1
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:25-CV-00334-RWS-RSP
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`DEFENDANTS’ INVALIDITY CONTENTIONS
`
`Pursuant to Local Patent Rules 3-3 and 3-4 and the Court’s Second Amended Docket
`Control Order (Dkt. 52), Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung
`Electronics America, Inc. (“SEA”) (collectively, “Samsung” or “Defendants”) provide these
`Invalidity Contentions and accompanying document production to Plaintiff PayGeo, LLC
`(“PayGeo”).
`I. Overview
`In this action, Plaintiff asserted in its P.R. 3-1 and 3-2 Disclosures of August 25, 2025
`(“Infringement Contentions”) that Defendants allegedly infringe claims 1-3, 22, and 24 of U.S.
`Patent No. 8,554,671 (the “’671 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No.
`10,796,296 (the “’296 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No. 10,937,018
`(the “’018 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No. 11,087,307 (the “’307
`patent”), claims 1-3, 5-8, and 10 of U.S. Patent No. 12,014,347 (the “’347 patent”) (collectively,
`the “Patents-in-Suit” and the “Asserted Claims”).
`
`PAYGEO, LLC,
`
`Plaintiff,
`v.
`SAMSUNG ELECTRONICS CO., LTD,
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 1
`
`
`
`
`
`
`
`34
`authored by the same inventor. Thus, a skilled artisan seeking to solve these problems would have
`looked to these cited references in combination.
`Thus, the motivation or reason to combine the teachings of the prior art references disclosed
`herein is found in the references themselves and in: (1) the nature of the problem being solved;
`(2) the express, implied, and inherent teachings of the prior art; (3) the knowledge of persons of
`ordinary skill in the art; (4) the fact that the prior art is generally directed towards the same
`problem; (5) the predictable results obtained in combining the different elements of the prior art;
`(6) the use of a known technique to improve similar devices, methods, or products in the same
`way; (7) the predictable results obtained in applying a known technique to a known device,
`method, or product ready for improvement; (8) the finite number of identified predictable solutions
`having a reasonable expectation of success; and/or (9) known work in various technological fields
`that could be applied to the same or different technological fields based on design incentives or
`other market forces.
`1. ’671 Patent
`Table 4: Exemplary Anticipatory and Combinations
`for the Asserted Claims of the ’671 Patent
`Chart Prior Art References
`A1 Look either alone or in combination with one or more of Stallings,
`Tumminaro, Lin, Lyons, Griffin, Delean, Gandhi, and/or Taveau
`A2 Lin either alone or in combination with one or more of Stallings, Tumminaro,
`Look, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A3 Tumminaro either alone or in combination with one or more of Stallings,
`Look, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A4 Pharris either alone or in combination with one or more of Lin, Stallings,
`Tumminaro, Look, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 2
`
`
`
`
`
`
`
`35
`Chart Prior Art References
`A5 PayPal Mobile alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A6 Venmo alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A7 Taveau alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`
`The prior art identified above, and in the attached ’671 charts, individually anticipate and/or
`can properly be combined in multiple ways to demonstrate the obviousness of the Asserted Claims
`of the ’671 patent. Various combinations of the references would have naturally been considered
`as part of the exercise of ordinary skill by one skilled in the art. The references disclosed in the
`attached charts and herein are also directed to the same or similar features as the purported
`invention claimed in the Asserted Claims of the ’671 patent. To the extent Plaintiff contends that
`any of these features solved a problem in the art, the references cited herein show that that problem
`was known to those of ordinary skill and had already been solved using obvious solutions.
`To that end, the Asserted Claims of the ’671 patent simply combine elements already
`disclosed and well known in the art and yield no more than what one skilled in the art would have
`expected from such a combination. For example, with respect to the ’671 patent, when confronted
`with the alleged problems described in the ’671 patent, one of ordinary skill in the art at the time
`of the alleged invention would have been motivated to consider the techniques taught by the prior
`art cited in these Invalidity Contentions. Consideration of the teachings of this prior art, both
`individually and in combination, would necessarily lead to the alleged invention claimed in the
`’671 patent. This is demonstrated by the cited prior art, which disclose all of the elements of the
`Asserted Claims of the ’671 patent, as well as motivations to modify or combine their individual
`teachings. One of skill in the art would have been motivated to either modify the prior art identified
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 3
`
`
`
`
`
`
`
`36
`in the claim charts or to combine that prior art in the manner indicated by, for example, their
`background knowledge, design incentives, effects of demands known to the design community, or
`other market forces. Moreover, the cited prior art share commonalities. To the extent it is argued
`that any cited prior art does not expressly disclose a particular claim or element, it would have
`been inherent in the disclosure and/or obvious to a person of ordinary skill in the art to include the
`claimed element to perform the invention as claimed in the ’671 patent.
`As described in the attached charts, all the elements of the Asserted Claims of the ’671
`patent were commonplace before the alleged date of inventions. For each element, there exists
`evidence from the cited prior art that it was well known in the art prior to the date of invention. To
`the extent it is argued that any of the cited prior art references, systems, and/or products do not
`anticipate the Asserted Claims, it would have been obvious to a person of ordinary skill in the art
`that the Asserted Claims are merely combinations of well-known methods and systems resulting
`in expected results.
`Additionally, Defendants hereby incorporate by reference the motivations to combine
`references set forth during the prosecution of the Asserted Claims of the ’671 patent, including the
`statements and reasoning set forth by the examiner, as to why it would have been obvious to modify
`or combine references to arrive at the limitations of the Asserted Claims of the ’671 patent.
`Defendants also incorporate by reference the admissions made in the ’671 patent and/or during
`prosecution regarding what was already known in the art.
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 4
`
`
`
`
`
`
`
`59
`desired security level configuration setting is set to a plurality of security levels.”
`(claim 6).
`Accordingly, these claims—and any claim(s) depending directly or indirectly therefrom—may be
`invalid under 35 U.S.C. § 112, ¶ 2, or 35 U.S.C. § 112(b) as indefinite.
`IV. P.R. 3-4: Document Production Accompanying Invalidity Contentions
`Defendants have produced documents, including SamPay_00061731 –
`SamPay_00068036, pursuant to P.R. 3-4(a) and P.R. 3-4(b). In addition, pursuant to P.R. 3-4(a)
`and under the Protective Order in this action, Defendants are making source code available in the
`Washington, D.C. office of their counsel.
`V. Invalidity Under 53 U.S.C. § 101 and Defendants’ Subject Matter Eligibility
`Contentions
`The Asserted Claims of the Patents-in-Suit are invalid under 35 U.S.C. § 101 for failing to
`recite patent-eligible subject matter. Defendants incorporate by reference herein their Subject
`Matter Eligibility Contentions concurrently served with these Invalidity Contentions.
`
`Dated: November 3, 2025
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Christopher T. Blackford
`Melissa R. Smith
`Texas State Bar No. 24001351
`GILLAM & SMITH LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`Tel: (903) 934-8450
`Fax: (903) 934-9257
`melissa@gillamsmithlaw.com
`
`Gerald F. Ivey
`Parmanand K. Sharma (pro hac vice)
`Christopher T. Blackford (pro hac vice)
`Nicholas A. Cerulli (pro hac vice)
`Christina Ji-Hye Yang (pro hac vice)
`Connor M. McGregor (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 5
`
`
`
`
`
`
`
`60
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Tel: (202) 408-4000
`Fax: (202) 408-4400
`gerald.ivey@finegan.com
`parmanand.sharma@finnegan.com
`christopher.blackford@finnegan.com
`nicholas.cerulli@finnegan.com
`christina.yang@finnegan.com
`connor.mcgregor@finnegan.com
`
`Charles H. Suh (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street, 8th Floor
`Reston, V A 20190-6023
`Telephone: (571) 203-2700
`Facsimile: (202) 408-4400
`charles.suh@finnegan.com
`
`Benjamin R. Schlesinger (pro hac vice)
`Benjamin A. Saidman (pro hac vice)
`Wyatt L. Bazrod (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`271 17th St. NW Suite 1400
`Atlanta, GA 30363-6209
`Telephone: (404) 653-6400
`Facsimile: (202) 408-4400
`benjamin.schlesinger@finnegan.com
`benjamin.saidman@finnegan.com
`wyatt.bazrod@finnegan.com
`
`Sneha Nyshadham (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`3300 Hillview Ave., 2nd Floor
`Palo Alto, CA 94304
`Tel: (650) 849-6600
`Fax: (650) 849-6666
`sneha.nyshadham@finnegan.com
`
`Attorneys for Defendants
`Samsung Electronics Co., Ltd. &
`Samsung Electronics America, Inc.
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 6
`
`
`
`
`
`
`
`61
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on November 3, 2025, copies of the foregoing
`Defendants’ Invalidity Contentions and Exhibits have been served to Plaintiff through its counsel
`of record via email.
`/s/ Seth D. Katz
`Seth D. Katz
`Case Manager
`
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 7
`
`
`
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:25-CV-00334-RWS-RSP
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`DEFENDANTS’ INVALIDITY CONTENTIONS
`
`Pursuant to Local Patent Rules 3-3 and 3-4 and the Court’s Second Amended Docket
`Control Order (Dkt. 52), Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung
`Electronics America, Inc. (“SEA”) (collectively, “Samsung” or “Defendants”) provide these
`Invalidity Contentions and accompanying document production to Plaintiff PayGeo, LLC
`(“PayGeo”).
`I. Overview
`In this action, Plaintiff asserted in its P.R. 3-1 and 3-2 Disclosures of August 25, 2025
`(“Infringement Contentions”) that Defendants allegedly infringe claims 1-3, 22, and 24 of U.S.
`Patent No. 8,554,671 (the “’671 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No.
`10,796,296 (the “’296 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No. 10,937,018
`(the “’018 patent”), claims 1-2, 4, 6-9, 11, and 13-14 of U.S. Patent No. 11,087,307 (the “’307
`patent”), claims 1-3, 5-8, and 10 of U.S. Patent No. 12,014,347 (the “’347 patent”) (collectively,
`the “Patents-in-Suit” and the “Asserted Claims”).
`
`PAYGEO, LLC,
`
`Plaintiff,
`v.
`SAMSUNG ELECTRONICS CO., LTD,
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 1
`
`
`
`
`
`
`
`34
`authored by the same inventor. Thus, a skilled artisan seeking to solve these problems would have
`looked to these cited references in combination.
`Thus, the motivation or reason to combine the teachings of the prior art references disclosed
`herein is found in the references themselves and in: (1) the nature of the problem being solved;
`(2) the express, implied, and inherent teachings of the prior art; (3) the knowledge of persons of
`ordinary skill in the art; (4) the fact that the prior art is generally directed towards the same
`problem; (5) the predictable results obtained in combining the different elements of the prior art;
`(6) the use of a known technique to improve similar devices, methods, or products in the same
`way; (7) the predictable results obtained in applying a known technique to a known device,
`method, or product ready for improvement; (8) the finite number of identified predictable solutions
`having a reasonable expectation of success; and/or (9) known work in various technological fields
`that could be applied to the same or different technological fields based on design incentives or
`other market forces.
`1. ’671 Patent
`Table 4: Exemplary Anticipatory and Combinations
`for the Asserted Claims of the ’671 Patent
`Chart Prior Art References
`A1 Look either alone or in combination with one or more of Stallings,
`Tumminaro, Lin, Lyons, Griffin, Delean, Gandhi, and/or Taveau
`A2 Lin either alone or in combination with one or more of Stallings, Tumminaro,
`Look, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A3 Tumminaro either alone or in combination with one or more of Stallings,
`Look, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A4 Pharris either alone or in combination with one or more of Lin, Stallings,
`Tumminaro, Look, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 2
`
`
`
`
`
`
`
`35
`Chart Prior Art References
`A5 PayPal Mobile alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A6 Venmo alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`A7 Taveau alone or in combination with one or more of Look, Stallings,
`Tumminaro, Lin, Lyons, Gandhi, Griffin, Delean, and/or Taveau
`
`The prior art identified above, and in the attached ’671 charts, individually anticipate and/or
`can properly be combined in multiple ways to demonstrate the obviousness of the Asserted Claims
`of the ’671 patent. Various combinations of the references would have naturally been considered
`as part of the exercise of ordinary skill by one skilled in the art. The references disclosed in the
`attached charts and herein are also directed to the same or similar features as the purported
`invention claimed in the Asserted Claims of the ’671 patent. To the extent Plaintiff contends that
`any of these features solved a problem in the art, the references cited herein show that that problem
`was known to those of ordinary skill and had already been solved using obvious solutions.
`To that end, the Asserted Claims of the ’671 patent simply combine elements already
`disclosed and well known in the art and yield no more than what one skilled in the art would have
`expected from such a combination. For example, with respect to the ’671 patent, when confronted
`with the alleged problems described in the ’671 patent, one of ordinary skill in the art at the time
`of the alleged invention would have been motivated to consider the techniques taught by the prior
`art cited in these Invalidity Contentions. Consideration of the teachings of this prior art, both
`individually and in combination, would necessarily lead to the alleged invention claimed in the
`’671 patent. This is demonstrated by the cited prior art, which disclose all of the elements of the
`Asserted Claims of the ’671 patent, as well as motivations to modify or combine their individual
`teachings. One of skill in the art would have been motivated to either modify the prior art identified
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 3
`
`
`
`
`
`
`
`36
`in the claim charts or to combine that prior art in the manner indicated by, for example, their
`background knowledge, design incentives, effects of demands known to the design community, or
`other market forces. Moreover, the cited prior art share commonalities. To the extent it is argued
`that any cited prior art does not expressly disclose a particular claim or element, it would have
`been inherent in the disclosure and/or obvious to a person of ordinary skill in the art to include the
`claimed element to perform the invention as claimed in the ’671 patent.
`As described in the attached charts, all the elements of the Asserted Claims of the ’671
`patent were commonplace before the alleged date of inventions. For each element, there exists
`evidence from the cited prior art that it was well known in the art prior to the date of invention. To
`the extent it is argued that any of the cited prior art references, systems, and/or products do not
`anticipate the Asserted Claims, it would have been obvious to a person of ordinary skill in the art
`that the Asserted Claims are merely combinations of well-known methods and systems resulting
`in expected results.
`Additionally, Defendants hereby incorporate by reference the motivations to combine
`references set forth during the prosecution of the Asserted Claims of the ’671 patent, including the
`statements and reasoning set forth by the examiner, as to why it would have been obvious to modify
`or combine references to arrive at the limitations of the Asserted Claims of the ’671 patent.
`Defendants also incorporate by reference the admissions made in the ’671 patent and/or during
`prosecution regarding what was already known in the art.
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 4
`
`
`
`
`
`
`
`59
`desired security level configuration setting is set to a plurality of security levels.”
`(claim 6).
`Accordingly, these claims—and any claim(s) depending directly or indirectly therefrom—may be
`invalid under 35 U.S.C. § 112, ¶ 2, or 35 U.S.C. § 112(b) as indefinite.
`IV. P.R. 3-4: Document Production Accompanying Invalidity Contentions
`Defendants have produced documents, including SamPay_00061731 –
`SamPay_00068036, pursuant to P.R. 3-4(a) and P.R. 3-4(b). In addition, pursuant to P.R. 3-4(a)
`and under the Protective Order in this action, Defendants are making source code available in the
`Washington, D.C. office of their counsel.
`V. Invalidity Under 53 U.S.C. § 101 and Defendants’ Subject Matter Eligibility
`Contentions
`The Asserted Claims of the Patents-in-Suit are invalid under 35 U.S.C. § 101 for failing to
`recite patent-eligible subject matter. Defendants incorporate by reference herein their Subject
`Matter Eligibility Contentions concurrently served with these Invalidity Contentions.
`
`Dated: November 3, 2025
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Christopher T. Blackford
`Melissa R. Smith
`Texas State Bar No. 24001351
`GILLAM & SMITH LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`Tel: (903) 934-8450
`Fax: (903) 934-9257
`melissa@gillamsmithlaw.com
`
`Gerald F. Ivey
`Parmanand K. Sharma (pro hac vice)
`Christopher T. Blackford (pro hac vice)
`Nicholas A. Cerulli (pro hac vice)
`Christina Ji-Hye Yang (pro hac vice)
`Connor M. McGregor (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 5
`
`
`
`
`
`
`
`60
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Tel: (202) 408-4000
`Fax: (202) 408-4400
`gerald.ivey@finegan.com
`parmanand.sharma@finnegan.com
`christopher.blackford@finnegan.com
`nicholas.cerulli@finnegan.com
`christina.yang@finnegan.com
`connor.mcgregor@finnegan.com
`
`Charles H. Suh (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street, 8th Floor
`Reston, V A 20190-6023
`Telephone: (571) 203-2700
`Facsimile: (202) 408-4400
`charles.suh@finnegan.com
`
`Benjamin R. Schlesinger (pro hac vice)
`Benjamin A. Saidman (pro hac vice)
`Wyatt L. Bazrod (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`271 17th St. NW Suite 1400
`Atlanta, GA 30363-6209
`Telephone: (404) 653-6400
`Facsimile: (202) 408-4400
`benjamin.schlesinger@finnegan.com
`benjamin.saidman@finnegan.com
`wyatt.bazrod@finnegan.com
`
`Sneha Nyshadham (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`3300 Hillview Ave., 2nd Floor
`Palo Alto, CA 94304
`Tel: (650) 849-6600
`Fax: (650) 849-6666
`sneha.nyshadham@finnegan.com
`
`Attorneys for Defendants
`Samsung Electronics Co., Ltd. &
`Samsung Electronics America, Inc.
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 6
`
`
`
`
`
`
`
`61
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on November 3, 2025, copies of the foregoing
`Defendants’ Invalidity Contentions and Exhibits have been served to Plaintiff through its counsel
`of record via email.
`/s/ Seth D. Katz
`Seth D. Katz
`Case Manager
`
`
`Patent Owner, PayGeo, LLC - Ex. 2005, p. 7
`
`
`
`
`
`
`
`
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