Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 1 of 115 PagelD #:
`1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`PAYGEO, LLC,
`Case No. 2:25-cv-334
`Plaintiff,
`DEMAND FOR JURY TRIAL
`V.
`
`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`Defendants.
`
`N N N N N N N N N N N N N
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff PayGeo, LLC (“Plaintiff” or “PayGeo”) files this Complaint for Patent
`Infringement and Demand for Jury Trial against Samsung Electronics Co., Ltd. (“SEC”) and
`Samsung Electronics America, Inc. (“SEA”) (collectively “Defendants” or “Samsung’) and
`alleges as follows:
`
`THE PARTIES
`
`1. PayGeo is a limited liability company organized and existing under the laws of
`Texas, with its principal place of business located at 508 South Airport Boulevard, South San
`Francisco, CA 94080-6912.
`
`2. SEC is a corporation organized and existing under the laws of the Republic of
`Korea, with its principal place of business located at 129 Samsung-Ro, Yeongtong-gu, Suwon-si,
`Gyeonggi-do, 16677, Republic of Korea. SEC designs and makes products, including
`telecommunication and mobile phone products that are sold throughout the United States,
`
`including in this District, and introduces products into the stream of commerce that incorporate
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 2 of 115 PagelD #:
`2
`
`infringing technology knowing that they would be sold in this District and elsewhere in the
`United States.
`
`3. SEA is a corporation organized and existing under the laws of New York, with its
`principal place of business located at 85 Challenger Road, Ridgefield Park, New Jersey 07660.
`SEA has been registered to do business in Texas under File Number 0011028006 since at least
`June 10, 1996. SEA may be served with process through its registered agent, CT Corporation
`System, located at 1999 Bryan Street, Suite 900, Dallas, Texas 75201. SEA is a wholly-owned
`subsidiary of SEC. SEA conducts business operations at multiple locations within this District.
`For example, SEA maintains offices located at 6625 Excellence Way, Plano, Texas 75023; a
`retail store located at 2601 Preston Road, Frisco, Texas 75034; and a support center located at
`3580 Preston Road, Suite 100, Frisco, Texas 75034. SEA markets and sells products, including
`consumer electronics and mobile devices, throughout the United States, including in this District,
`and introduces products into the stream of commerce that incorporate infringing technology
`
`knowing that they would be sold in this District and elsewhere in the United States.
`
`JURISDICTION AND VENUE
`4. Jurisdiction and venue for this action are proper in this District.
`5. This action for patent infringement arises under the patent laws of the United
`
`States, 35 U.S.C. § 101 ef seq. This Court has original subject matter jurisdiction over this
`controversy pursuant to 28 U.S.C. §§ 1331 and 1338(a) because this is a civil action arising
`under the Patent Act.
`
`6. Each Defendant is subject to this Court’s personal jurisdiction consistent with the
`principles of due process and the Texas Long Arm Statute. Tex. Civ. Prac. & Rem. Code
`
`§§ 17.041, et seq.
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 3 of 115 PagelD #:
`3
`
`7. This Court has personal jurisdiction over each Defendant at least because, through
`each Defendant’s own acts and through the acts of the other Defendants acting as its agent,
`representative, or alter ego, they each (i) have a presence or a regular and established place of
`business in the State of Texas and this District; (ii) have purposefully availed themselves of the
`rights and benefits of the laws of the State of Texas and this District; (iii) have done and are
`doing substantial business in the State of Texas and this District, directly or through
`intermediaries, both generally and with respect to the allegations in this Complaint, including
`their one or more acts of infringement in the State of Texas and this District; (iv) maintain
`continuous and systematic contacts in the State of Texas and this District; and (v) place products
`alleged to be infringing in this Complaint in the stream of commerce, directly or through
`intermediaries, with awareness that those products are likely destined for use, offered for sale,
`sold, and imported into the State of Texas and this District.
`
`8. For example, Defendants have authorized retailers and distributors in the State of
`Texas and this District for the products alleged to be infringing in this Complaint, and
`Defendants have derived substantial revenues from their infringing acts occurring within the
`State of Texas and this District.
`
`0. Defendants have established sufficient minimum contacts with the State of Texas
`and this District such that they should reasonably and fairly anticipate being brought into court in
`the State of Texas and this District without offending traditional notions of fair play and
`substantial justice, and Defendants have purposefully directed activities at residents of the State
`of Texas and this District. Moreover, the patent infringement claims alleged herein arise out and
`
`are related to one or more of the foregoing activities. A substantial part of the events giving rise
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 4 of 115 PagelD #:
`4
`
`to Plaintiffs’ claims, including acts of patent infringement, have occurred in the State of Texas
`and this District.
`
`10. Venue is also proper in this Court under 28 U.S.C. §§ 1391(b) and (c¢) and
`1400(b) because each Defendant is subject to personal jurisdiction in this District and has
`committed acts of infringement in this District. Each Defendant, through its own acts and
`through the acts of each other Defendant acting as its agent, representative, or alter ego, makes,
`uses, sells, offers to sell, and imports infringing products within this District, has a continuing
`presence within this District, and has the requisite minimum contacts with this District such that
`venue 1s proper.
`
`11. For example, SEA maintains a regular and established place of business in this
`District located at 6625 Excellence Way, Plano, Texas 75023 and has committed acts of
`infringement in this District, as described herein. Further, SEC directs and controls the actions
`of SEA such that it too maintains a regular and established place of business in this District
`located at 6625 Excellence Way, Plano, Texas 75023 and has committed acts of infringement in
`this District. Additionally, venue is proper as to SEC, a foreign corporation, because suits
`against foreign entities are proper in any judicial district under 28 U.S.C. § 1391(c)(3).
`
`12. Further, Defendants have submitted to venue and the exercise of personal
`jurisdiction in this District in patent infringement actions previously filed by other parties. See,
`e.g., Answer, 99 11-20, The Rsch. Found. for the S.U.N.Y., et. al. v. Samsung Elecs. Co., et. al.,
`No. 2:23-cv-00141 (E.D. Tex. Aug. 10, 2023), ECF No. 25; Answer, 49 13, 18, Cal. Inst. Tech v.
`Samsung Elecs. Co., No. 2:21-cv-00446 (E.D. Tex. Apr. 5, 2022), ECF No. 19; Answer to
`Amended Complaint, 9 6, 7, Jawbone Innovations LLC v. Samsung Elecs. Co., No. 2:21-cv-
`
`00186 (E.D. Tex. Dec. 9, 2021), ECF No. 27.
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 5 of 115 PagelD #:
`5
`
`PAYGEQO’S INNOVATIONS AND ASSERTED PATENTS
`
`13. PayGeo’s founder, Rabih Salem Ballout, invented digital wallet technology that
`facilitates and executes financial transactions between mobile devices. PayGeo’s inventions
`enable its users to transfer, receive, or otherwise conduct financial transactions in a secured
`mobile environment. Mr. Ballout combined his love for electronics and his hobby for building
`circuitry for different applications in creating a platform that enables users to conduct various
`financial transactions using a mobile device.
`
`14. Inrecognition of its innovations, the United States Patent and Trademark Office
`(“USPTO”) has awarded PayGeo numerous patents covering its secure financial transaction
`platform.
`
`15. On October 8, 2013, the USPTO duly and legally issued U.S. Patent No.
`8,554,671 (the “’671 Patent”), entitled “System and Associated Method and Service for
`Providing a Platform that Allows for the Exchange of Cash Between Members in a Mobile
`Environment.” The *671 Patent lists Rabih Salem Ballout as its inventor and is assigned to
`PayGeo. Attached hereto as Exhibit 1 is a true and correct copy of the *671 Patent.
`
`16. The *671 Patent generally discloses a method and system for initiating a financial
`transaction via an application on a mobile device; communicating the transaction between
`devices using uniquely generated codes; using the codes to authenticate the transaction; and
`executing the transaction.
`
`17. On October 6, 2020, the USPTO duly and legally issued U.S. Patent No.
`10,796,296 (the “’296 Patent”), entitled “Kit, System and Associated Method and Service for
`
`Providing a Platform to Prevent Fraudulent Financial Transactions.” The *296 Patent lists Rabih
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 6 of 115 PagelD #:
`6
`
`Salem Ballout as its inventor and is assigned to PayGeo. Attached hereto as Exhibit 2 is a true
`and correct copy of the 296 Patent.
`
`18. The °296 Patent generally discloses a system and method for registering various
`payment methods from various payment sources within an application on a mobile device;
`authenticating the payment methods by communicating between the device and corresponding
`credit card companies, financial institutions, and/or other third-party entities; storing the payment
`methods within the application; accessing the application using a security credential; initiating a
`financial transaction using a function identifier within the application; selecting a registered
`payment method; communicating the transaction between the device and the corresponding
`credit card company, financial institution, or other third-party entity; requesting execution of the
`transaction from the corresponding credit card company, financial institution, or other third-party
`entity; and providing a notification of the outcome of the transaction.
`
`19. On March 2, 2021, the USPTO duly and legally issued U.S. Patent No.
`10,937,018 (the “’018 Patent”), entitled “Kit, System and Associated Method and Service for
`Providing a Platform to Prevent Fraudulent Financial Transactions.” The ’018 Patent lists Rabih
`Salem Ballout as its inventor and is assigned to PayGeo. Attached hereto as Exhibit 3 is a true
`and correct copy of the 018 Patent.
`
`20. The *018 Patent generally discloses a system and method for registering and
`authenticating various payment methods from various payment sources within an application on
`a mobile device by communicating between the device and corresponding credit card companies,
`financial institutions, and/or other third-party entities; storing the payment methods within the
`application; accessing the application using a security credential; initiating a financial transaction
`
`using a function identifier within the application; selecting a registered payment method;
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 7 of 115 PagelD #:
`7
`
`communicating the transaction between the device and the corresponding credit card company,
`financial institution, or other third-party entity; requesting execution of the transaction from the
`corresponding credit card company, financial institution, or other third-party entity; and
`providing a notification of the outcome of the transaction.
`
`21. On August 10, 2021, the USPTO duly and legally issued U.S. Patent No.
`11,087,307 (the “’307 Patent”), entitled “Kit, System and Associated Method and Service for
`Providing a Platform to Prevent Fraudulent Financial Transactions.” The *307 Patent lists Rabih
`Salem Ballout as its inventor and is assigned to PayGeo. Attached hereto as Exhibit 4 is a true
`and correct copy of the 307 Patent.
`
`22. The 307 Patent generally discloses a system and method for registering various
`payment methods from various payment sources within an application on a mobile device;
`authenticating the payment methods by communicating between the device and corresponding
`financial institutions and/or other third-party entities; storing the payment methods within the
`application; accessing the application using a security credential; initiating a financial transaction
`using a function identifier within the application; selecting a registered payment method;
`communicating the transaction between the device and the corresponding financial institution or
`other third-party entity; requesting execution of the transaction from the corresponding financial
`institution or other third-party entity; and providing a notification of the outcome of the
`transaction.
`
`23. On June 18, 2024, the USPTO duly and legally issued U.S. Patent No. 12,014,347
`(the “’347 Patent”), entitled “Kit, System and Associated Method and Service for Providing a
`
`Platform to Prevent Fraudulent Financial Transactions.” The ’347 Patent lists Rabih Salem
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 8 of 115 PagelD #:
`8
`
`Ballout as its inventor and is assigned to PayGeo. Attached hereto as Exhibit 5 is a true and
`correct copy of the *347 Patent.
`
`24, The ’347 Patent generally discloses a system and method for setting various
`security credentials on a mobile device; enabling secured access to a local application on the
`device and to features within the application; authenticating access to the application using one
`or more security credentials; and authenticating access to a feature using one or more security
`credentials.
`
`25. The °671, °296, °018, 307, and *347 Patents are collectively referred to herein as
`the “Asserted Patents.”
`
`26. PayGeo owns all rights, title, and interest in and to the Asserted Patents.
`
`27. PayGeo has not offered for sale or sold any product that embodies any claim of
`any of the Asserted Patents, nor has it licensed the Asserted Patents to any third party. Thus,
`PayGeo’s recovery of pre-suit damages for Samsung’s infringement of the Asserted Patents is
`not limited by 35 U.S.C. §287(a).
`
`PATENT ELIGIBILITY
`
`28. All of the Asserted Patents are patent eligible, valid and enforceable. The
`Asserted Patents are not abstract and specifically claim inventive concepts that represent
`significant improvements over conventional systems for conducting electronic financial
`transactions.
`
`29. The claimed inventions of the *671 Patent describe interactions between devices
`and servers that creates a highly secured mobile environment to facilitate financial transactions
`(’671 Patent at 4:49-53) utilizing tokenization technology to encrypt a financial transaction and
`
`to identify a user’s sensitive financial information (id. at 4:66-5:3), and to authenticate financial
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 9 of 115 PagelD #:
`9
`
`transactions utilizing a security level associated with the financial transaction (id. at 9:60-10:23,
`10:64-11:3).
`
`30. The *671 Patent improves the security of facilitating financial transactions
`between mobile devices by requiring a security level access to initiate a financial transaction via
`an application on an initiating mobile device; generating unique codes that identify the financial
`transaction and the user’s sensitive financial information; using servers to transmit the generated
`codes from the initiating mobile device to appropriate financial institutions for verification and
`authentication of the financial transaction request and a reverse code from the financial
`institution back to the initiating mobile device accepting or declining the financial transaction
`request; and executing the financial transaction request accordingly on a receiving mobile
`device.
`
`31. The claims of the 671 Patent describe an inventive concept because they provide
`a novel platform that facilitates financial transactions between mobile stations that
`unconventionally uses uniquely generated codes in lieu of sensitive financial information to
`transfer information relating to the financial transaction between mobile stations; to authenticate
`the transaction with corresponding financial institutions; and to transmit and execute the outcome
`of the transaction accordingly.
`
`32. The claimed inventions of the 296 Patent describe interactions between a mobile
`device, servers, and payment sources to register and authenticate payment methods for use in
`future financial transactions within an application on the mobile device (’296 Patent at 3:66-4:7,
`4:15-19) using bilateral communications between the payment sources of credit cards, financial
`institutions, and/or third-party entities, and the mobile device to store payment methods
`
`associated with a particular payment source on the application within the mobile device (id. at
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 10 of 115 PagelD #:
`10
`
`5:14-20); utilizing function identifiers within the application to initiate a financial transaction
`with another mobile device using a payment method associated with a particular payment source
`(id. at 5:26-31, 6:51-61); facilitating bilateral communications between the payment source and
`the mobile device to execute the financial transaction (id. at 5:3-7, 5:31-33); and transmitting and
`notifying the other mobile device of the outcome of the financial transaction in real-time.
`
`33. The *296 Patent improves the security of registering and storing financial
`information on a local application on a mobile device for use in future financial transactions by
`requiring a security level access to the application on the mobile device; establishing bilateral
`communication links between the mobile device and credit card companies, financial
`institutions, and/or third-party entities; registering payment methods associated with the credit
`card company, financial institution, and/or third-party entity; and storing the payment methods
`on the local application. Additionally, the *296 Patent improves the efficiency of facilitating
`financial transactions between mobile devices by utilizing a phone number associated with a
`receiving mobile device; requesting a financial transaction using an established bilateral
`communication link between an initiating mobile device and appropriate credit card company,
`financial institution, or third-party entity; and generating and transmitting a notification of the
`outcome of the financial transaction in real-time to the initiating mobile device and receiving
`mobile device.
`
`34. The claims of the 296 Patent describe an inventive concept because they provide
`a novel and unconventional use of mobile devices with backend systems and specific
`authentication protocols that store payment methods associated with particular payment sources
`which use bilateral communications and function identifiers to initiate financial transactions with
`
`other mobile devices in real-time in order to protect the financial information of the user.
`
`10
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 11 of 115 PagelD #:
`11
`
`35. The claimed inventions of the 018 Patent describe an application on a mobile
`device configured to communicate between devices, servers, and payment sources to register and
`authenticate payment methods for use in future financial transactions (018 Patent at 4:6-14,
`4:22-26) using bilateral communications between the payment sources of credit cards, financial
`institutions, and/or third-party entities, and the mobile device to store payment methods
`associated with a particular payment source on the application within the mobile device (id. at
`5:10-14, 5:22-28); utilizing function identifiers within the application to initiate a financial
`transaction with another mobile device using a payment method associated with a particular
`payment source (id. at 5:34-39, 6:60-7:3); facilitating bilateral communications between the
`payment source and the mobile device to execute the financial transaction (id. at 5:39-41); and
`transmitting and notifying the other mobile device of the outcome of the financial transaction in
`real-time.
`
`36. The ’018 Patent improves the security of registering and storing financial
`information on a local application on a mobile device for use in future financial transactions by
`requiring a security level access to the application on the mobile device; establishing bilateral
`communication links between the mobile device and credit card companies, financial
`institutions, and/or third-party entities; and registering and storing payment methods associated
`with the credit card company, financial institution, and/or third-party entity on the local
`application. Additionally, the 018 Patent improves the efficiency of conducting financial
`transactions between mobile devices by utilizing a phone number associated with a user of a
`receiving mobile device; requesting a financial transaction using an established bilateral
`communication link between an initiating mobile device and appropriate credit card company,
`
`financial institution, or third-party entity; and generating and transmitting a notification of the
`
`11
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 12 of 115 PagelD #:
`12
`
`outcome of the financial transaction in real-time to the initiating mobile device and receiving
`mobile device.
`
`37. The claims of the 018 Patent describe an inventive concept because they provide
`a novel and unconventional system architecture that integrates the use of mobile devices with
`backend systems and servers secured by specific authentication protocols that store payment
`methods associated with particular payment sources which uses bilateral communications and
`function identifiers to initiate financial transactions with other mobile devices in real-time in
`order to protect the financial information of the user.
`
`38. The claimed inventions of the 307 Patent describe an application on a mobile
`device configured to communicate between devices, servers, and payment sources to register and
`authenticate payment methods for use in future financial transactions (’307 Patent at, 4:11-19,
`4:27-31) using bilateral communications between the payment sources of financial institutions
`and/or third-party entities, and the mobile device to store payment methods associated with a
`particular payment source on the application within the mobile device (id. at 5:16-20, 5:27-33);
`utilizing function identifiers within the application to initiate a financial transaction with another
`mobile device using a payment method associated with a particular payment source (id. at 5:39-
`44, 6:65-7:8); facilitating bilateral communications between the payment source and the mobile
`device to execute the financial transaction (id. at 5:44-46); and transmitting and notifying the
`other mobile device of the outcome of the financial transaction in real-time.
`
`39. The *307 Patent improves the security of registering and storing financial
`information on a local application on a mobile device for use in future financial transactions by
`requiring a security level access to the application on the mobile device; establishing bilateral
`
`communication links between the mobile device and financial institutions and/or third-party
`
`12
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 13 of 115 PagelD #:
`13
`
`entities; and registering and storing payment methods associated with the financial institution
`and/or third-party entity on the local application. Additionally, the 307 Patent improves the
`efficiency of facilitating and verifying financial transactions between mobile devices by utilizing
`a phone number associated with a user of a receiving mobile device; requesting an electronic
`financial transaction using an established bilateral communication link between an initiating
`mobile device and appropriate financial institution or third-party entity; and generating and
`transmitting a notification of the outcome of the financial transaction in real-time to the initiating
`mobile device and receiving mobile device.
`
`40. The claims of the *307 Patent describe an inventive concept because they provide
`a novel and unconventional system architecture that integrates the use of mobile devices with
`backend systems and servers that store payment methods associated with particular payment
`sources by establishing and using bilateral communications and function identifiers to initiate
`financial transactions with other mobile devices in real-time use of mobile devices; and that
`protects the sensitive financial information of the user through specific authentication protocols.
`
`41. The claimed inventions of the *347 Patent describe a method and system of
`registering security levels on a mobile device (’307 Patent at 5:29-35); and enabling secure
`access to local applications on the mobile device and to features within the local applications by
`assigning one or more registered security levels (id. at 10:32-39, 11:26-34, 11:35-41).
`
`42. The ’347 Patent improves the security of access to local applications on a mobile
`device that facilitate financial transactions and stores sensitive financial information by enabling
`a user to use a biometric scan as a type of security credential; to register and store one or more
`security credentials on a mobile device; and to designate one or more security credentials to
`
`provide access to applications and its features on a mobile device.
`
`13
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 14 of 115 PagelD #:
`14
`
`43. The claims of the *347 Patent describe an inventive concept because they provide
`a novel multi-level security platform for securing access to local applications and its features on
`a mobile device that is highly secure and efficient to the end user. Additionally, the’347 Patent
`provides a non-generic and specialized system for collecting, registering, and storing biometric
`information for use in security settings on a mobile device and its applications.
`
`SAMSUNG’S INFRINGEMENT OF PAYGEQO’S PATENTS
`
`44. Samsung is a multibillion-dollar worldwide technology conglomerate. Samsung
`is a global leader in the mobile device and wearable device market, which includes smartphones,
`tablets, and smartwatches.
`
`45. In or around September 5, 2013, Samsung launched “Samsung Knox,” a mobile
`security solution that protects applications and data by strictly defining what each process is
`
`allowed to do and which data it can access.
`
`Platform Philosophy
`
`% Knox
`
`Keeping your data safe N\\ %
`and secure .
`
`With defense-grade protection built right in,
`Knox Vault has your data security covered.
`
`KNnox Vault
`
`Shop secure devices Play Knox video
`
`Ex. 6 (https://www.samsung.com/us/business/solutions/samsung-knox/). It is “an end-to-end
`
`solution that provides security hardening from the hardware through the application layer.”
`
`14
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 15 of 115 PagelD #:
`15
`
`Samsung KNOX Available for Use by
`Consumers
`
`on September 5, 2013
`
`Share
`
`Samsung Electronics announced the commercial availability of Samsung KNOX for use by consumers.
`Samsung KNOX is an end-to-end solution that provides security hardening from the hardware through the
`
`application layer. Samsung KNOX implements a concept called “container” that is a separate secure execution
`environment for a set of pre-screened applications to run and store data.
`
`Ex. 7 (https://news.samsung.com/global/samsung-knox-available-for-use-by-consumers).
`
`46. In or around September 28, 2015, Samsung launched “Samsung Pay,” a mobile
`payment service capable of making purchases in person, online, or via a mobile app. Ex. 8
`
`(https://news.samsung.com/global/samsung-announces-launch-dates-for-groundbreaking-mobile-
`
`payment-service-samsung-pay).
`
`47. Samsung also created “Samsung Pass,” an application for storing payment cards
`and various types of digital content that utilizes biometric authentication software to provide
`secure access for its users. Samsung Pass is capable of sensing and registering physiological
`data such as a fingerprint or iris associated with a user of a Samsung smartphone or smartwatch
`
`to verify the identity of the user.
`
`15
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 16 of 115 PagelD #:
`16
`
`what is samsung pass
`
`These days a mobile phone is an essential part of everyday life. Now, thanks to Samsung Pass, you can customise various services to handle
`daily tasks and keep yourimportant information in one secure place. Learn more about this app below.
`
`Ex. 9 (https://www.samsung.com/levant/support/apps-services/what-is-samsung-pass/).
`
`48. In or around June 2022, Samsung integrated Samsung Pay and Samsung Pass into
`“Samsung Wallet” in certain countries, including the United States. Samsung Wallet maintained
`Samsung Pay’s ability to facilitate mobile payments via a Samsung device and Samsung Pass’s
`ability to facilitate secured access using biometric authentication, and further integrates Samsung
`
`Knox’s ability to provide secure access to users’ sensitive data.
`
`Use Samsung Wallet on your Galaxy F
`phone
`
`Samsung Pass and Samsung Pay are getting better by coming together to make the new
`Samsung Wallet app! But hang on, Samsung's Blockchain Wallet app will also be joining
`them later on. Whether you're a long-time Samsung Pay user or a new Galaxy customer
`who wants a digital wallet, migrating to and using the new app will be simple. Keep
`reading to learn more about Samsung Wallet and what it has to offer.
`
`Ex. 10 (https://www.samsung.com/us/support/answer/ANS10001347/);
`
`16
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document 1 Filed 04/02/25 Page 17 of 115 PagelD #:
`17
`
`Check out Samsung Wallet's new
`features
`
`With everything we carry in our pockets or bags these days, it’s easy to forget something at
`home, like your keys or credit cards. This won’t be an issue when you use the Samsung Wallet
`app on your Galaxy phone to store all of your important day-to-day assets, like your car and
`house keys. You can even store boarding passes so getting through the airport is a breeze.
`Samsung Wallet can also link up with cryptocurrency accounts, such as Coinbase and Gemini, so
`you can manage your digital currency.
`
`Payments >
`Samsung Pass >
`Digital keys >
`Digital assets >
`Boarding passes >
`
`see, e.g., Ex. 11 (https://www.samsung.com/us/support/answer/ANS00091982/).
`
`49. The “Accused System and Devices” as used herein refers collectively to
`Samsung’s mobile payment and authentication platform and associated services including
`Samsung Wallet, Samsung Pay, Samsung Pass, Samsung Knox, and Samsung’s servers and
`software which are used to implement and operate the platform and associated services, and the
`following Samsung devices that are manufactured, used, tested, imported, sold, offered for sale,
`and imported by or on behalf of Samsung:
`
`e Galaxy A Series
`e Galaxy J Series
`
`e Galaxy Note Series
`
`17
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 18 of 115 PagelD #:
`18
`
`e QGalaxy S Series
`e (Galaxy XCover Series
`e QGalaxy Z Series
`e (Galaxy M Series
`e Galaxy Watch, Watch Active, Watch Active 2
`e (Galaxy Watch 3
`e Galaxy Watch 4, Watch 4 Classic
`e (Galaxy Watch 5, Watch 5 Pro
`e (Galaxy Watch 6, Watch 6 Classic
`e Galaxy Watch 7 Series
`e (Galaxy Watch Ultra
`e Galaxy Watch FE
`50. Samsung makes, uses, sells, offers for sale, and/or imports into the United States
`and this District the Accused System and Devices for facilitating secure electronic financial
`transactions that infringe the Asserted Patents.
`51. Samsung has infringed and continues to infringe one or more claims of each of
`the Asserted Patents by engaging in acts that constitute infringement under 35 U.S.C. § 271,
`including but not necessarily limited to making, using, selling, and/or offering for sale, in this
`District and elsewhere in the United States, and/or importing into this District and elsewhere in
`the United States the Accused System and Devices.
`52. Inaddition to directly infringing the Asserted Patents pursuant to 35 U.S.C.
`§ 271(a), literally and/or under the doctrine of equivalents, Samsung indirectly infringes all the
`
`Asserted Patents under 35 U.S.C. §§ 271(b) and (c¢), literally and/or under the doctrine of
`
`18
`
`
`
`
`
`
`
`
`Case 2:25-cv-00334-RWS-RSP Document1 Filed 04/02/25 Page 19 of 115 PagelD #:
`19
`
`equivalents. Samsung induces infringement of the Asserted Patents by instructing, directing
`and/or requiring others, including its customers, purchasers, users, and developers, to meet claim
`elements, literally and/or under the doctrine of equivalents, of the Asserted Patents. Samsung
`contributorily infringe