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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`PLAINTIFF PAYGEO, LLC’S DISCLOSURE OF ASSERTED
`CLAIMS AND PRELIMINA RY INFRINGEMENT
`CONTENTIONS UNDER LOCAL P ATENT RULES 3-1 AND 3-2
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`Pursuant to Sections 3-1 and 3-2 of the Local Patent Rules, Plaintiff PayGeo, LLC
`(“PayGeo”) makes the following Disclosure of Asserted Claims and Preliminary Infringement
`Contentions to Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`(collectively, “Samsung”), including the attached claim charts attached hereto as Appendix A,
`Appendix B, Appendix C, Appendix D, and Appendix E (collectively, the “Infringement
`Charts”) for the Accused Products (as defined below) of U.S. Patent Nos. 8,554,671 (the “’671
`Patent”), 10,796,296 (the “296 Patent”), 10,937,018 (the “018 Patent”), 11,087,307 (the “307
`Patent”), and 12,014,347 (the “347 Patent”) (collectively, the “Asserted Patents”), and the
`accompanying document production.
`PayGeo makes this disclosure based upon information presently known and reasonably
`available to it as of the date hereof. This disclosure and the accompanying Infringement Charts
`are preliminary as discovery has not yet commenced in this action such that Samsung has not
`produced any technical documents. As PayGeo’s investigations are ongoing, PayGeo reserves
`PAYGEO, LLC,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO. LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.,
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`Defendants.
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`Case No. 2:25-cv-00334-RWS-RSP
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`the right to amend, modify, supplement, and/or narrow any portion of this disclosure including,
`but not limited to, the identification of asserted claims, the products and/or services accused of
`infringement, and the bases and manner of infringement, as necessary and appropriate, as the
`case develops, in accordance with the Federal Rules of Civil Procedure, this Court’s Local Rules,
`including Local Patent Rule 3-6, and any orders entered in this action, in light of future
`document production, interrogatory responses, admissions, disclosures, fact witness testimony,
`expert discovery, and any other discovery, any amendments to the pleadings, any additional
`items of evidence, or for any other reason authorized by statute, rule, or applicable case law.
`PayGeo further reserves the right to rely upon the opinions of one or more experts in support of
`the contentions in this disclosure in accordance with the scheduling order to be entered in this
`action.
`I. P.R. 3-1(a): Asserted Claims
`Based on the information presently known to PayGeo and without the benefit of relevant
`discovery or a claim construction order, PayGeo provides the following contentions pursuant to
`Local Patent Rule 3-1(a):
`Samsung has infringed and continues to infringe the following claims (collectively, the
`“Asserted Claims”):
` Claims 1-3, 22 and 24 of the ’671 Patent,
` Claims 1-2, 4, 6-9, 11 and 13-14 of the ’296 Patent,
` Claims 1-2, 4, 6-9, 11 and 13-14 of the ’018 Patent,
` Claims 1-2, 4, 6-9, 11 and 13-14 of the ’307 Patent, and
` Claims 1-3, 5-8 and 10 of the ’347 Patent.
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`Samsung has directly infringed and continues to directly infringe the Asserted Claims
`pursuant to 35 U.S.C. § 271(a), including by making, using, selling, and/or offering for sale the
`Accused Products in the United States and/or by importing them into the United States.
`Additionally, Samsung has directly infringed and continues to directly infringe the Asserted
`Claims pursuant to 35 U.S.C. § 271(a) by acting as the final assembler of infringing networks
`because it controls, assembles, and combines the components to form the infringing systems
`described in the accompanying Infringement Charts. According to the Local Patent Rules and
`any forthcoming discovery order in this case, PayGeo reserves the right to supplement the
`Infringement Charts with source code citations once it has been made available for inspection.
`Specifically, PayGeo will supplement elements in the Asserted Claims with source code citations
`if they are capable of being met as a result of functionality in source code or through a
`combination of source code and hardware elements. Samsung’s direct infringement of the
`Asserted Claims in some instances is also a result of joint infringement.
`In addition, Samsung is inducing infringement and contributing to infringement of the
`Asserted Claims under 35 U.S.C. §§ 271(b) and (c) by providing detailed instructions in its
`documentation, encouraging, directing, and requiring third parties, including its customers, to
`directly infringe by using and installing the Accused Products in the United States. For example,
`Samsung induces infringement the Asserted Patents because it directly provides services,
`directions, and documentation to its users directing them on how to use the Accused Products.
`Samsung has known or was willfully blind to the fact that it is contributing to the infringement of
`the Asserted Claims of the Asserted Patents. Further, Samsung’s software is not a staple article
`or commodity of commerce suitable for substantial non-infringing use.
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`PayGeo prepared this disclosure and accompanying Infringement Charts without the
`benefit of Samsung’s noninfringement theories. To the extent that Samsung contends that it does
`not literally infringe a claim, Samsung infringes under the doctrine of equivalents. Once PayGeo
`receives Samsung’s non-infringement positions, if any, PayGeo may demonstrate how the
`described functionality of the Accused Products is at most insubstantially different from the
`claimed functionality and performs the same function in the same way to achieve the same result.
`II. P.R. 3-1(b): Accused Instrumentalities
`Based on the information presently known to PayGeo, and without the benefit of relevant
`discovery or a claim construction order, PayGeo accuses of infringement the technologies used
`to operate and/or support Samsung’s mobile payment and authentication platform and associated
`services, as set forth in PayGeo’s accompanying Infringement Charts, including the following
`components:
` “Samsung Phones” which is defined to include Galaxy S series including the S
`series devices compatible with 5G (S6, S6 Edge, S6 Edge+, S7, S7 Edge, S8, S8+,
`S9, S9+, S10E, S10, S10+, S10 Lite, S20, S20+, S20 Ultra, S20 FE, S21, S21+,
`S21 Ultra, S21 FE, S22, S22+, S22 Ultra, S23, S23+, S23 Ultra, S24, S24+, S24
`Ultra, S25, S25+, S25 Ultra); Galaxy Note series including the Note series
`devices compatible with 5G (Note 5, Note 5 FE, Note 7, Note 8, Note 9, Note 10,
`Note 10+, Note 10 Lite, Note 20, Note 20 Ultra); Galaxy A series including the A
`series devices compatible with 5G (A5, A7, A8, A8+, A8 STAR, A9, A9 Pro,
`A15, A16, A80, A23, A24, A25, A26, A30S, A31, A32, A33, A34, A35, A36,
`A42, A50S, A51, A52, A52S, A53, A54, A55, A56, A71, A72, A73); Galaxy
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`Fold series (Fold, Z Fold2, Z Fold3, Z Fold4, Z Fold5, Z Fold6, Z Fold7); and
`Galaxy Flip series (Z Flip3, Z Flip4, Z Flip5, Z Flip6, Z Flip7).
` “Samsung Watches” which is defined to include Gear S2, Gear S3, Gear Sport,
`Galaxy Watch, Galaxy Watch Active, Galaxy Watch Active2, Galaxy Watch3,
`Galaxy Watch4, Galaxy Watch4 Classic, Galaxy Watch5, Galaxy Watch5 Pro,
`Galaxy Watch6, Galaxy Watch6 Classic, Galaxy Watch7, Galaxy Watch Ultra,
`Galaxy Watch FE.
` “Samsung point of sale (POS) systems” which is defined to include Tizen Kiosk
`Touch Display, Galaxy XCover series (XCover Pro, XCover 5, XCover 6 Pro,
`XCover 7 Pro), Galaxy Tab Pro, Galaxy Tab S series (S5e, S6, S6 Lite, S6 5G,
`S7, S7+, S7 FE, S8, S8+, S8 Ultra, S9, S9+, S9 Ultra, S9 FE, S9 FE+, S10+, S10
`Ultra, S10 FE, S10 FE+), Galaxy Tab A series (A, A7, A7 Lite, A8, A9, A9+),
`and Galaxy Tab Active series (Active, Active 2, Active Pro, Active 3, Active 4
`Pro, Active 5).
`The “’671 Accused Products” are Samsung Phones, Samsung Watches, and Samsung
`POS Systems which operate Samsung Wallet, Samsung Pay, Samsung Pass, Samsung Knox, and
`the associated Samsung servers.
`The “’296 Accused Products” are Samsung Phones and Samsung Watches which operate
`Samsung Wallet, Samsung Pay, Samsung Pass, Samsung Knox, and the associated Samsung
`servers.
`The “’018 Accused Products” are Samsung Phones and Samsung Watches which operate
`Samsung Wallet, Samsung Pay, Samsung Pass, Samsung Knox, and the associated Samsung
`servers.
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`The “’307 Accused Products” are Samsung Phones and Samsung Watches which operate
`Samsung Wallet, Samsung Pay, Samsung Pass, Samsung Knox, and the associated Samsung
`servers.
`The “’347 Accused Products” are Samsung Phones which operate Samsung Wallet,
`Samsung Pay, Samsung Pass, Samsung Knox, and Secured Folders.
`The ’671 Accused Products; the ’296 Accused Products, the ’018 Accused Products, the
`’307 Accused Products, and the ’347 Accused Products are collectively referred to as the
`“Accused Products.”
`PayGeo asserts that the Accused Products in the accompanying Infringement Charts,
`incorporated herein by reference (see Appendices A-E), infringe all of the Asserted Claims as
`specified in those accompanying Infringement Charts.
`Due to the early stage of this litigation, the lack of substantial discovery to date, and the
`absence of a claim construction order, the above identification is necessarily limited and
`preliminary in nature. PayGeo reserves the right to amend, modify, supplement or narrow these
`contentions pursuant to the Federal Rules of Civil Procedure, the Court’s Local Rules, the
`discovery order, and the Court’s Scheduling Order, including identifying additional Accused
`Products as it obtains additional information over the course of discovery and in light of a claim
`construction order.
`III. P.R. 3-1(c)-(d): Claim Charts
`Based on the information presently known to PayGeo and without the benefit of relevant
`discovery or a claim construction order, PayGeo provides the Infringement Charts pursuant to
`Local Patent Rules 3-1(c)-(d) at the following appendices:
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` Appendix A: Infringement Chart for the ’671 Patent showing how the ’671
`Accused Products infringe the Asserted Claims of the ’671 Patent;
` Appendix B: Infringement Chart for the ’296 Patent showing how the ’296
`Accused Products infringe the Asserted Claims of the ’296 Patent;
` Appendix C: Infringement Chart for the ’018 Patent showing how the ’018
`Accused Products infringe the Asserted Claims of the ’018 Patent;
` Appendix D: Infringement Chart for the’307 Patent showing how the the’307
`Accused Products infringe the Asserted Claims of the ’307 Patent; and
` Appendix E: Infringement Chart for the ’347 Patent showing how the ’347
`Accused Products infringe the Asserted Claims of the ’347 Patent.
`PayGeo does not contend that any element of any Asserted Claim is governed by 35
`U.S.C. §112(¶6).
`The Accused Products literally infringe each Asserted Claim. To the extent that Samsung
`contends that an element of an Asserted Claim is not literally present in an Accused Products,
`PayGeo will provide a responsive showing that the claim element is, at a minimum, present in
`the Accused Products under the doctrine of equivalents. PayGeo’s Infringement Charts set forth
`its currently known doctrine of equivalents theories without the benefit of Samsung’s non-
`infringement positions, discovery or the Court’s claim construction order.
`PayGeo has subdivided the Asserted Claims in the Infringement Charts to explain where
`the Accused Products meet each claim element. These subdivisions are not to be taken as an
`indication of the boundaries of claim elements with respect to the doctrine of equivalents, or any
`other issue.
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`Due to the early stage of this litigation, the lack of discovery to date (including discovery
`concerning Samsung’s products and/or services), and the absence of a claim construction order,
`the Infringement Charts are necessarily limited and preliminary in nature. PayGeo reserves the
`right to amend, modify, supplement, or narrow any portion of these contentions pursuant to
`Local Patent Rule 3-6, including, but not limited to, the identification of asserted claims,
`products, features or services accused of infringement, and the bases and manner of
`infringement. For instance, the Accused Products may infringe the Asserted Claims in multiple
`ways, e.g., multiple aspects of the Accused Products may satisfy certain claim elements. While
`the Infringement Charts show how exemplary aspects of the Accused Products satisfy claim
`elements, there may be additional ways that they satisfy those elements. PayGeo reserves the
`right to provide an alternative claim mapping or infringement contentions for such Accused
`Products or other products and services.
`IV. P.R. 3-1(e): Priority Date
`Pursuant to Local Patent Rule 3-1(e), PayGeo hereby identifies that each Asserted Claim
`of the Asserted Patents is entitled to a priority date of July 18, 2011.
`V. P.R. 3-1(f): Own Patent-Practicing Products
`Based on the information presently known to PayGeo and PayGeo’s present
`understanding, PayGeo provides the following contentions pursuant to Local Patent Rule 3-1(f):
`PayGeo does not identify any of its own products as practicing the patents. PayGeo has
`not offered for sale or sold any product that embodies any claim of any of the Asserted Patents.
`PayGeo reserves the right to amend, modify, supplement, or narrow these contentions
`pursuant to Local Patent Rule 3-6.
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`VI. P.R. 3-2: Accompanying Document Production
`Pursuant to Local Patent Rule 3-2, PayGeo provides herewith a document production
`which includes, inter alia, a copy of the file history for each of the Asserted Patents. PayGeo
`makes this production based upon information presently known as reasonably available to it as of
`the date hereof. PayGeo reserves the right to supplement its document production as the case
`develops over the course of discovery and as additional information becomes known or available
`to it. PayGeo has also provided documents identified in the table below.
`Bates Range Reference
`PayGeo 001195 – PayGeo 001254 ’671 Patent
`PayGeo 001255 – PayGeo 001525 ’671 Pat ent File History
`PayGeo 000001 – PayGeo 000061 ’296 Patent
`PayGeo 000062 – PayGeo 000285 ’296 Pat ent File History
`PayGeo 000286 – PayGeo 000346 ’018 Patent
`PayGeo 000347 – PayGeo 000599 ’018 Pat ent File History
`PayGeo 000600 – PayGeo 000660 ’307 Patent
`PayGeo 000661 – PayGeo 000891 ’307 Pat ent File History
`PayGeo 000892 – PayGeo 000952 ’347 Patent
`PayGeo 000953 – PayGeo 001194 ’347 Pat ent File History
`PayGeo 002526 – PayGeo 002536 Documents that may reflect aspect of
`conception or reduction to practice
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`Dated: August 25, 2025
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`By: /s/ James Hannah
`Paul J. Andre (pro hac vice)
`Lisa Kobialka (pro hac vice)
`James Hannah (pro hac vice)
`Christina Finn
`HERBERT SMITH FREEHILLS
`KRAMER (US) LLP
`333 Twin Dolphin Drive, Suite 700
`Redwood Shores, CA 94065
`Telephone: (650) 752-1700
`paul.andre@hsfkramer.com
`lisa.kobialka@hsfkramer.com
`james.hannah@hsfkramer.com
`christina.finn@hsfkramer.com
`
`Elizabeth L. DeRieux (Bar No. 05770585)
`Capshaw DeRieux LLP
`114 E. Commerce St.,
`Gladewater, Texas 75647
`Telephone: 903-845-5770
`ederieux@capshawlaw.com
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`Attorneys for Plaintiff
`Pa
`yGeo, LLC
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that on August 25, 2025, a tru e and correct copy of the
`foregoing PLAINTIFF PAYGEO, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND
`PRELIMINARY INFRINGEMENT CONTENTIONS UNDER LOCAL PATENT RULES
`3-1 AND 3-2 was served via electronic mail upon counsel of record for Defendants as indicated:
`Melissa R. Smith
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone: (903) 934-8450
`melissa@gillamsmithlaw.com
`
`Christopher T. Blackford
`Nicholas A. Cerulli
`Gerald F. Ivey
`Connor Michael McGregor
`Parmanand K. Sharma
`Christina Ji-Hye Yang
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER LLP
`901 New York Ave., NW
`Washington, DC 20001
`Telephone: (202) 408-4000
`christopher.blackford@finnegan.com
`nicholas.cerulli@finnegan.com
`gerald.ivey@finnegan.com
`connor.mcgregor@finnegan.com
`parmanand.sharma@finnegan.com
`christina.yang@finnegan.com
`
`Benjamin A. Saidman
`Benjamin R. Schlesinger
`Wyatt Bazrod
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER LLP
`271 17th Street NE, Suite 1400
`Atlanta, GA 30363
`Telephone: (404) 653-6416
`benjamin.saidman@finnegan.com
`benjamin.schlesinger@finnegan.com
`wyatt.bazrod@finnegan.com
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`Sneha Nyshadham
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER LLP
`3300 Hillview Avenue
`Stanford Research Park
`Palo Alto, CA 94304
`Telephone: (650) 849-6766
`sneha.nyshadham@finnegan.com
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`Attorneys for Defendants
`Samsung Electronics Co., Ltd. and Samsung
`Electronics America, Inc.
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`
`/s/ James Hannah
`James Hannah
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