactional Solutions", issued September 1, 2020.
    • Technology Synopsis: The patent describes a mobile device with a "secure module" that, after a successful biometric authentication, is configured to generate a key, encrypt both the key and the stored payment information, and provide this encrypted package for use in a transaction via short-range RF circuitry.
    • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶118
    • Accused Features: The complaint alleges that Samsung's devices, through their use of tokenization and cryptogram generation in the EMV payment process, practice the claimed steps of generating a key, encrypting information, and providing it for a transaction Compl. ¶¶120-129

III. The Accused Instrumentality

Product Identification

  • The Accused Instrumentalities are Samsung's mobile devices, including the Galaxy S, A, Z Fold, Z Flip, Watch, and Tab series, that are equipped with the Samsung Wallet (formerly Samsung Pay) mobile payment service Compl. ¶15 Compl. ¶21 The Samsung Galaxy S23 Ultra is identified as an exemplary device Compl. ¶21

Functionality and Market Context

  • The accused functionality enables users to make contactless payments at point-of-sale (POS) terminals Compl. ¶15 A user first authenticates their identity on the device, typically using a biometric method like a fingerprint scan Compl. ¶25 The device then uses Near Field Communication (NFC) to transmit tokenized payment information to an NFC-enabled POS terminal to complete the transaction Compl. ¶15 Compl. ¶22 The complaint highlights that Samsung is a leading provider of these devices and that the mobile payment market represents over a trillion dollars in annual transaction volume in the U.S. Compl. ¶14 Compl. ¶21 The complaint includes a teardown image of the Samsung Galaxy S23 Ultra motherboard, identifying an NXP chip as providing both NFC and secure element functionality.

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,151,345 Infringement Allegations

Claim Element (from Independent Claim 23) Alleged Infringing Functionality Complaint Citation Patent Citation
A cellular network adapter for a cellular network device configured with a cellular network application interface comprising: The Accused Instrumentalities, such as the Samsung Galaxy S23 Ultra, are alleged to be the cellular network adapter. ¶31 col. 2:27-30
a secure element comprising a data file; The Accused Instrumentalities include a secure element (e.g., an embedded Secure Element or eSE) which stores a tokenized Device Account Number that serves as a surrogate for the user's primary account number. This constitutes the data file. ¶33 col. 4:3-10
a secure element reader ... configured to interrogate the secure element by executing file system functions according to ISO 7816-4 and to generate file information from the secure element data file; The Accused Instrumentalities allegedly emulate ISO 7816-4 cards and include processors configured to access the transaction information from the secure element. This is alleged to be the secure element reader. ¶35; ¶34 col. 2:30-36
a near field communications controller bridge chip to convert the file information to an RF data signal for an external reader; and The teardown of the Galaxy S23 Ultra allegedly shows an NXP chip providing NFC functionality, which is alleged to be the NFC controller bridge chip. ¶31; ¶8 col. 2:37-40
a communications controller configured to receive the file information ... convert ... and to transmit the transaction authorization information ... over a wireless network ...; The one or more processors on the device's motherboard are alleged to be the communications controller, which converts the file information into a unique cryptogram (transaction authorization information) and transmits it. ¶31; ¶34; ¶36 col. 2:41-55
wherein the wireless network comprises a cellular network and the secure element reader ... is configured to await a startup instruction comprising an unpredictable number originating over the cellular wireless network prior to interrogating the secure element. The complaint alleges that the secure element reader is configured to perform this step. ¶36 col. 6:47-59

U.S. Patent No. 8,548,924 Infringement Allegations

Claim Element (from Independent Claim 60) Alleged Infringing Functionality Complaint Citation Patent Citation
A token for transmitting a communications data package to a host device, the token comprising: The Accused Instrumentalities are alleged to be the claimed token, which transmits data to a host device (e.g., a POS terminal). ¶43; ¶48 col. 2:54-56
a mounting structure; The motherboard of the accused devices, such as the Samsung Galaxy S23 Ultra, is alleged to be the mounting structure. ¶44 col. 2:57-57
a secure element affixed to the mounting structure, the secure element including a data file containing transaction information; An embedded Secure Element (eSE) chip is affixed to the motherboard and contains a tokenized Device Account Number, which is the data file with transaction information. ¶44; ¶45; ¶46 col. 2:58-61
a secure element interrogator affixed to the mounting structure and configured to interrogate the secure element ... and to generate the communications data package...; and A processor, also on the motherboard, is alleged to be the interrogator that accesses the transaction information from the secure element and combines it into a data package (a unique cryptogram). ¶44; ¶47 col. 2:62-67
a communications controller affixed to the mounting structure and configured to receive the communications data package ... and to transmit the communications data package to the host device. The same processor is alleged to also act as the communications controller, transmitting the data package to the host device (POS terminal). ¶44; ¶48 col. 3:1-5
  • Identified Points of Contention:
    • Scope Questions: For the '345 patent, a central question will be whether the term "cellular network adapter", which is claimed as being for a cellular device, can be construed to read on the entire cellular device itself, as alleged by the Plaintiff. For the '924 patent, a question may arise regarding the scope of "mounting structure" and whether a general-purpose motherboard meets this limitation, or if a more specific structure is required by the patent.
    • Technical Questions: The complaint's infringement theory for the '345 patent hinges on the final limitation of claim 23, requiring the device to "await a startup instruction comprising an unpredictable number originating over the cellular wireless network". The complaint makes a conclusory allegation that the accused devices meet this element Compl. ¶36 but provides no specific factual support explaining how this function is performed. The evidence for this highly specific security step will be a critical point of contention.

V. Key Claim Terms for Construction

  • The Term: "startup instruction comprising an unpredictable number" (from claim 23 of the '345 Patent)

    • Context and Importance: This term defines a specific security protocol that appears to be a core aspect of the invention of the '345 patent. The complaint's infringement allegation for this element is conclusory, making the construction of this term pivotal. Practitioners may focus on this term because its interpretation will determine the type and quality of evidence Plaintiff must produce to prove this element is met.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint does not provide specific evidence, but a party could argue that any random number or nonce exchanged during a communication handshake before data access could satisfy the "unpredictable number" requirement.
      • Evidence for a Narrower Interpretation: The specification of the '345 patent describes this feature in the context of the secure element reader awaiting this instruction from the wireless network prior to interrogating the secure element, suggesting a specific challenge-response security sequence before any internal data access is initiated US 8,151,345 B1, col. 6:47-59 This suggests a specific, ordered security protocol, not just any random number exchange.

  • The Term: "mounting structure" (from claim 60 of the '924 Patent)

    • Context and Importance: The complaint alleges the phone's motherboard is the "mounting structure" Compl. ¶44 The viability of this assertion depends on how broadly the term is construed. Practitioners may focus on this term because if it is construed narrowly to mean a dedicated carrier or housing for the secure element, as opposed to a general printed circuit board, it could create a mismatch with the accused products' architecture.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not appear to explicitly define "mounting structure". A party could argue it should be given its plain and ordinary meaning, which could encompass any structure, like a motherboard, to which components are affixed.
      • Evidence for a Narrower Interpretation: The patent figures (e.g.,Fig. 10 of US 8,548,924 B2) show a "smartcard module" with a "module top" and "module bottom" where the die are mounted. A party could argue that "mounting structure" refers to this specific module-level packaging, not a general device motherboard, which could narrow the claim scope.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges facts that may support such a claim, stating that Samsung's press releases and support documents instruct users on how to perform the allegedly infringing payment process (Compl. ¶25.
  • Willful Infringement: Plaintiff alleges willful infringement for the '772, '345, and '924 patents Compl. ¶133 Compl. ¶135 The willfulness allegation for the '772 patent is based on alleged pre-suit knowledge, asserting that Samsung has been aware of the patent since at least October 25, 2016, when Samsung cited it as prior art in its own patent prosecution Compl. ¶66 The willfulness allegations for the '345 and '924 patents are based on knowledge acquired upon service of the complaint Compl. ¶38 Compl. ¶50

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

  • A core issue will be one of evidentiary proof: can Plaintiff provide sufficient factual evidence to demonstrate that Samsung's devices perform the specific security step of awaiting a "startup instruction comprising an unpredictable number originating over the cellular wireless network," as required by claim 23 of the '345 patent, a point on which the complaint is presently silent?
  • A second key issue will be one of claim construction: can the term "cellular network adapter" in the '345 patent be construed to cover an entire smartphone, and can "mounting structure" in the '924 patent be construed to mean a general motherboard, or do these terms require more specific component structures that may not be present in the accused devices?
  • A final question will center on willfulness: will Plaintiff's allegation that Samsung cited the '772 patent as prior art in its own patent application be sufficient to establish pre-suit knowledge and support a finding of willful infringement, potentially leading to enhanced damages?
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